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The County has told Parties of Record there will be no public comment at the August 20 appeal hearing. Below is our letter objecting to that — read it, then add your name.

August 17, 2026

VIA HAND DELIVERY AND ELECTRONIC MAIL

John M. Butrick, Deputy County Attorney
Legal Department
County of Sandoval
Post Office Box 40
Bernalillo, New Mexico 87004
jbutrick@sandovalcountynm.gov

Re: Objections Related to Appeal of Planning and Zoning Commission Denial, Case No. CU-26-001 (Placitas Telecommunications Tower), Hearing Before the Board of County Commissioners, August 20, 2026, 10:00 a.m.

Dear Mr. Butrick:

The undersigned Parties of Record in the above-referenced appeal write to formally object to the County's position as communicated by your email to Ed Garner, Ph.D. on August 13, 2026 that "there will be no public statements" at the August 20, 2026 hearing before the Board of County Commissioners, and to raise additional objections regarding the record on which that appeal will be decided. These positions are contrary to the County's own written procedures and to New Mexico law, and we ask that they be addressed before the hearing.

I. The County's Own Written Procedures Promise Parties of Record an Opportunity to Be Heard

The written guidance previously furnished by the County Attorney's office to appellants and participants in these proceedings expressly distinguishes between general public testimony and testimony from "Parties of Record." (Copy enclosed.) Section 4 of that guidance, titled "Public Testimony vs. Parties of Record," states:

"Because this is an appeal 'on the record,' the Board will only hear from the Parties of Record. These are the people who spoke or submitted written comments at the first hearing. If someone from the general public attends who did not participate in the first hearing, the Chair may not allow them to speak, as their comments would constitute 'new evidence.'"

Numerous members of the public, including the undersigned, appeared and/or submitted written comments at the Planning and Zoning Commission hearing that resulted in the denial of the conditional use permit at issue in this appeal. Under the County's own written procedures, we are Parties of Record entitled to be heard at the August 20 hearing. Your office's blanket statement that "there will be no public statements" directly contradicts this written procedure and would deny Parties of Record the opportunity the County itself has promised.

II. The Procedural Script Provided Compounds the Problem, Because the Applicant and the Appellant Are the Same Party

The "Chairman's Procedural Script and Checklist" you provided was prepared for a different matter, Case No. ZNCH-25-005 (a Zone Map Amendment application by Evan Kinsley), not this case, CU-26-001. To the extent the County intends to apply that same format to this appeal, it produces an absurd result that independently deprives Parties of Record of any opportunity to be heard.

That script allocates presentation time exclusively between two roles: the "Appellant" (15 minutes) and the "Appellee/Applicant" (20 minutes). That structure presumes the Appellant and the Applicant are different parties, so that both sides of the underlying dispute — the applicant that sought approval, and the party appealing the outcome — are represented and heard.

In this case, however, the Applicant and the Appellant are the same party: Sun State Towers applied for the conditional use permit, the Planning and Zoning Commission denied it, and Sun State Towers is now the Appellant asking the Board to reverse that denial. If the Board follows the script as written, Sun State Towers would occupy both the 15-minute "Appellant" slot and the 20-minute "Appellee/Applicant" slot, consuming the entirety of the time allotted for argument, while the Parties of Record who actually opposed the project and spoke against it before the Planning and Zoning Commission would be given no time to speak at all. That result cannot be reconciled with the County's own instructions describing Parties of Record's right to be heard, nor with New Mexico law.

III. New Mexico Law Requires an Opportunity to Be Heard

NMSA § 3-21-6(B) provides that "No zoning regulation, restriction or boundary shall become effective, amended, supplemented or repealed until after a public hearing at which all parties in interest and citizens shall have an opportunity to be heard." (Copy enclosed.) Excluding Parties of Record from the August 20 hearing, whether by categorical statement that "there will be no public statements," or by a procedural format that leaves them no allotted time, would violate this statutory guarantee.

IV. The Appeal Is Confined to the Record, and the Underlying Application Was Itself Defective

The Sandoval County Wireless Telecommunications Facilities Siting Ordinance (Ord. No. 03-10-16-11A) ("WTFS Ordinance") reinforces the "on the record" limits described above. Section 34 of the WTFS Ordinance provides that "[a]ny review of a decision of the Zoning Commission by the County Board shall be confined to the record of the proceedings."

The Parties of Record objected at the hearing on May 19, 2026 that the Property Owner's Agent Authorization Form required by Section 7.B of the WTFS Ordinance had not been properly executed. Racquel Huslig, who signed the Authorization Form in February 2026, was not the owner of the subject parcel and therefore lacked authority to authorize the Application. That defect was reflected in at least two of the Planning and Zoning Commission's conclusions supporting its unanimous denial of the Application, including its findings of "[u]ndisputed and uncured misrepresentations and deficiencies in the Applicant's application" and unanswered questions as to "whether the Applicants received valid authorization to sign the application from the underlying Property owners."

V. The Applicant's June 9, 2026 Authorization Form Is New Evidence Outside the Closed Record

The record in this matter closed at the conclusion of the Planning and Zoning Commission hearing on May 19, 2026. When the Applicant submitted its appeal on or about June 25, 2026, it attached a new Authorization Form dated June 9, 2026, three weeks after the record closed, purporting to cure the defect described above.

Because the June 9, 2026 Authorization Form did not exist, and was not part of the record, at the time the Planning and Zoning Commission closed the hearing and rendered its decision, there is no legitimate basis for including it in, or considering it as part of, the record on this on-the-record appeal. We respectfully request written confirmation that the June 9, 2026 Authorization Form has not been, and will not be, viewed by, provided to or considered by any member of the Board of County Commissioners in connection with this appeal.

VI. General Objection to Untimely Materials

Despite our in-person request to the Planning and Zoning Department, we have not received a copy of the official record that will be before the Board on August 20, 2026, and accordingly have not had the opportunity to determine whether other materials have been added to, or removed from, the record as it existed at the close of the Planning and Zoning Commission hearing on May 19, 2026. We reserve, and hereby raise, a general objection to the admission of any material, written or oral, that was not timely submitted to the Planning and Zoning Commission on or before May 19, 2026.

This concern is heightened, not diminished, by the County's position that there will be no opportunity for Parties of Record to speak at the August 20 hearing. We understand that the Applicant, Sun State Towers, will be permitted to speak. If Parties of Record are simultaneously barred from speaking, there will be no opportunity for anyone to object, in real time, to new factual assertions or exhibits the Applicant may attempt to introduce at the hearing itself. Denying Parties of Record any opportunity to be heard therefore does more than exclude us from the proceeding, it removes a crucial check against the introduction of new evidence in violation of the "on the record" limits of Section 34 of the WTFS Ordinance.

VII. Status of the Section 3-21-6(C) Protest Analysis

As you know, we have submitted a protest consistent with NMSA § 3-21-6(C), which provides that the underlying zoning action may not become effective absent the heightened vote of the Board if the owners of 20% or more of the affected areas have protested the proposed zoning action. Please advise, in writing, the status of the County's analysis and determination regarding that protest and whether a heightened vote of the Board will be required.

VIII. Preservation of the Record

This letter is submitted to ensure the record for the August 20, 2026 hearing reflects that Parties of Record requested, and were denied, the opportunity to be heard; that the Application was challenged as defectively authorized; and that we object to the inclusion of the June 9, 2026 Authorization Form and any other untimely material in the record. This letter preserves all rights and remedies arising from these objections, including on further appeal.

IX. Requests

Accordingly, we request that the County:

  1. Withdraw or clarify the position that there will be no public statements at the August 20, 2026 hearing, and confirm that Parties of Record, those who spoke or submitted written comments at the Planning and Zoning Commission hearing, will be afforded a meaningful opportunity to be heard, consistent with the County's own written instructions and NMSA § 3-21-6(B);
  2. Confirm which procedural script and time allocations will actually govern the August 20, 2026 hearing on Case No. CU-26-001, given that the script provided to date pertains to a different case;
  3. Confirm in writing that the Applicant's June 9, 2026 Authorization Form has not been, and will not be, provided to, viewed by or considered by the Board, and that the record before the Board is limited to what was before the Planning and Zoning Commission as of the close of the May 19, 2026 hearing;
  4. Provide a paginated copy of the official record that will be before the Board for the August 20, 2026 hearing promptly to allow time for review before the hearing;
  5. Provide this letter, together with its enclosures, to each member of the Board of County Commissioners and place it in the record for the August 20, 2026 hearing;
  6. Provide written notice of any decision issued on this appeal; and
  7. Acknowledge receipt of this letter in writing.

A copy of this letter is being hand-delivered to the Planning and Zoning Department with a request for an endorsed copy showing receipt.

Please contact me with any questions.

This letter may be signed in counterpart by any number of Parties of Record. Parties of Record signing in person complete one line in ink, including printed name, mailing address, and date. Parties of Record who wish to join by email reply to notowerplacitas@gmail.com with words such as "I join in and adopt this letter" together with their printed name and mailing address; upon receipt, that information is entered on the signature page on the signer's behalf, and the confirming email is retained as the record of the signer's assent. A final, consolidated signature page is provided to the County with the delivered letter.

Respectfully submitted by the undersigned Parties of Record.

Enclosures: NMSA § 3-21-6; Appellant Instructions.
cc: Doraida Arias, Sandoval County Planning and Zoning Department

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