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KRPI AM Radio Transmitter Site Supplemental Master Project Narrative

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KRPI AM Radio Transmitter Site Supplemental Master Project Narrative KRPI AM Radio Transmitter Site Supplemental Master Project Narrative KRPI Supplemental Project Narrative Table of Contents I. REVISED LOCATION OF ANTENNA ARRAY ................................................................. 1 II. OTHER REVISIONS AND CORRECTIONS TO APPLICATION MATERIALS.............. 2 III. COMMON PROJECT CONCERNS RAISED IN PUBLIC COMMENTS ...................... 4 A. Radio Frequency Interference ............................................................................................. 4 B. Health Effects of Radiofrequency Emissions ..................................................................... 6 C. Visual and Character Impacts ........................................................................................... 11 D. Impacts to Canadians ........................................................................................................ 14 E. Public Benefit.................................................................................................................... 16 F. Avian Impacts ................................................................................................................... 17 G. Impacts to Property Values ............................................................................................... 19 H. Notice ................................................................................................................................ 19 I. Height Limits .................................................................................................................... 20 IV. TABLE OF AUTHORITIES ............................................................................................ 23 ii KRPI AM Radio Transmitter Site Supplemental Master Project Narrative This Supplemental Project Narrative incorporates and supplements the KRPI Radio Transmitter Site Master Project Narrative submitted with the July 2013 CUP application (July 2013 Project Narrative). It describes technical revisions to the CUP master site plan and related minor changes made to certain of the reports and studies submitted with the original CUP application in July 2013. It also discusses and responds to common project concerns that have been raised through public comment on the project proposal. I. Revised Location of Antenna Array The supplemental materials for the project include a revised CUP master site plan (See Tab 2). This revision shifts the location of the antenna array on the project site from the northeast (NE) portion of the site, as depicted in the original CUP master site plan submitted with the application in July 2013, to the southwest (SW) portion of the site, as depicted in the revised CUP site plan. The antenna array location shown on the revised CUP site plan is consistent with the FCC and FAA approvals for this project. The antenna location coordinates used for the FCC and FAA applications reflect the antenna array in the SW portion of the property. However, shortly after filing the FCC and FAA applications for this project, and as part of the County permit application project due diligence, the applicant identified potential wetland areas in the SW portion of the property. While these areas were identified as non-regulated wetland areas in the Wetland Assessment prepared for the project, the antenna array location was shifted to the NE portion of the site in an effort to avoid the potential for impacts to these areas. As a result, the original CUP application included a CUP master site plan reflecting the NE antenna array location. After submittal of the original CUP site plan, and during the processing of the CUP application, County staff conducted a field visit, verified the Wetlands Assessment conclusions, and confirmed that the small wetlands in the SW corner of the site are not regulated critical areas. This determination allowed the antenna array to be placed back in the SW portion of the site without the potential for impacts to County critical areas. Shifting the antenna array from the NE to the SW portion of the site allows the project to better meet the CUP criteria in the Whatcom County Code, as analyzed in more detail in the July 2013 Project Narrative. In particular, the SW location will minimize visual and aesthetic impacts by allowing for a larger forested buffer to be provided between the antenna array and Tyee Drive and McKenzie Way, thereby reducing the potential risk of impact to views from adjacent properties and the potential for impact to the character of the area. This change to the project site plan also resolves an inconsistency noted by some project comments between the July 2013 CUP master site plan and some of the documents from the federal construction permit process. As indicated above, the SW location depicted on the revised CUP master site plan is now aligned with the antenna structure location coordinates used for the KRPI Supplemental Project Narrative FAA “No Hazard” determinations and with the filed FCC Antenna Structure Registrations. However, the transmitter site drawing submitted with the FCC construction permit application included a drawing depicting the structures in the NE portion of the site, while the antenna location coordinates in the application reflected the array in the SW portion of the site. The coordinates provided to the FCC and FAA have never changed since the original application in 2009, only the mapping. The FAA and FCC coordinates have always reflected the array in the SW corner of the parcel. The drawing submitted to the FCC in 2012 was submitted during the internal process of evaluating the wetlands in the SW portion of the site, and the NE corner array location was then used in anticipation that Whatcom County regulations would require avoidance of construction near those areas. As noted, the subsequent confirmation that these wetlands are not regulated County critical areas eliminates the need to pursue a NE corner location. As noted above, in this revision of the CUP site plan, the shift of the proposed location of the array to the SW brings the structures into the positions consistent with the FAA “No Hazard” determination and Antenna Structure Registration coordinates. This adjustment does not conflict with the FCC construction permit because the Antenna Structure Registrations are controlling. (In addition, FCC permits commonly are adjusted post-construction for array movements on site necessitated by site specific limitations or local permit conditions.) II. Other Revisions and Corrections to Application Materials The revision of the structure locations to the southwest portion of the parcel also allows the applicant to correct several inadvertent errors that occurred in the previously submitted original CUP application materials. First, during the process of reviewing the public comment, the applicant determined that the visual photo simulations and visual impacts analysis of the Visual Resources Technical Report (URS, June 2013) (“Visual Resources Report”) were based upon the FAA coordinates structure locations (in the SW portion of the parcel).1 The revised site plan conforms the antenna structure locations to the FAA coordinates and thus results in a location that is consistent with the June 2013 Visual Resources Report. However, the Visual Resources Report did include minor text references and some map references to the NE corner location. The Project Description in Section 2.0 at page 1 included a reference to the antenna array being located on the east portion of the property, and Figures 1 and 2 of the Visual Resources Report depicted the NE corner location. Figures B1-B10 and C1-C3 each included a small vicinity map in the bottom left corner, which also depicted the NE corner location. Thus, the supplemental project submittal includes copies of the pages of the URS Visual Resources Report that have been corrected to conform and accurately depict the location of the antenna array in the SW portion of the site. (See Tab 4). No other changes to the Visual Resources Report are required because the photo simulations and analysis in the Report address the FAA coordinate SW location for the antenna structures. Second, in the original July 2013 site plan, a minor drafting error mislocated the antenna array elements relative to one another (essentially depicting a mirror image). The revised site 1 The technical process for creating the photosimulations uses the geospatial coordinates in the No Hazard Determinations and Antenna Structure Registrations to place the antenna structures within the landscape. 2 KRPI Supplemental Project Narrative plan also corrects this error, and now accurately depicts the engineered antenna placements within the array in the SW corner location. (See Tab 2). Consistent with the revised site plan, a revised clearing plan is also being submitted here, reflecting the SW corner location for the array (See Tab 3). Third, the Wetlands Assessment submitted with the original July 2013 CUP application makes text references to the location of the antenna array in the NE corner, and includes Figures that reflect the NE corner location. The revised CUP site plan has been provided for re- evaluation to Aqua Terr, the consultant who prepared the Wetlands Assessment. Aqua Terr has reviewed the new location and has prepared an Addendum letter addressing the changed location. (See Tab 5). This Wetlands Assessment Addendum also provides analysis and information responsive to the Whatcom County Critical Areas Biologist request for a new critical areas assessment to address certain
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