Draft Environmental Impact Statement
Shorts School Road Am Antenna Structures 67

c
ompleted, there will be no additional structures of any kind erected on the site. Thus, this
proposal will effectively remove this property from the risk of other types of future
development, and preserve agricultural use of the land.

LU Policy 7.C.6 �The county shall ensure that permitted uses in designated agricultural
lands adjacent to airports are compatible with airport operations and requirements of the
Federal Aviation Administration.�

The transmission structures are not �obstructions� or �hazards� to air safety under
applicable regulations. An FAA �No Hazard� Determination has been issued for the
proposal. The proposal is consistent with published safety and land use compatibility
recommendations of the Washington State Department of Transportation, and will not
interfere with operations at Harvey Field. A settlement with Harvey Field was reached
during the hearing process.

Capital Facilities

Goal CF 11 �Facilitate the siting of essential public facilities sponsored by public or
private entities and whose location within unincorporated areas may be appropriate.�
The proposed project is not easily sited. It cannot be located in a developed or urban area.
Nor can it be located �out of the way� on a hilltop as many antennas may be, since AM
antennas require moist, lowland soils. The proposal is a private enterprise that provides a
public service. In some conditions, such as emergencies and bad weather, the project will
perform an essential public service. Emergency management agencies favor the proposal
and would benefit from the enhanced communications capability to be provided.

The electromagnetic spectrum is the property of the public and regulated by the Federal
Communications Commission. Licensees of AM radio stations do not own the spectrum
they use to broadcast. Instead, they pay a fee to the government to hold the license and
broadcast programming over the airwaves. Though a licensee is free to transfer the
license to another entity through a sale, the license is subject to forfeit to the Federal
Communications Commission at all times if actionable incidents, contrary to the public
interest, occur. The government also requires broadcasters to install equipment that
allows them to monitor the Emergency Alert System, formerly known as the Emergency
Broadcast System. All broadcasters are required to retransmit emergency information in
its entirety or sign off to allow others to do so. KRKO is considered a participating EAS
radio station and is required to retransmit emergency information for the Snohomish
County area from KIRO-AM 710 and the National Oceanic and Atmospheric
Administration (NOAA). Maintaining EAS equipment is a requirement of the FCC
specifically for national emergencies, though KRKO voluntarily offers its signal to local
government agencies and participates in the Central Puget Sound EAS network.

Comment letters received from the Washington State Department of Emergency
Management, Island, Snohomish, Skagit, San Juan, Jefferson Counties, and the South
Snohomish County Emergency Services Coordinating Agency (ESCA) underscored
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