Draft Environmental Impact Statement
Shorts School Road Am Antenna Structures 6

2 PROPOSED ACTION and ALTERNATIVES

2.1 Project History

On October 11, 2000, S-R Broadcasting applied to Snohomish County for permits to construct a
new transmitter site for KRKO-AM at the Shorts School Road site, consisting of eight antennas,
five at 466 feet tall, and three at 425 feet tall; all antenna structures were to be supported by guy
wires, and because of FAA regulations related to their height, all were proposed to be lighted and
marked with orange and white aviation marking paint. Public notice of the proposed antenna
project was published November 1, 2000 in The Herald and November 8, 2000 in the Snohomish
Tribune. Snohomish County Planning and Development Services (�PDS�) determined the
application to be complete by letter dated 11/27/00. Shortly thereafter, two groups opposed to
the project formed: Harvey Field (�Harvey�) and Citizens To Preserve The Upper Snohomish
River Valley (�CPUSRV�). During the public comment period on the project, approximately
414 comment letters both in support of the project and in opposition to the project were received
by the County. Included among these letters were comments from the United States Fish and
Wildlife Service, the Washington State Department of Fish and Wildlife, and the National
Oceanic and Atmospheric Administration. In addition, CPUSRV leaders were afforded the
opportunity to meet twice with County officials to express their concerns about the project.
Those meetings included Steve Holt, then director of Planning and Development Services (PDS)
and Erik Olson, project lead for PDS.

First Project Revision

In early December, Snohomish County officials placed the statutory 120-day decision deadline
for the project on hold to allow for additional fact gathering. In response to public comments,
PDS requested additional information from Applicant S-R Broadcasting, including information
on avian interactions with communication structures, photographic simulations, a Critical Areas
Study, an RF Mitigation Plan, a Site-Selection Report, an acoustical analysis, lighting analysis,
real-estate evaluations, skydiving analysis, ballooning analysis, and an airport traffic, approach,
and takeoff analysis, in addition to the geotechnical and soils analyses the Applicant had already
provided to the County. On 08/14/01, the Applicant submitted the requested additional
information to PDS together with an amended SEPA checklist document reflecting the additional
information and suggested adjustments requested by the County. On 08/28/01, the County
resumed the 120-day decision calendar. On 10/04/01 both Applicant and representatives of
CPUSRV made presentations to the Snohomish County Agricultural Advisory Board. Following
that meeting, the Agricultural Advisory Board also submitted comments to PDS for the record.
The County relayed all comments received on the project to the Applicant and requested the
Applicant to address all issues as they were raised. As a result of the public input process, the
Applicant substantially revised the project from five guyed antennas 466 feet tall and three guyed
antennas 425 feet tall, to one self-supporting antenna 425 feet tall and seven self-supporting
antennas below 200 feet in height. After this revision, only one antenna, the 425 foot antenna,
required aviation marking and lighting. The remaining sub-200 foot antennas were exempt from
painting and lighting per FAA regulations, so lighting and painting were eliminated from seven
antennas.
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