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HomeMy WebLinkAboutWatson Communication Systems 1994 Master Plan 12-1994WATSON COMn~IUNICATION SYSTEMS - 1994 MASTER PLAN RESPONSE TO COMMENTS . _ ON DRAFT ENVIRONMENTAL IMPACT REPORT AND ENVIRONMENTAL ASSESSMENT FOR AMENDMENT TO SAN BRUNO MOUNTAIN AREA HABITAT CONSERVATION PLAN ,.__ AND ENDANGERED SPECIES ACT SECTION 10(a) PERMIT PRT-2-9818 - DECEMBER 1994 '4 ._ Prepared for San Mateo County Prepared by Thomas Reid Associates Palo Alto, California ~. WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.1 WATSON COMMiJNICATIONS SAN BRUNO MOUNTAIN MASTER PLAN RESPONSE TO COMMENTS ON DEIR The comment letters are attached. The responses are numbered according to the numbering system identified in each of the letters. The attachments follow the comment letters. FROM: Malcolm Carpenter, Town of Colma, July 27, 1994 The Town of Colma had no comments on the project. FROM: Carole Nelson, City of Brisbane, Sept. 2, 1994 Project Description. a. Residential Units There are two residential units planned for the current expansion of the communications facility: a two bedroom unit and a one bedroom unit. While conditions may change, current plans call for two security workers to occupy the two bedroom unit on a full time basis. Current thinking is that these workers will not reside there with their families, but will both be engaged in providing full-time security service for the facility. Upgrading and expansion of equipment at the site will require additional service attention. This will require additional service personnel. It is anticipated that an additional two or three service personnel may be added. However, much of the additional servicing will be handled by more efficient use of personnel. To accomplish this, there may be occasions where service personnel may be required to work an extended shift. The additional one bedroom unit is provided for those service personnel whose presence at the site may be required overnight. b. Tower The new tower description was submitted to the County on June 25, 1993. The new tower is 250 feet tall. With the mast, the total height is 315 feet. Elevation to the top of the mast would be 1540 feet. This would make it the second highest tower on the site, with the highest tower having an elevation of 1541 feet. This tower replaces tower T7 which is 150 feet high with an elevation of 1,375 feet. The new tower has three legs as opposed to four legs. The appearance of the tower can be see in the photo montage which is in possession of the County. The relationship of this new tower with respect to the other transmission towers can be seen in Attachment A to this letter. The new tower is shown in the attached photograph labeled "View with Proposed Project at Build-out" contained in Attachment B. Time Frame While the current expansion should satisfy the needs for towers and antennae dishes for the foreseeable future, one additional change is anticipated. This change is the replacement of aging Building F with another building occupying the same parcel. Height may vary. This is already a December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.2 disturbed site, and no additional changes to undisturbed areas are contemplated. Construction of proposed buildings are expected to be completed in 1995, while the total utilization of satellite dish sites are expected within a five to eight year time span. d. Project Use and Benefits The project consists of two primary elements: radio/television communication towers and satellite antennae dish facilities. The radio and television transmission facilities have been associated with San Bruno Mountain for many years and include the transmission facilities for a number of major Bay Area broadcasters including KNBR, KQED, and KTVU. The major modification of the site associated with this use is the replacement of the current Building E with a new and slightly larger Building E, and the replacement of Tower T7 with the new tower. The purpose for this modification, which is limited to an existing site, is to provide facilities and the ability for the broadcasters to utilize new highdefinition television (HDTV) technology that will soon be placed into service. This facility, and the Bay Area in general, needs to anticipate the needs of developing technology and to provide infrastructure for it. These towers also provide platforms for microwave communication dishes which link data and communication transmissions from the satellite dishes to other facilities located in the north and east bay where they are used and relayed on. The satellite antennae/dishes provide the San Francisco Bay Area with their major satellite communication and date transmission facilities for the far east and the Pacific rim. These links carry telecommunications, computer transmissions and entertainment signals that link Asia and Australia to the Bay Area, and are an integral part of the information "Super Highway". These facilities are currently overloaded and require expansion. This type of facility, along with the integration of microwave communications links to the towers, assist in maintaining the San Francisco Bay Area as a corporate and high technology center. A diagrammatic summary of the interlinking of the San Bruno Mountain facilities with other telecommunications facilities in the Bay Area are shown in Attachment C. 2. Conformance with County Policy. As indicated in the DEIR the project is in conformance with all applicable County policies. Residential uses are allowed in a RM zoning district (Sam Herzber, County Planning Division, pers. comm.). 3. Vegetation and Wildlife. The issue of pets, particularly dogs and cats, is of concern to the County Division of Parks and Recreation and the HCP Operator. Pets are not now allowed in the Park. After further discussions with the Applicant on the problems pets pose in areas surrounded by County Park, the Applicant has agreed to prohibit its employees from having dogs or cats on the property. Since the residential units proposed would provide security on the site it is expected that the project would actually benefit the HCP. Full-time trained security personnel on-site would help prevent unauthorized access to the closed oPf areas of the park and reduce the incidents of vandalism to parked cars. As stated in the DEIR, the presence of security personnel on-site could prevent butterfly poachers from illegally taking endangered butterflies. Garbage is currently collected on site twice per week. Garbage stations are also provided for park users. Domestic garbage is to be stored in containers until collected. While there will be a minor December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.3 increase in garbage generated due to the residential units being built, this increase is not expected to result in any increase in collection trips now currently utilized. It must be stressed that the majority of use of this site, along with attendant refuse and environmental loads, comes from users of the park and not from Watson Communication personnel. The number of personnel on site an any one time is small and there is no major increase anticipated. Addition of the residential units would not incrementally affect the park and no additional mitigation should be necessary. In fact, the Park Department has welcomed the assistance and benefits that would come from full-time security presence on the site. No special night lighting is proposed. Lighting will be no more than currently in use on existing buildings. Please note that there is technically only one structure in a new location. 4. Geology, Soils and Hydrology. Because of its small size, this project does not fall under the jurisdiction of the Regional Water Quality Control Board. Instead, the County of San Mateo has jurisdiction under their STOPP program as part of the building and grading permit process. Watson has designed all new and modified buildings to conform to use of existing storm water facilities. The erosion concern in Ravine #2 has been resolved through the use of drilled pier foundations for all new satellite dishes, soil conditions permitting. Each foundation would consist of three (3) 12 inch diameter piers. This results in minimal disturbance of the native ground and negligible runoff. Not all of the area would be disturbed at any one time, and vegetation damaged during the installation of the piers would be replaced in accordance with the restoration plan included as Attachment D. Watson Communications has agreed to establish a monitoring program that would examine improved area after the first heavy rainfall (greater than 1 inch) each year and to correct any erosion problems encountered. 5. Aesthetics. Two photos have been prepared to show the visual impact of the project. The first photo, Existing Conditions, was taken from the Serramonte Shopping Center/280 corridor area looking northeast to the site. The second photo, With Project at Build-out, shows the new dishes in Ravine #1 and #2, the new tower at Building E, and Building G. The simulated photo was made using the computer software "Photo Styler". An existing 9 meter dish on the Existing Condition photo was copied and duplicated in the various new locations as shown on the project plan. Each dish was placed by eye using topographic features such as the transmission lines, towers and buildings, trails, and vegetation. The access road in Ravine #2, equipment shelters, Building G in Ravine #1, and the new tower at Building E were also added in that same fashion. Color samples of camouflage paint were obtained from Watson Communications. Watson can use a tan paint on the dish faces only. Any darker color would cause absorption heating in the reflector and would interfere with transmission signals (Jay Watson, per. comm.). Dark green can be used on all structures and on the backsides of the dishes. In the Proposed Project at Build-out view some of the dishes were darkened to simulate a tan color. These represent dish faces pointing in a south westerly direction. Other dishes were darkened to simulate a dark green color. These dishes would be facing in a easterly direction. Painting the December S, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS p.4 dishes would mitigate visual impacts of long-range views of the dish ravines from the Serramonte/280 corridor area. 6. Health and Safety. General Comments While the City of Brisbane's concern over EMF (electromagnetic fields) is justified, the following should be noted: 1) "Low frequency" EMF is not an issue. Low frequency fields are associated with power transmission. All of us are exposed to it with electric blankets, electric motors and heating elements such as electric stoves. Normal concern would be over location of power transmission lines in the 60 hz range. This type of installation contains HF (High frequency) equipment that generates high frequency EMF. This type of radiation is termed "non-ionizing". 2) Mitigation measures for high frequency EMF and microwave transmission were incorporated into the original use permit. The analysis and mitigation measures are detailed in the following reports, attached hereto as Attachment E for ease of reference: i) E.H. Villaseca 8/29/84 ii) Hammett & Edison 6/23/88 iii) Hammett & Edison 8/24/88 iv) Hammett & Edison 3/19/91 v) Hammett & Edison 5/22/91 b. Satellite Dishes dishes: The following summarizes microwave radiation and the radiation associated with satellite i) Satellite dishes are parabolic reflectors. The purpose of this shape is concentrate the transmitted signal into a parallel path to prevent signal diffusion. Radiation is highly concentrated within the beam, and there is little disbursion. ii) Signals are measured within the beam (collimated), and outside the beam (shadow). iii) The minimum "look angle" is 30°. The measurements were made at 10° to provide a factor of safety. iv) Radiation levels fall off sharply with both distance and angle off center of the beam. A 17 milliwatt (mw) per cm2 signal at origin drops off to 0.072 mw/cm2 at 1 meter outside the collimated beam at a distance of 60 meters. The collimated beams do not pass near any human or terrain feature present at the site. Radiation continues to fall off rapidly the further outside the collimated beam one goes, until at a small angle off center, there is no measurable radiation. v) The EPA has no standards for non-ionizing radiation. OSHA standards call for a maximum of 10 mw/cm2. ANSI standards C95.11982 call for an unlimited maximum exposure of 1.0 mw/cm2. The EPA is considering adopting the ANSI standards. December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P•5 vi) The ANSI standard is the same as used for domestic microwave ovens. vii) Since the signal is only 0.072 mw/cm2 at 1 meter outside the collimated beam and the maximum continuous exposure recommended by ANSI is 1.0 mw/cm2, there is a considerable factor of safety. To more fully explain the impact and effects of the satellite beams, attention is to be directed to Attachment F. viii) Figure 1 shows the relative intensity of radiation from a transmission beam as measurements move away from the center of the beam. ix) Figure 2 shows the general direction of the beams toward the fixed geosynchronic orbit of the satellite. Note that the beams are generally directed toward the southwest. This means that radiation is generally directed in that area, and does not affect the areas to the side or rear of the dishes. Also, it is important to note that no radiation is created when a dish is in a receiving mode. x) Since this type of non-ionizing radiation is measured in dosages of 6 minutes, a typical bird flying at 20 miles per hour (30 feet per second) crossing a 15 meter collimated beam would be exposed to the beam for approximately 17 meters of flight time at 100 meters, or about 2 seconds. This means that the dosage would be less than 0.1 mw/cm2, or far less than the maximum continuous dosage permitted under ANSI standards. Humans in the area would not be affected because the look angle causes the beam to clear the ground far above when humans might be passing. c. Transmission Towers i) Tower transmissions were characterized in previous reports. ii) In all cases, mitigation measures reduced measured radiation at all spots on the mountain to less than the recommended 1.0 mw/cm2 iii) EMF falls off sharply with distance and total exposure to the public is minimal and less than the unlimited exposure levels recommended. iv) The tower replacement conforms to all limits, and in fact improves the performance by being higher than the existing tower. v) Revised measurements of radiation levels are made when new towers are installed to verify their conformance with standards. 7. Traffic and Parking. Increase in traffic would be minimal and probably limited to less than five additional vehicles on a daily basis. Two employees are expected to reside in the units. This would result in some increase in traffic for shopping and recreation. There will be a minor increase attributable to occasional filling of the water tank servicing the residential units with potable water. However, this is expected to be limited to approximately one trip every one to two weeks. Some minor decrease in traffic would result from service personnel staying in the second residential unit. Again, it must be stressed that the vast majority of traffic on Radio Road is associated with park usage and not the communications facilities. December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS p,6 Parking accommodations will continue to be provided on private property for the service personnel. Each building, existing or planned, have parking aprons that show on the building plans. 8. Public Services. Additional calls on security services might occur with the addition of security personnel as 24 hour presence would be maintained to deter vandalism and other unlawful acts. However, the mere presence of security personnel should deter these acts, and should reduce the present security burden from the Sheriff's Department, CDF and the Parks Department. No additional demand for services is expected. New or replaced facilities will use the current electrical infrastructure. We expect electrical demand to decrease on a per unit basis as new and more efficient equipment is installed. FROM: Jake Sigg, California Native Plant Society, September 6, 1994 1. Comment acknowledged. Development is proposed on private land. The HCP allows for managed development with habitat mitigation. 2. Cumulative Impacts. As a clarification, approval of the SBM HCP was not based on the ability of the Plan Operator to restore habitat, but rather to preserve habitat. The HCP states on page III-10: "The reliance on preservation (as opposed to manipulation or restoration) is an extremely important one. Preservation of existing ecological conditions is preferable to attempting to recreate these conditions after disturbance or elsewhere (e.g. clearing brush to create grassland) for several reasons. Preservation is less expensive than restoration. Even more importantly, there is always uncertainty as to whether a restoration or habitat enhancement effort will produce the desired result or whether it will adversely affect another species. Although the habitat enhancement techniques recommended in this plan have been tested in range management or other enhancement programs reported in literature, their application to San Bruno Mountain is still, in many ways, an experiment with unknown results." The HCP was approved for the following primary reasons: Loss of 1490 of the habitat of the mission blue and 89:0 of the habitat of the callippe silverspot was determined not to jeopardize the long-term survival of the species. As mitigation the HCP relies on the conveyance of substantial additional habitat in private ownership to the County of San Mateo (some 800 acres in all), and the generation of a permanent funding source to carry out habitat management activities in perpetuity. Development under the HCP would affect about 400 acres of the 3600 acre Mountain. The current status of development on the Mountain is shown in Attachment G. The following is a comparison of expected acres of development and conserved habitat in 1982 with actual development and conserved habitat in 1994: December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.7 1982 1994 Developed 368 acres 353 acres under construction or done 19 acres unknown status Unplanned Parcels 260 acres 216 acres Conserved Habitat 2,732 acres 2,741 acres As indicated in the above table, actual development on San Bruno Mountain in 1994 is consistent with what was anticipated in 1982. Conserved habitat has increased by about 9 acres from what was expected with the help of the Department of Fish and Game which purchased Owl and Buckeye Canyons. Developed acres increased slightly due to the change in status of several unplanned parcels. The development of an additional acre on the Watson Communications property would not significantly increase the cumulative development anticipated under the 1982 HCP, and would maintain the acreage of conserved habitat within that expected in 1982. 3. Hydrological Impacts. See Brisbane comment #4 and BALW comment #12. 4. Public Access and Health. Watson Communications is not aware of any FCC considerations for tightening restriction on non-ionizing radiation. FCC has adapted the ANSI standard which is 10 times more strict than the OSHA standard. All facilities are in compliance and satellite dishes have an additional safety factor of 5 already. Also see Brisbane comment #6. 6. Other Impacts. The top of the Mountain is open to the public throughout the daylight hours. There is no restriction on the number of visitors that can use the site. The addition of two persons who would provide security on-site would not significantly increase human presence on the property. At present, workers on the Watson property are allowed access up to the site at all times in the event of equipment failure or other problems. The presence of the security personnel around the clock is not considered a significant change from existing conditions. Pets will not be allowed on the property nor will there be ornamental landscaping or other gardening. Watson communications has agreed to provide signage for the County Parks Department indicating that feeding wildlife is not permitted. Mitigation. See Sigg comment #2. 8. Aesthetics. See under Brisbane comment #5. 9. Comments in Mr. Sigg's February 10, 1994 letter submitted on the Negative Declaration was used as scoping material for preparation of the DEIR. Most of the comments in Sigg's earlier letter have been repeated by him and others in the DEIR comments which are responed to in this document. December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS p,g FROM: Dana Dillworth, Bay Area Mountain Watch, No Date Comments are the opinions of the Commentor and are acknowledged. 2. Project Understates the Project. All of the components of the project are listed in the Project Description and are analyzed in the impact analysis sections. The 400' horizontal bore between Ravine #1 and Ravine #2 will be done completely underground and would not result in above ground disturbance (see Page 6 in DEIR). Building F water usage is not increased. Increase storage capacity is mandated by County fire codes. Storage of water has no effect on habitat as it is installed within a fenced and existing disturbed area. Building G grading amounts are shown on the grading drawings that were submitted to the County. Blasting is not required. Grading amounts are shown on the grading drawings for Ravine 2. Access roads are shown on the drawings and grading quantities were submitted to the County. The addition of two dwelling units above an existing building and does not increase the surface coverage. Cumulative Impacts. See under Jake Sigg comment #2. 4. French Drains. See BALW comment#15. 5. Septic System. Overall operation is no different than the current. See comments above. Project already has leachfield. Some of these leach lines now exist in habitat areas. These would be abandoned. Six parking spaces at Building G is simply utilization of roof deck. Leachfields comply with County Health Standards. Approval of Regional Water Quality Control Board is not required (Per Doug Straw 10/6/94) because area being developed is less than five acres. There are no cooling towers. Water is stored for firefighting purposes. 6. Cumulative Traffic Impacts. Since the top of the Mountain is open to public access there is no limit on the number of vehicles trips that may be generated during daylight hours when the Park is open. Given this, the addition of five trips generated by the residential portion of the project is not significant. See under Jake Sigg comment #2. 8. Alternatives. Attachment C shows the interrelationship of the San Bruno Mountain site with other facilities. There are no other Watson Communication facilities that can replace this site both in terms of location, and application and centrality to clients serviced. Also see Brisbane comment +~1. 9. Aesthetics. See Brisbane comment #5. 10. Comment is the opinion of the Commentor and is acknowledged. December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.9 11. The project is not considered growth-inducing (see Page 45 of DEIR). The Applicant has a right to apply for modifications to his use permits and to seek amendments to the HCP. He is exercising his rights and the proposed project is subject to public hearings and approval by the County and USFWS (for the HCP amendment). The County will judge whether the project should be approved based on the DEIR, comments received on the DEIR, and public testimony. 12. It is true that the property owner should maintain buildings in a safe condition, however, at a certain time it becomes necessary to upgrade or re-construct deteriorating or substandard buildings. 13. It is true that although Mission blue have not been observed on the lupines located next to Building C, they could visit these plants. The callippe shown in Figure 8 were observed hilltopping in the areas shown. The project would not remove any of the callippe's larval food plants nor is it expected to change the ability of the callippe to hilltop in the same areas shown in Figure 8, or even elsewhere on the site. 14. The funding program for the HCP is necessary for its implementation. The HCP has been criticized for not doing enough exotic pest plant control. The ability of the County to do exotics control is based on the annual budget available to fund the work. Additional funding generated by the project would increase funding available to perform needed pest plant control work on areas of the Mountain not currently targeted for control efforts due to budget limitations. 15. Before removing the debris at Building F, the landowner would have to obtain a HCP Site Activity Permit from the Plan Operator. At this time the actual impact of removing the debris can be determined. If sensitive species are present, site-specific mitigation measures can be required as part of the issuance of the HCP Site Activity Permit. 16. Variances. Variances are permitted under County regulations. They have to do with the proximity to property boundaries which have no effect on the scale of the project to overall landmass. The variance for the septic system would allow abandonment of a septic system now emptying downhill into sensitive habitat area. 17. An eletrophoresus study would be needed to determine if plants and animals found on the summit are genetically different from those found in other areas of the Mountain. This type of study would require taking plant and animals samples to a laboratory and would be costly. The possible information to be gained is not considered worth the expense. FROM: Bay Area Land Watch (via Brian Gaffney), September 2, 1994 1. Overview. Comments are opinions of the Commentors and are acknowledged. Individual issues in this general comment are responded to as specific items below. 2. DEIR Fails to Adequately Discuss Significant Environmental Impacts. The acreage destroyed by the project are covered on in Table 3 on page 28 of the DEIR and in individuals discussion on pages 28 and 30. Noise and dust impacts from the replacement of the tower at Building E is not considered significant due to the small area affected (less than 20 square feet). The latitude projection for the shading diagram was double-checked and is correct. 3. All impacts listed in the first paragraph of page 2 of the comment letter are covered in the DEIR. December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.10 4. See response to Dana Dillworth comment #11. 5. No heavy machinery or major grading is required in any areas adjacent to sensitive habitat. Dust generation would minimal and is not expected to significantly impact food plants of the listed butterflies. 6. See Jake Sigg comment #6. 7. There is a better opportunity to inform permanent workers and security personnel of the importance of not feeding wild or feral domestic animals then there is of controlling this activity by park users. The County can ask workers and security personnel to keep an eye-out for park users who are feeding wild animals. The workers can either request that the users stop the activity or call the Park Rangers and let them know it is happening. 8. Only one of the two units is planned for continuous occupancy. The County Division of Parks and Recreation welcomed the added benefits of full-time security on the top of the Mountain (Dennis Henley, Park Ranger, pers. comm.). Dogs or cats would not be allowed on the Watson property. 9. Golden Aster. The golden aster is not considered a sensitive species under the HCP or by resource agencies (USFWS, CDFG), and was therefore not subject to specific analysis in the DEIR. The site of Building G does not support the golden aster and this plant would not be affected by project development. 10. The project would not significantly increase traffic from the existing conditions. There will be no new public access points created as a result of project development. The project will not increase off-site development. There are no cooling towers proposed, only water holding tanks. The addition of two security guards is not going to support any additional commercial infrastructure than currently exists off-site. 11. Soils reports are in the possession of the County and are a matter of public record. The soils report can be reviewed at the San Mateo County Planning Department, County Government Center, Redwood City. Contact Sam Herzberg at (415) 363-1823. 12. The only storm water runoff not placed into holding tanks or into existing channels is the runoff in Ravine #2. Pursuant to the grading plan, this impact has been mitigated by the use of drilled pier foundations. This leaves minimal areas other than natural ground collecting runoff. 13. Mitigation of storm water runoff will be achieved by the STOPP program to be submitted and approved by the County with the grading permit application. 14. Leachlines are to be placed at a depth of 8 feet. This is too deep to have an effect on plant life. Please note that the project already has leachlines with no deleterious effect. Some of the existing leach lines do not conform to current health codes; these will be replaced. 15. The only concrete pads proposed are for the several equipment shelters associated with this dish satellites. In these small areas french drains are intended to be used. Their purpose is to collect the runoff from the pads and recharge this water back to the ground. Additional water diversion will prevent water velocities from causing erosion. December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.11 16. The document concerning "Visitation Ranch" was published more than 20 years ago, and is superceeded by more current geotechnical studies. 17. Erosion caused by runoff will be mitigated by the STOPP program. We know of no slides in the area to be developed. 18. The geotechnical engineer has determined that drilled piers are not required at Building G. These geotechnical studies have been submitted to the county. 19. Alan Kropp & Associates performed a slope stability study at Building E. The determination was that drilled piers would not disturb the slope. The site for Building E is flat, and spoil created by drilled would be removed. No erosion can result from this type of construction. 20. Final design for pads has been completed and has been on file with the building department for a number of years. These are now being changed to drilled piers. The balance of the building designs need not be completed for the purposes of an HCP amendment. 21. See City of Brisbane Comment #5. 22. Significance Criteria. The DEIR states in the impact section of each issue the rationale for determining why an impact was considered non-significant. For example, the removal of 6 coyote bushes in the proposed location of the new tower at Building E was considered non-significant. The DEIR describes each of the sensitive species and if and how they would be impacted by the project. 23. All of the items listed have been addressed in the DEIR except dust, pesticides, noise, and traffic, which were determined to be not significant based on the Initial Study. 24. An alternative site at the old Nike Base is discussed in Smith comment #4. The alternative of State or County purchase is not considered a reasonable alternative based in the landowners unwillingness to sell this important communications site and the cost of the land should it be for sale (which it is not). 25. See Jake Sigg comment #2. 26. See page 45 of the DEIR for the growth-inducing analysis. 27. No park trails would be affected by project construction. For additional aesthetics analysis see Brisbane comment #5. For a discussion radiation impacts see Brisbane comment #6. Radiation will remain far below unsafe levels. Increased signal activity at satellite dishes are focused beams and have no affect beyond short distances from the dishes. Tower radiation will be reduced by installation of newer and more efficient television transmitters. 28. The comments on the Negative Declaration were used as scoping material during preparation of the DEIR, and the substance of all comments were addressed in the DEIR. 29. The Project Description adequately describes the project and includes a site plan and descriptions of all elements of the plan. Future phases of the project: See Brisbane comment #1. 30. No biotic resources in areas adjacent to the project site would be impacted by project development. December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.12 31. The HCP allows landowners to seek amendments to the HCP every three yeazs. The Applicant is seeking an amendment at the appropriate time and has followed the appropriate steps for processing an HCP amendment. Since the HCP is consistent with the Recovery Plans for the San Bruno elfin or Mission blue butterfly, the project in complying with provisions of the HCP, is also consistent with the Recovery Plans. The project is consistent with the County's General Plan. The project is consistent with the permitting procedures for obtaining a use permit from the County of San Mateo. 32. The development proposed is not considered to be massive new development and would not significantly impact the Mission blue, callippe, or San Bruno elfin butterflies on San Bruno Mountain. FROM: Susan Smith, August 29, 1994 1. Need for project. See Brisbane comment #1. The existing 6 dishes are not adequate for current and future demand. 2. The Conservation Element of General Plan is not relevant to this project since the project is in an RM zoning district, with the current and proposed use allowable under that district. 3. The tower at Building E would be moved further away from elfin habitat. Radiation hazards: See Brisbane comment #6. 4. Alternatives -- Use of County facility at Nike base. A few years ago, the County Pazk Department required all users to vacate the West Peak site. When Watson Communications applied for its initial use permit, it was forced, as a condition of the use permit to accept all users of the West Peak site at reduced rents, and the REACT facility for free. This has increased the demand on the Watson facilities. Suitability of West Peak i) Since there aze no additional towers being added to the radio/television facilities, and only one being replaced, these facilities are not an issue. Additionally, the West Peak site is too low for the signal to cleaz the ridge for this type of transmissions. ii) Since all the control facilities are located on the peak, cables would need to be run from West Peak to the ridge. This is a distance of over one mile, and would entail laying cable along the roadway. This cable would be a hazazd, would cause more environmental disruption than the proposed expansion and would be subject to vandalism. iii) Siting satellite dishes at West Peak would have a far greater visual impact than in Ravine #2, since West Peak is generally visible from a much wider area. iv) The West Peak site is not suitable at all for the satellite dish installation. It is exposed to interference from terrestrial microwave sources from Palo Alto and the Bernal Heights AT&T December 8, 1994 WATSON COMMUNICATION MASTER PLAN DEIR -- RESPONSE TO COMMENTS P.13 facilities. The dishes need shielding from those sources, and the folds in the ground at Ravine 1 and 2 provide this shielding while providing the proper look-angle to the satellites. Construction impacts are mitigated by monitoring of habitat areas under the HCP. 5. Radio Road. A portion of this road is a public road and a portion is private. There is an agreement between Watson Communications and the County whereby the Park Service is responsible for road maintenance as long as the road is accessible to the public. If the public can be excluded, Watson Communications is responsible for maintenance. The public use of the road far exceeds that of Watson Communications, and is the major cause of funds expended for maintenance. 6. Leach line impacts: See BALW comment #15 7. TRA field biologist, Michael "Lion" Baumgartner, who has 14 years experience working on San Bruno Mountain believes that there has been no decrease in the population of Silene verecunda verecunda found on the Watson property in the last few years. The population appears to be stable or increasing slightly. Proposed master plan development would not affect the population. The populations of both sedum and lupine have increased on the Watson property in the past few years, both naturally and as a result of enhancement propagation. The control of exotic pest plants on the top of the Mountain has the highest priority under the HCP. The site is checked for seedlings at least twice a year and any found are either removed by hand or sprayed with herbicides. 8. Scenic Values. See under City of Brisbane #5. 9. Variances. See Dillworth comment #16 10. Additional information on project need is included in Brisbane comment #1. Biological, geotechnical, and visual impacts are described in their respected sections in the DEIR. FROM: San Mateo County Department of Health Services, August 23, 1994 1. No non-potable water would be used in the basin, toilet and showers. The potable water would be from domestic sources and would be trucked up and stored in a water tank. 2. All of the necessary test data will be provided to the Health Service Agency for review and approval. December 8, 1994 COMMENT LETTERS I/EC-05-1994 1E~~0 FRCM PLANNING 8 EUILDIhG TO 9'24024 P.03 -~ \,\ Wq%o y S ',,~ „ ~_. -"_w-..~~~-- TOWN OF COL!NA • 1198 EI Catziinv Real • Colma, CaIifarnia 94014 415-997-8300 • EAX 415-997-8308 July 27, 1994 Mr. Sam Herzberg, Planner II San Mateo County Planning Division 590 Hamilton Street, Second Floor Redwood City, CA 94063 RE; Watson Communication Systems DEIR dear Mr. Herzberg: Thank you for providing a copy of the Draft EIR for consideration by the Town of Colma. We have nc comments on this project. Sincerely, Malcolm C. Ca pester, A1CP City Planner MCC/s c~ ~ TO 932/4024 P.05 City O£1`zces 150 1Vorth Hill Drive, Suite 40 ~ Brisbane, California 94005 Telephone (415) 467-1515 Fax (415) 467-4989 September 2,1994 Mr. Samuel Herzberg Planning Division County of San Mateo Mail Drop 55RC1-00 590 Hamilton Street end Floor Redwood City, Ca. 94063 Subject: Comments on the Draft EIR/EA for an Amendment to the San Bruno Mountain HCP and ESA 1t)(A} Permit Amendment and Renewal of a Use Permit for the Watson Communications Systems 1994 Master Plan Dear Mr. Merzberg: Thank you for the opportunity to review the DraK Environmental Impact Report and Environmental Ass9ssment on Watson Communications 1994 Master Plan project. The DEiR contains important in#ormation of assistance to the City of Brisbane in understanding the project and its potential impacts. We have reviewed the subject EIR/EA and forvvard the following comments: i .Project iDescription. The Project Description describes the physical characteristics of the proposed improvements, but is lacking information regarding the operational implications of the new structures. The addition of residential use means that the site will be permanently occupied for the first time. Hvw many people wiN reside on the site? Wiil they be security workers only or workers and their families? Will the expansion of the control rooms and equipment space result tin increased empbyment, if so, by how much? Will it be daytime only or 2~4-hours a day? The Project Description includes replacement of an existing tower, but does not supply a description of the new tower. Will it be the same height or in any way differ from the existing tower? goes the Watson Communications 1994 Master Plan have a time frame associated with it? if so, it should be described. We would very much Pike to know if this expansion is expected to suffice for t-year, 10-years, 20-years or any specific period of time or if the Master Plan is silent aS to its projected horizon. DEC-05-1994 16~~1 FROM PLANNING & EUILDING The ElR contains a very brief description of the Need for the Project; however, because of the site's unique location in the midst of a regional park and habitat DEC-05-1594 16~~1 FROM PLANNING & EUILDING TO 9324024 P.06 conservation area, we would like to know mute. As noted on page 10, the project wilt benefit Watson Communications Systems commercial interests. But hvw will the public benefit? Are there any benefits to the local public••Brisbane, San Mateo County? Or to the people of the San Francisco, or the Bay Region? Z. Conformance with Plans, Ordinances and Policies: Use Permit U5E 81- 36. is residential use permitted in a RM District? Is it permitted under the terms of the existing Use Permit, or will a variance be required to allow full time occupancy of the site? is there a limit on the number of residential occupants allowed? tf not, has the County considered such a limit, either in conjunction with a variance Or as a condition of the amended Use Permit? 3. Vegetation and Wildlife. This section is very comprehensive regarding the potential effects of the project on the habitat of the special status species identi€ied in the HCP. We would Tike to see this section supplemented with some analysis of new issues that could be raised as an indirect result of residential occupancy of the site. The County Parks and Recreation Department raises one of these issues on page i 2•-pets. if residents of the site had pet cats or dogs, could they pose a threat to animals in the park? Could they expose the residents to flea-home diseases? Should pets be allowed 'in the middle of a Mabitat Conservation Area, even if it iS an enclave of private land? We also question whether or not the introduction of two residential units in this sensitive area might not raise vector control issues. There is no mention of hpw the resident's garbage will be disposed of or how it will be stored before disposal? In general, we would tike to see a more rigorous analysis of the potential effects on the HCP area related to introduction of residential land use and increased human presence in its midst. Possibly some additional mitigation measures should be developed to ensure chat the project wits not indirectly or inadvertently create any new problems for the Park. 4. Geology, Soils and Hydrology. This section notes that the hazard of water erosion is moderate to very high, yet the mitigation section does not address this hazard. We request that this section be augmented to require that a Storm Water Pollution Prevention Plan (SWPPP) be developed and implemented at the site during construction. The plan should be prepared by a quali#ied civil engineer or certified engineering geologist, and should include a monitoring program to ensure that it is implemented properly. I"urtherrnore, due to the sensitive bocation of the site, we urge the County to require that the SVYPPP also address the operation of the project. 'T'his would include everything in Mitigation Measure G60.1, but would be expanded to include monitoring and procedures to require corrective action in the event that there are any erosion or sedimentation problems created by the project. 5. Aesthetics. The aesthetics section would have been easier to comprehend if it were illustrated with photos of the project area and the locations where the new DEC -es-199a 16 ~ ~2 FRCf1 PLArvN I NG & EU I t_D I NG TO 93t~a22a P.ar construction is proposed_ This project will irnolve a massive concentration of large satellite dishes in a very smatl area. Atrnost by definition it has the potential for very significant aesthetic impacts. This section does not sufficiently demonstrate the conclusion that there will not be any adverse visual impacts. We would like to see a much more comprehensive and careful review in the Final EIR. We are concerned that this section does npt address night lighting. Will there be security or other fights used at the site? Frorn where will they be visible? Will the lights in the residential units be visible off-site? If so, from where? 7'he Final EIR should include an analysis of lighting impacts and mitigation measures should be recommended. The impacts analysis states that the dish antennae and equipment shelters will be painted "appropriately" to blend with the surroundings. No mitigation is deemed necessary. We urge the County to tormalize this intention in a mitigation section, setting criteria to determine what is "appropriate." It should also include the residential structures as well as the equipment shelters. In addition, the impacts season should address possible glare from shiny metallic surfaces or windows, and mitigation to reduce glare should be included. 6. Health and Safety. The EIR does not address any potential risks to the public or to workers from the concentration of low frequency EMFs and microwave radiation generated at this site. We ask that the Final EIF~ be expanded to include an analysis of these issues. 7. Traffic. it appears that traffic was "cooped out" of the analysis. However, since residential uses will be added and there will be an increase in employment at the site, we would tike the Final E1R to tell us haw many daily trips will be generated and how that compares to the existing traffic. We would also like to know where parking wilt be provided on the site. 8. Public Services. the introduction of residential use on the site could increase the calls for service to Brisbane or Daly City. Because of our proximity, we are frequently the first responder to calls from San Bruno Mountain Park. This potential impact should be noted. Please discuss in greater detail how services are now supplied to the site and how this could change with implementation of the project. We would also tike to know whether the existing electrical facilities supplying the Watson Communications site are adequate to support this project. If not, how will the electrical service be expanded? WiA it involve any excavation or new aerial lines. If so, will there be any impacts associated with this work? Ws3 assume that the County will prepare a Mitigation Monitoring Program for this project prior to final action, as required by CEQA. We ask that a Draft of the Mitigation Monitoring Program be prepared Cgncurrentty with the Final EIR and sent to all signatories to the NCP, including the City of Brisbane, for our review. DEC-05-1°94 16~~3 FROM PLANNING & EUILDING TO 93274024 P.08 We appreciate the opportunity to submit these comments and look forward to receivin he Finai E1R. Si e , ~iOl_f= G . SO Planning Dir r TOTAL P.08 DEC-05-1594 16 40 FROM PLANNING & BUILDING TO 93274024 P.04 California Native Pant Society ,338 (Mega Strcet, San Francisco, California 94122 6 September 1994 To: Mr- Sam Her7:berg, San Mateo County Planning Department From: Jacob Sigg, President, Yerba Buena Chapter, State Chair, Invasive Bzcotics Committee Re: File US>/ 8136 and VAR 93-0010 San Bruno Mountain telecommunications expansion The virtues of San Bruno Mountain are too well-known to nced recounting here. The mountain's scientific vitality and signiftcance has been documented and celebrated. Federal, state and county designations are official reoogctition of its special value. That value is given greater prominence by San Bruno Mountain's geographic placement in the heart of a highly developed and denser-populated metropolitan area. Of equal value is the aesthetic and recreational pleasure it has gave" to its visitors. Those citizens populabin~g this area have shown their apprcciatio~n for this providential gift. The presence of an urban industrial development in the very heart of this wild area is an unfortunate historical anachronism which San Mateo County should be taking steps to phase out. Its jarring presence is totally inappropriate in the setting and expansion should not even be considered. Approving expansion would call into question the Competence of the county bD manage this priceless natural asset. Citizens should not be required to continually defend this beleaguered mountain from yet another piecemeal, ruinous project. 'T'he whole of the remainder of the mountain should be accorded the status of a biological preserve similar to that of Edgewood County Park. It should be inviolate from further incursions. Fundamental bo our view of the value, status and function of San Bruno Mountain is the health of the mountain's ecosystem, the state of the biological community in its complexity, its richness and diversity, the inte:rractivn of its wmponentparts--its wholeness. We place our highest value on this, and not on any one component" Ct?MYn~ 'IIVE IlVQ~ACT~ What should be noted is that events go in one direction only: there are ever greater human impacts--whether it be development, structures, activities, paths or manifold disturbances. Bvery year there are fewer native plants to sustaiun the biological community. It is this fact vvhrc weighs so heavily with us and partially accounts for our fierce vpposttron to further encroachment. This umdu+ectionality of events should have been offset by mitigation itn the form of restored habitat. This was the intent of the Habitat Conservation Plan. To date, the county is unable to identify restored areas to co sate far loss to de:velopmeztt. Until it can demonstrate compensatory achievements, its cold not approve this projectThe cumulative impacts of this and other projects ate not considered in the DE1R. ffi'_QRO .1N:YIOFF S IlNPA 'T9 As noted in the DEIR, the hazard of water erasion is high and the nature of the soils and topography is conducive to rapid runoff. There is already deep gullying around Radio Road below sate A. The DEIR does not address how this gully is ao acxomodate the greater runoff volume additional structures would entail. DEIR posits french drains as a solution to some of the runoff, without specifying draist dimensions. French drains labor under several disabilities: 1) they cannot handle the volume of a sustained downpour, 2) the percolation rate into this particular bedrock over the long eexxn is urllmown, 3) they are subject to siltation, and 4} the water percolating into the; rock strata will daylight somewhere, changing offsite plaint composition in some unlrnown way. The additional concrete pads, buildings and other stxvetures will mean coneentratzng rainfall runoff into areas not capable of absorbing it r ,,,,., ,,w h =Dedicated to t ye preservation o f Cali f vrnia native f (era DEC-05-1994 1E~41 FROM PLANNING & BUILDING TO 93274024 P.05 Siltation of San Francisco Bay must be considered. Fog condensation will be tantamount Ao summa rain and runoff concentrated where it is debouched, changing plant composition. Changes in hydrology as well as nutrient enrichment are posed by existing and proposed septic lcachfields. The addition of living quarters will expand and intensify the unknown negative effects of the present leachfiel by several degrees of magnitude. How much needs m be stated. vegetation will be changed where leachates are pttisent. The Federal Communications Commission ~ is considering tightening zestrictians on non-ionizing radiation. We received uncon reports of the possibility of the FCC increasing permissible public distance from some transmitters by a factor of five. If this happens, public access to the mountain summit could be denied. The DEIR needs to addi+css this question and what potential effect it will have on public access. The DLER merely states that if the project is xtot built, a licant will bo unable to meet mai~cet demand Dves this meet the requirements of CA? The public should have some data We have received info~rntal verbal opinion from a cESpected telecommunications professional that ~s~d project far e~xccods presenfly foreseen potential for the marl~et. How is the public tp c- be assured that project is Headed? DF.,~R should consider eacpansion of present facilities operated by applicacit elsewhere in the Bay Area in lieu of this damaging project. It should also consider unused county facilities clsEwhece on San Bruno Mountain. U7'HER IMPAC')<'S DEIR ignores one of the largest impacts of the project: the increased and round-the-clock human presence an site. San Bruno Mountain State and County Park has bexru designated by the county as a Natuiai Preserve. Human beings disrupt habitats, even when we aic not aware of it, There will be frequent auto trips, disruptive to wildlife, to the wild character of a lace and to human recieationists. Humans un~nte[i>ronadly interfere with breeding, nestirtg, ~vragi~g. Residents may have pets, which can be a diroct threat to wildlife, DEIR states that pets must be kept indoor. How is this m be enforced? Where will be tight lighting and noise, which have unknown effects on wild communities. Wildlife may become dependent on being fed by indulgent humans. A ~y fox has already statioried itself for handouts at the summit ~arkYttg lot. One of the pernicious desttttctive wet9ds on San Bruno Nlauntain, german ivy (Senecio mikatriordes), started in California as a house punt. Garck:i escapes are common and have made a major contribution to the destruction of the California flora. The impact of human residents and their daily activities on habitat must be addr~esal. ~a~Trorr AlI mitigation measures mentioned in I7ELR have yet bo be proven viable. San Mateo County has been operating the San Bruno Mountain Habitat Conservation Plaxi ,for 12 gears and is unable to ~dendfy restored habitat m co~nppaattsate for the hundreds of acres which have been Lost tv development. Revegetating disturbed areas is much more difficult thaxt is assumed Failures are uumerotis and Dover large meas. Successes have beat few and small. Maximizing chances of success is expensive and requires mvnitiot~ing and follow-up, usually lacking in such arrangeixients, as are penalties for failure to meet requirements. Invasive weeds are continuing to expand in population si~C all over the mountain. Not only cue the mountain's biological values in serious decline, recreational values axe tl>reatcned also, If greater measures are not taken m stem the tide of go~cse, broom, fennel, cotoneasta, pampas grass, eucalyptus acrid others, no one will think of going to Saga Bruno Mountain to recreate. DEC-05-1594 16 42 FROM PLANNING & BUI<_D[NG TO 9?2'74024 P.06 Damage dune to the mountain by this project will not be compensated fur by the small amount of ,money it would generate for the HCP fund. 8 Existing facilities are p t from great distances. Siting satellite dishes in swales will not ~rovent theix being seen by many thousands £com their homes and in their travels. And tt-e zmpact on mountarn users/l>ikerslreareationists ishuge and not mitigable. The Sarr Mateo County General Plan places a very high priority vn aesthetics in such a settirtg. We ask that you incorporate aw previous rannaarks in yow response. O CL--~_---'+ -~~VG rKUI'i r-~n~+i~~fvu ;, L',ULLii~u tU ~ _ _G-r ~ _ -. ~..i-. THE CALIFORNIA: NATIVE -PLANT SOCIETY TO: San Mateo County Planning Oepfsr#mfsnt, Sam Hontberg RE: Watson GommunlcationslT~lsoommunioations Proptarflfas UP 81.86, YAR 93-000=10, ENV 93.0163 , Februery 7 0, 1994 Human soc+ety has surroundf~d and severed San Bruno Mountain and transformed it into a biological island; having littlfa interaction with outside Alements other than those oooasionfad by hurnarl pGtivity. As an islf~nd, it hos limited genetic potential and thus diminished meona of responding to chonginQ environments. The oreo is dongerousty smol! for creatures like the Iorger vertebrates morooned on this island, thus inbreeding depression becomes a problem for many Sp6Ci0S. tt follows that further diminution of this 'violated mountain will ~ be detrimental to on already weakf3ned ecosystem. The Colifornia Native Plant Society opposes ony acfivlty which further diminishes the site or quclity of tho mountain's habitat. The project gains. additionol irnportancf3 by virtue of the foot thot it is sited at the mountoin's highest elevafions. The sails here are some of the thinnest and wfafather the harshest. It is buffered by strong, cold winds and fog. tt is ~probf~ble that the plants which thriv® here are of a different genetic constitution thah those in tower, more protected sites. What effect further damage will have on this eGOSystem must be considered in relationship to this partifxltor kind of habitat, not the mountain as a whole. Thus, the contemplated action, by peroentage, will have a graeoter impact than dlsaussed in the initial study. SY far the project's biggest df~mage will be caused by Phases 1 and 2. Phase 1 wit! sevarelY impact d slope in which Luplnus albl~rorta callinus, lorvaf food plant of the mission blots buttertty, is oo•dominant with Bafaccharis, Arfie~»islo and Heterothaaa s®ssilifloro bol~aradar~ Thf~ latter, i~ an important nectar food. plant for numerous butterflies, ~nduding the mission blue. The site represents one of the denl.est °on°eMrotions of this lupine and Helbr~vlheoo on the :mountain. Per your admission, ('Yes' pg, E, 2.c.) these 'arf3 indicetors of habitat qualtfy.• Phose~ 2 is iQrger and more detrtmentat in terms of disruption and ecosystem damogo, 'the sh0er ateepnfsss of the terrain and limited surface area for rain absorption - exooerbotnr! by 24 addi}ionol oonoro+c pods. 7 ogvipment st-wttf~rtd and rofafys - wltt vause fierce gully washfss: o substantiol off.rite impact.: ' OEOIGATtO TO THE f gEtEAVATION Ott CAI~fOfiNfA NATIVE FORA Presently there is'svidence of erosion on the southernmost dirt. road of Phase 2 and poorly engineered drainvge in Phase I. Pampas grass growing in both areas will proliferate given the conditions of disturbed earth. These impacts need to' be addressed with or without a future project. Residential uses {building'C") are inappropriate and not consistent with existing uses. Holusehold pets, potential introduction of invasive plants, pssoclated vehicu(vr trips, increosed trips to service the water and geptir, tonks, and impacts to police anti firF services necessary for noncontiguous development are not anoiyzed. increased woter/septic cyst®m usoge and its impt7Cts hove not been ciorified: there is concern that septic leaehate will impact thv vegetation down slopo. Sitene verecunde verecunda hoe been found near the summit, although it is not in evidence at this time of the yeor, OYQro11, these orBCts are favorable habitat for future plont populations. Intensification of the current use Qfiminates any prospect of a nat~,rai succession and movement of plants and animols in th4 area. Aesthetic imposts ate understated., This project greotly increases the visual impact of an industrial orea~ in the heart of o biological preserve. It will be deleterious to the whole atmosphere of the mountain, to both humons and wildlife, There is no discussion of altemativos.. The no project clternative of siting the proposed facilities on other, less sens'ltiw 'hilltop habitats or building-tops should he ; analyzed as well os shara~d/cooperative arrangements with the existing soteltite focillHes. Ignoring post performance, the proposed mitigation measures, in particular $3,500 per year contribution to the HCP, scorc;ely compensates for the proposed destruction and toss. The proposod easement mitigation does not compensate for the loss, as it is not Qqual in habitat valuo and could not be developed for many of tfie some reasons offered in this letter. In cor~dusion, your findings for fhe hosts of issuing a negotive declpration are not suffident, in potticuler, impacts to the Aoro and fauno, oesthetics, and lade of discussion of cumulative impacts warroints prepa+ofion of Environm®ntal Impact Report. ,,rr~~ , S~~ rely/G~G~~~.~ . ~~~, eoAeervntbn Co-CAoir 8igp, President San Mateo County (485-1533) Yerbo Auena Chopter (7 1 8) oc: USt-WS CDFO Sort Fnancisoo Chron~l~ Sierra Club, l.orno Priata Chapter CNPS, Ray BuNer, VP Oons4rvation and Kin 8ogOon, Legal Advisor TOTAL P.OS CEC-05-1994 16 42 FROM PLANNING & BUILDING TO TO: Sam Herzberg, Project Planner, San Mateo County and the US Fish and Wildlife Service FROM: Dana Dillworth, President, Boy Area Mountain Watch RE: EIR/EA Amendment to SBM HCP and ESA SEC. 10(a) PRT•2-9818 93274024 P . 0'7 San 6runo Mountain is a fragile ecosystem already oomprornised by the existing communications facility at its summit. This expansion plan is akin to the invasive species epidemic: an aggressive, uncontrolled multiplication of matter with permanent, irreversible impacts displacing the native plant community's chance for succession - at an alarming rate. (ln 19$1 - 10 towers, 8 buildings, 1 stofion; 1982 - f 0 stations, 200 sq. ft. building; 19$3 - 22 stations, buildings/roads; 1985 -building; 1988 - 525 sq. ft. bldg and roads; and 199 - 32 st ions loss of 1 acre habitat to buildin sand numerous undisclosed im cts.} Like invasive species, this trend must be eradicated, NOW!! TN EIR FAi S MANY SPECI-S: L~1e yroiect description understates the nro~ect (S-1) by using concealing language like 'analtary faali#ies" and 'existing developed areas.' ft fails to mention a 400' horizontal bore between ravines 1 and 2, a neoriy one-acre habitat loss, and the shear volume of water proposed #or use at the "F" building site, 2 This information is not completely forthcoming in the 'Project Components" section either (p. 6 - 8). The amount of grading needed for building 'G' is never disclosed, whether blasting wilt be required because bedrock is at a depth of less than one foot in the ravine is not disclosed, neither the extension nor repair of roads to serve ravine 2, nor the amount of grading requited in ravine 2 is disclosed. It even calls the construction of two dwelling units a 'modificafion." As such, it requires that the reader accept the leap-of-faith conclusions that the impacts will be limited to the footprints of the buildings and pla#orms and that all pan be mitigated to the level of insignificance. 3 Cumulative impacts analysis is entirely lacking,, The reoder must envision each component to comprehend the magnitude of the project. The fact that o geotechnical consultant indicated that the "soil is suitable for a french drain' (in ravine 2) does not mean that, environm®ntolly speaking, that is an appropriate 4 mitigation measure, nor that it would mitigate the impact to the level of insignificance without creating its own impacts. If fails to mention the limitations of the system, the additional site preparation necessary, the importation of rock/drainage materials, or off-site impacts of diverting water. DEC-05-1994 16 43 FRGM PLANNING & BUILDING TO 93274024 P.OE -2- The report projects the additional septic foods to be `intermi#ent' (building "E") vr'light' 5 (building 'G') without guaronteeing thot to be the case. The oddition of six parking spaces at building 'G" indicates a greater usage than eluded to in the EIR/EA. The new feachate loads fvr buildings "C" and the combined 'E'- 'F" system are not quanfified. The impacts of additional nutrients and polluting the watershed with human waste, soaps, toxic chemicals (etc.) is not discussed. Nor is approval from the Regional Water Quality Board indicated. Additionally, since the bulk of the 'F' building water (as is other sites) is used for cooling the transmission towers, the impact of rned woter entering a sensitive habitat is not discussed. 6 Cumulative traffic impacts is not credible at `less than five additional vehicles a day.` Two 12-hour shifts to the 'C` building without a trip for lunch, messengers, or errands is four trips alone. Furthermore, one trip could have a devastating impact on wildlife. The purpose of a cumulative impacts analysis is to determine whether individual effects, when considered together, hove a compounded effect. Since a lot of information is not even discussed, it is not possible to engage in an adequate cumulative impacts analysis. The ran of reas noble alternatives an s's is inad ate. If you accept the notion that a dwelling unit is necessary for security (which t do not) then 6Q0 square feet is adequate for that purpose. Dining rooms, decks, more than one 8 unit and the applicant's indication that they will not adhere to the 'no-pets' rule or be held responsible for monitoring poachers belies the credibility of their daim that security is the in#ended purpose of this structure. Furthermore, remote cameras, other locations such os the entrance to Radio Road - an area already destroyed by eucalyptus- or under-utilized buildings (250 Radio Road in particular) are a few potential alternatives that have not been explored. The applicant asserts that this is the only location for the project, absent any facts to back this daim. Since Watson Communications owns many hilltop facilities throughout the iBay Area, there must be other, less sensitive habitat areas that could bear the brunt of this massive project. This project could be scaled down #or this si#e dnd redistributed to those other facilities. Reasonable alternatives, that would still achieve the applicant's objectives, need to be considered. Co ions a erro s. 9 Statements regarding aesthetics are contradictory (p 40-41.) 't'he two-story buildings will clearly be visible from 6risbane, the night lighting will be disturbing. The dishes in ravine 1 are dearly visible from Serromonte Shopping Center. A building with dishes on top will be even more so. Camouflage painting does not make the impact more acceptable or insignificant. DEC-05-194 16~~=.'4 FROM PLANNING & EUILDIhG TO 9?274024 P.09 -3- It is ironic that the odjacent pork recognizes that 'the generally open. oaturot character 10 of San Bruno Mountain is one of its greot resources to the surrounding Zones of development' (emphasis added) and that a more than threefold intensification at its summit would be considered consistent and compatible with the neighboring uses. 11 Are there any limi#s #o the intensity of development at this site? This project sets a precedent: it it is allowed, future intensification could not be stopped because the same reasoning would be applied -it's infill, it's a modification, it's consistent with previously allowed uses, etc. Therefore, these conclusions must be oorefully reviewed for their pofiential for long-range, site-s chic grewth-inducing impacts. 12 The Comment under the 'no project' alternative that 'old faalifies would continue to deteriorate' (p Q3) without this expansion is inappropriate and has no place in an EIR. !t is incumbent on the property owner to keep their property sate and irrelevant to the consideration of envi-onmental impacts. ~ 3 There are severot comments that the lupine near building 'C' have not had Mission Blue associated with them. Since butterflies are mobile, there is no evidence that they would not visit the site. The map for Collippe indicates that this area is very important for ahem. Since the status of Callippe is presently, actively under consideration, it is prudent to give equol consideration to this species. (Personal communication with Dr. Hafernic.) The fact that adult animals have not been observed is a specious argument for allowing further disruption_ 14 The assumption that increased Dash payments to the plan operator will mitigate the loss of one acre of habitat to insignificance is pure speculation, There is no evidence that new or better quality habitat has been or will be afforded by this measure. There is no guomntee - no deposit or perfom~ance bond -that this mitigafion would be effective. There is no measurement, no means to determine whether this purported mitigation measure would indeed reduce the impacts to the level of insignificance. 15 It is erroneous to believe that there would be no impacts to removing the collapsed building debris opposite building 'F'. While t was probably the person to point Dui this eye-sore to the Planning Department, I would venture that it is integrated into the envsronment, teaming with wildlife, functioning both for shelter and food. 16 The reasoning for the variances is spurious as welt. One purpose of setbacks is to keep the buildings in scale with the property, The front yard variances will have an impact on the appearance of the project because the setback areas will be used for parking. The earlier drawings indicate thot screening/security gates will be odjacent to the road. These voriances would allow buildings that are inappropriote for their landmass - making them prominent ridgetine features. The variance for the septic system would concentrate the teachate in a sensitive habitat and for the reasons previously stated, should not be allowed. DEC-05-1994 16 45 PROM PLANNING & BUILDING TO 93274024 P. 10 There has been no biol~ioal study as required by CEQ'4, to determine whether the 11 plant and anima! spedes at the summit differ genetically from the species found in more protec#ed areas. The summit ecosystem should be jealously guarded for its ability to have survived these harsh conditions, thus far. it would seem that any respected environmentalist would come to this same conclusion; the project is beyond the ecosystem's ability b support, it should not ~ approved. fn conclusion, the SIR is deficient and should be withdrawn. The mitigation measures are unproven or inappropriate for the site. The varionces arse unsuitable given the constraints. The application to amend the HCP should be denied as the empirical need and data has not been established. a9~,~/~~r~-- TOTAL P. 10 DEC-E5-1994 16 55 FROM PLANNING 8 EUILDING TO 9~2'~'4L24 P.02 LAW OFF1C8 OF BRIAN Gh~'FNEY 625 Second Street, Suite 17.0 Petaluma, CA 94952 (707 ) 766-9267 Phone (707) 766-9865 FAX VI ~RTGINA,I. BY MAIL September 2, 1994 Mr. Sam Herzberg San Mateo Gounty Planning Department 590 Hamilton Street Redwood City CA 94063 Re: Comment of Bay Area Land Watch regarding Draft EIR/I~A prepared for Watson Communications Expansion on Radio Road o~ San Bruno Mountain, San Mateo Gounty (Fi.le# USE 81-36, VAR 93-007.0, ENV 93-0163] Dear Mx. Sam Herzberg: Enclosed please find our comments on this matter. The attached comments are meant to incorporate and supplement comments independently submitted by other members of the public and should be considered in context with such othez' comments. Please include my above-noted address and that of David Schooley, Say Area Land Watch, P.O. Box AO, Brisbane CA 94005, in any further communications to the public by your office on this proposed project. I am particularly interested in learning the dates on which the San Mateo County Planning Commission and the Board of Supervisors will hold public hearings and formally consider this issue. If you have any questions, please feel free to contact me. Thank you for affording us this opportunity to comment. Vex truly yours, Brian~f'ney ec: David Schooley, Bay Area Land Watch Jake Sigg, Calif Native Plant Society Chris Nagano, U.S. Fish & Wildlife Service Mike Horton, U.S. Fish & wildlife Sexvice DEC-p5-1994 16~~5 FROM PLANNING & BUILDING TO Comment of Bay Area Land Watch regarding Draft for Watson Cvmm. Expansion on Radio Road of San San Mateo County (File# USE 81-35, VAR 93-0010, 93274p24 EIR/EA prepared Brune Mountain, ENV 93~0163J P.p3 I. OVERVIEW Z The conclusion of the Bay Area Land Watch, after review of the Draft EIR/EA for the proposed Watson Communication Expansion project, is that the draft document is legally inadequate because it fails to suf ~iciently discuss: significant environmental impacts, explanations as to why impacts judged non-significant were determined to be so, mitigations or alternatives, cumulative impacts, the growth inducing impacts, the social/economic impacts, inconsistencies between the project and the general and regional plans. In addition, the project summary, project descriptions, the environmental setting description and the description of long-- term and irreversible consequences are each inadequate. Failure to adequately analyze each of these issues will result in violations of the California Environmental Quality Act, the National Environmental Policy Act, and the federal Endangered Species Act. Moreover, if significant new information is added in order to compensate for the deficiencies of this draft report as an informational document, then the DEIR/EA must be renoticed and offered for reconsideration by the public. II. THE DEIR/EA IS INADEQUATE BECAUSE ,IT FAILS To ADEQUATELY DISCUSS SIGNIFICANT ENVIRONMENTAL IMPACTS A draft EIR must identify and focus on possible significant environmental impacts of a proposed project. The analysis should clearly identify both direct and indirect impacts, as they occur in the short and long term. Pub. Res. Code 2X000; CEQA Guideline §15126. An agency should not be allowed to hide behind its own failure to gather data. S trom (1st Dist. 1988) 202 CA3d at 311. This document fails to discuss the impacts that each of the project components listed at p. 6 -8 will have vn the environment. Therefore, the public ca» not independently assess the impact, which may be significant given the resources in the vicinity. The discussion which is provided at p. 28 - 30 is inadequate, among other reasons, because 1) it doesn't fully reveal where the acres tv be destroyed by the pz'oject are located; 2) there is no discussion of the impact Caused by noise and dust related to the relocation of the Tower at Building E; 3) 1 DEC-05-1°94 16~~5 FRGM PLANNING & EUILDING TO 93c740c4 P.04 the shading analysis uses a diagram with an inaccurate latitude projection; 4) the conclusion of no effect on sedum is unsupported by the analysis provided or the diagram at P• Z9. Additionally, there is no adequate discussion of the 3 significant threats posed by vehicular traffic, removal of buildings, addition of concrete pads, grading, noise, dust, and human trampling will cause to: the Mission Blue Butterfly in tseevalsczlInitiaBuStudng GAnswers Phase II (wee Fig. 7, p. 23). (_____-- y • to Yes Answers' reveals the take of a number of Mission Blue Butterfly will likely result; the Callippe Siiverspot in the vicinity of Building C and Building F (~ Fig. 8. p• 24); the San Bruno Elfin Butterfly in the vicinity of Building E, F, Phase II, I, and Building A, and the road used to access Buildings E, F, and H (S_~e. Fig. 9, p. 26) . Inconsistencies between a proposed project and 4 general/regional plans are normally considered significant impacts. therefore the specifics of the proposed Watson expansion which mandate a variance and an amendment to the HCP must be discussed as significant impacts. Here there is no such discussion. Dust has been identified by the U.S. Fish and Wildlife 5 service as a threat to the adult and early stages of the endangered and candidate species of butterflies on San Bruner Mountain. In this proposed project there is no discussion of the significant and cumulative adverse impacts the increased heavy machinery traffic and removal of thousands of cubic yards of dirt will have to the Mountain's butterflies. San Bruno Mountain has been identified as a complex and s fragile ecosystem which faces its greatest threat from invasive, non-native plants. This DEIR/EP, fails to discuss the effect of allowing people to live in the project's new buildings will have on the fragile ecosystem because of the introduction of household plants and pets. 1n particular, see the concerns of San Mateo County Parks Director at p. 15 and response of Watson at p. 16. The construction of buildings which will allow ~aeople to ~ live on Radio Ridge will also increase the chances that people will feed wild mammals and add to increased garbage (~ the concerns of San Mateo County Parks Director at p. 14 and response of Watson at p. 15.) Recent scientific evidence points to threats caused by non- $ ionizing radiation and electromagnetic radiation emitted by telecommunication systems such as those proposed for this project. The radiation may pose significant. threats to humans as well as wildlife. There is no discussion of this threat by the project proponent. The plant, golden aster, is numerous in the site proposed 2 IiEC-05-1994 1E~~7 FROM PUANNING 8 EUIUDING TO 9327424 P.05 for Building G. This plant like lupine is a nectar plant for the 9 mission blue butterfly. The plant is not discussed in the Draft EIR despite the fact. that Building G construction will result in the grading of 9000 cubic yards of earth, of which about 4000 cubic yards would be hauled offsite. The project will likely significantly affect this plant. Although the golden aster is only one of the Mission Hlue food plants, it is particularly important because it blooms extremely late in the season and because San Bruno Mountain is the southern portion of its range. The truck traffic which will be needed to serve the 10 increased number of proposed water cooling towers, the increased number of people living on site, and construction of new vehicular and pedestrian access to facilities (Negative Declaration, project description >~IO) all lead to a reasonable inference that the project will increase off-site development. There is no revelation of the results of the ENGEO and Myers 11 studies mentioned at p. 33 of the report. The California Courts have held that when relying on existing environmental. documents, agencies should be wary of relying so heavily on incorporation by reference as to place an undue burden on the public's efforts to understand the agency's reasoning in assessing a project's impacts. mingt~gn v. Solano Catty (1st Dist. 1987) 195 Cal. App. 3d 491. The location at which the public can review the incorporated documents should be clearly stated. Guidelines 15150(b). There is an inadequate discussion of the stormwatez runoff 12 from buildings, concrete satellite pads, and proposed french drains. The Draft EIR/EA admits at p.34 that even without the proposed project additions water is cuzrently diverted into native vegetation and that not all of existing runoff is carried by the Road drainage channel yr into water holding tanks. The addition of 3z new dish satellites, 10 new equipment 13 shelters, a new 10,000 square foot building, a new 5,000 square foot building, two new dwelling units to an existing building, two new 5,000 gallon water tank, replacement of five additional 5,000 gallon water tanks, boring of a signal conduit hole, and installation of larger leach fields and sewage tanks will cause significant adverse impacts by channeling mote water into gullies, changing the hydrological regime and thereby affecting native plant life, as well as cause erosion. Each new building, satellite dish, and replacement tower must be separately analyzed for its potential for significantly and cumulatively affecting the environment. 14 There is nv discussion of whether the proposed french will take a sustained downpour and how these additions will change the hydrology as it is reasonable to expect that the concentrated water will have to come out somewhere out and thereby affect plant communities and erosion. drains The use of leachfields in this fragile plant ecosystem is TO DEC-05-1594 16~~7 FROM PLANNING 8 BUILDING 15 16 11 18 9~2 r4e~4 P.06 sensitive to table. This area has proven tv be extremely unaccep neater volume leachfi.elds will human impacts. Adding more and 9 no doubt change the hydx'ologacendangered plantulifent load, an thus pose threats to rare an Most of San Bruno Mounta~e study ofoslopef steepness onnthe s percent. ~n early and comple Mountain which the County did not consult in ~ts hoitiQesiaudx~~Yld 6 of w t ~ v the Slope Element Model on prription which was published by the t P]LanninCi D~ ve' xn October 1971. This document was no Crocker Land Company consulted and should be as part of an EIR. In particular the 24 new dishes which are planned far Phase II of the pxoject are planned for an area with extremely steep slopes, must probably over 15 percent. Because of the erosion and water runoff which likely will result from the location of Undor these dishes the impact aver ificantllthe projectednphysical CEOA for an effect to be sign changes need not be forthcoming immediatthe,Draft EIR/BAlitself produce the significant effects. Here, admits at p. 36 that not all slides were confined to areas of open space. In addition~o ectEZR/EA fails to discuss impacts. caused by the proposed p 7 Building G is planned to be built in a swell. Building G may only be supported on footings, not drilled piers into bedrock. Substantial evlndationssextend intorbedrock that nolude that even i f a 11 the ~f ou danger of instability will occur ovex' time. 19 20 21 ZZ In addition Building Ethatttheeunengineerddfillumay settled fill. Kropp was concerned Although the under the weight. of the proposed new building. graft EIR appears to make a recommendation of dz~illed, cast-in- place friction piers, there is no discussion of how this drilling will affect the stability and erosion of the area. The final design of tha structures and dish pads have not been completassessinzetheefulhepotentxalrforesignifmcantsimpact. deprived of g There is no substantial QvidQnce to t~P~rbuildingsertion that addition of 32 new satellites, suppo g leachfields would not have a substantial adverse aesthetic impaart . III. THERE IS NO STATE E pET~IINEDNTO BE SUCHCTS 2DENTIFIED AS NONSIGNIFXCA~NT A draft EIR must include a an explanative of the rationale which prompted a conclusion that impacts, identified as nonsignificant~ocumentefailsnto containuexplanationslasltoewhy 815128. This d a CEC-05-1594 1E~58 FRGM PLANNING & EUILDING TO 93274024 P.0^r the following were deemed not significant: - relocation of Building E Tower (p. 28); - impact tv coast rock cress (p. 19), San Bruno Mountain manaanita (p. 19), arctostaphylos uva-ursi (p. 19), Fransican wallflower (p. 20), San Francisco Campion (p. 20); - removal of o.1 acres of native plants at Phase Z area (p. 30); - removal of 0.$ acres of native plants at Phase II area (p. 30); - Building C's affect on off-site drainage (p. 34); - drilled pier foundation on adjacent habitat (p. 37); - partially unhealed debris slopes in area of Building G (p. 37); - Building impacts on erosion and hydrological regime (p. 38); - Satellite pads impacts on erosion and hydrology (p. 38); - aesthetic change caused by proposed project (p. 40-41); ~- noise and traffic (p.45 and 46); T3 IV• THE DEIR/EA IS INADEQUATE BECAUSE IT DOES NOT INCLUDE A SUFFICIENT DISCUSSION OF MITIGATIONS TO SIGNIFICANT ENVIRONMENTAL IMPACTS Because the DEIR/EA does not discuss all significant adverse impacts, as shown above, then the discussion of mitigations presented to date can not possibly have identify all specific mitigation measures. Yn particular the document makes no mitigation provision for, among others, the following impacts: dust, pesticides, leachfields, noise, destruction of larval food plants, take of endangered species, erosion, stability, aesthetics, traffic. Z4 V• THE DEIR/EA IS INADEQUATE BECAUSE IT DOES NOT INCLUDE A SUFFICIENT DISCUSSION OF ALTERNATIVES Neither of the two altex-natives press»ted includes a sufficient discussion comparing the environmental impacts of the alternative implementation with the project as proposed. In addition, there should be included a discussion of the comparative environmental benefits of removing the existing facilities on Radio Ridge with the land passing to the State or County Park system. Y5 Vr• THE DEIR/EA IS INADEQUATE BECAUSE IT DOES NOT INCLUDE A CUMULATIVE IMPACT ANALXSIS cumulative impacts are defined as two ar more individual effects which, when considered together, are considerable or which compound or increase other environmental impacts. CEQA Guideline §15355. A cumulative impact analysis must view the proposed project in connection with other related past, presQnt, and reasonably foreseeable probable future projects whose impacts 5 93274024 P.08 DEC-05-1994 16~~9 FRGM PLANNING 8 EUILDING TO might compound or interrelate with those of the proposed project. FpTC v Jo nson 170 Ca1.App.3d 604, bZ5. The implementation ov tse ~mpactsSon sens~tM~enPlantsaandad cumulative significant ad er p art of thzs EIR. Those past animals which must be considered as p projects whicht~esHCPeallowedesincer1982chthe developments on the amendments to Northeast Ridge, the South Slopes, and Pacific Pointe: t e failure in HCP funding: and the inability of the Habitat rxanager to either succesveunon-natiVes•raTheseaincxementalnyet cumulative eradicate invasi effects acre exactly the type of projects for which the California State Legislature created CEQA tv govern. This analysis is Particularly important here because of the historic loss of habitat which has led to the .status of threatened, rare, or endangered for the 1Mountain's plants and animals. s VII. THE DTXR/SEDDPROJECT DISCUSS THE GROWTH INDUCING IMPACTS OF Z THE PROPO The DEIR/EA alleges at p. 10 and p.45 that the proposed expansion of the Watson Telecommunication System is necessary to keep up with demand for such services. `fhere is no evidence or rationale presented as to why 32 new dish satellites, l0 new equipment shelters, a new 10,000 square foot building, a new 5,000 square foot building, two new dwelling units to an existing building, two new 5,000 gallon water tank, repla ofeatsifnal five additional 5,000 gallon water tanks, boring g conduit hole, and installation of larger leach fields and sewage tanks are needed tv keep up with market demand or how such massive additional construction will not induce growth. Clearly this project will induce gxawth locally as well as throughout the through out the Bay Area. In particular, the fact that people will for the first time be living on Radio Ridge is an increase in population. Aisv, more than tripling of the current communications capacity will induce greater economic activity in this field of telecommunications which field poses potential significant hazards to animals and wildlife. A lead agency must never assume that growth in an area is necessarily beneficial or of little significance environmentally, but must make its judgment in this regard only after open-minded analysis. Pub. Res. code §21100(8): CEQA Guideline §1512b(g). 21 VIII. xHE DEIR/EA MPACTSOOFCTHEAPRO SEDCPROJEC'X' F ECONOMIC AND SOCIAL I Physical changes occasioned by this project include deterioration in the skyline view of the Mountain, decreased use of the Park trails during construction activities, as well as exposure of hikers to increased radiation levels after additional 6 GEC-05-1594 1r~E0 FRGM PLANNING & EUILGIhG TO 93274G24 P.OS satellite construction. Each of these physical changes may cause decreased use of the Mountain as a recreational location which will negatively impact the quality of life for people in the region who look to San Bruno l~iountain for such recreation, and thus indirectly effect the local economy by nv longer attracting visitors to the area surrounding the Mountain. 28 29 IX. THE DRAFT EIS/EA SUMMARX IS INADEQUATE The Summary is inadequate because it does not identify: 1) each significant effect with proposed mitigation measures and alternatives that would reduce or avid that effect: 2) areas of" controversy known to the lead agency from comments submitted by the public and other agencies (including relevant comments subz~itted by Bay Area Land watch and others in response to the Negative Declaration on this proposed project); 3) issues to be resolved, including choice among alternatives and whether or how to mitigate the significant effects. For these reasons the Summary violates CEQA Guideline §151.23. X. THE DRAFT EIR/EA PROJECT DESCRIPTTON IS INADEQUATJr. The DEIR/EA is inadequate because it does not include a general description of the proposed project's technical, economic, and environmental characteristics. See CEQA Guideline 15124. The document only contains a list of new or modified structures at p. 6-8, but no description of the environmental. characteristics of the land or its surrounding, or of the technical aspects of the grading, erosion, and habitat disturbance/mitigation. In addition, the document does not discuss the specifics of each of the planned additions or changes listed as `Project Components' at p. 6-8, nor define the terms 'Phase I, II, and III' of the proposed operating program, nor what is considered 'Ravine 1.' The project description is also inadequate because it does not include, either in the Project Description (Section I.C.) nor in the section entitled `Conformance with Plans, Ordinances, and Policies' a list of the agencies expected to use the DEIR/EA in their decisivnmaking as well as a list of approvals for which the document will be used. t~i21 this document be used by CDFG for evaluation of project compliance with state endangered species or public trust laws? will San Mateo County use this document in determining whether to deny or grant the use permit, and the proposed variance and the HGP Amendment? How else will the document be used and by whom? what is the order of Such decisions? The draft report also fails to account for reasonably foreseeable future phases of the proposed project. egg laurel Heim, 47 Cal.3d 376, 393.399 (1988). Because of these omissions, important ramifications of the proposed project remain hidden from this discussion and thus frustrate the goals of CEQA. gantiavo Count, j Water District v Qn»t~ty of orAr„o ~ l l g C. A. 3d 818, 830 (1981). 7 DEC-GS-1594 17~E0 FROM PLANNING & EUILDING TO 932 ~ae2a P. lE "Only through an accurate view of the project may affected outsiders and public decision-makers balance the proposal's benefit against its environmental costs consider mroigsal°and measures, assess the advantage of terminati~9tinty of Pnvo v. City weigh other e1te71aci~e3d~185 ex92~J.93e(Ig77). XI. THE DEIR~EA ENVIRONMENTAL SETTING pESGRIpTION IS INADEQUATE 30 The description is inad~q~nt~eevacinity ofetheopr jectaebut evaluation of the envlronmen only dixectly on the project site (21.4 acres) and an overview o the mountain as a Shteei~3anC~~eaedirectlytadjacentxto thethe 2i.4 care project art of the environmental project site that is not described as p setting. Tn particular there is no descriptioneC~ sitetxOThispis for plants in the adjacent vicinity to the prof an important omission because the butterfly location maps show concentrations of listed butterflies in such areas which must depend on host plants. The list of plants of concern EP•1`3-20) and their location (p. 18) are incorrect because they do not indicate the golden aster located in the vicinity of Building G. -discussion of hydrology and drainage at p. 34-35 is inadequate because it does not describe drainage conditions before project commencement - discussion of slope stability at p. 35 - 36 is inadequate because it does not adequately describe conditions of each of the many varied slopes before project commencement - discussion of aesthetics at p.40 is inadequate because it does not adequately describe aesthetic cax~ditions before commencement for each of the 10 towers, 8 control buildings and 1 satellite station. 31 XII. THE DESCRXPTION OF LONG-TERM AND IRREVERSIBLE ENVIRONMENTAL CONSEQUENCES IS INADEQUATE This project propose to alioo~ massive new development to occur in the same vicinity as populations of, among other, San Bruno Elfin, Callippe gilverspot, and Mission Blue butterflies. The populations of Elfin and Mission Blue continue tv fluctuate without any` movement towards recovery from their endangered status. In addition, the plight of the Callippe continues to worsen and the U_S. Fish and wildlife Service is today considering listing it as a threatened or endangered species, and designating critical habitat for the Callippe, because of continued decline in population numbers on this very Mountain- The further decline of species populations is de facto a long- term and irreversible environmental consequence. Failure to assess these impacts makes this document inadequate as 8 L'tC 85-194 17~E1 FROM PLANNING & BUILDING TO 93274024 P.11 informational document for local. decision makers or the concerned public. 3Z XIII. THE DEZR/EA IS INADEQUATE BECAUSE zT FAILS To AISCUSS ALL INCGNSiSTENCIES $ETWEEN TN1G PRQJECT AND GENERAL ANA REGXONAL PLANS The document (s~Pg p.ll) fails to discuss the inconsistency between this project and the Section 10(a) permit, the Habitat Conservation Plans (HCP), and the HCP Agreement. What are the specific changes which necessitates ara amendment? The project only discusses Fws role in processing and appro~ring (or denying) amendments to the above documents. The px-oject at p.ll fails to discuss inconsistelncies between the project and recovery plans for the listed plants and animals. The project at p.12 fails to discuss inconsistencies between the project and local general plans. The project at p.12 fails to discuss inconsistencies between the project and the use permit which has resulted to the project pzoponents application for an amendment to the use permit and for a variance. 9 TOTAL P.11 1730A Jones Street, San Francisco, Ca 94109 775 1812 August 29, 1994 Attn: Planning Division, County of San Mateo Mail Drop 55RC1-00 590 Hamilton Street, 2nd Floor Redwood City, CA 94063 ~Re: FILE USE 81-36 and VAR 93-0010 WATSON COMMUNICATION EXPANSION ON SAN BRUNO MT. DEIR AND HCP - 40vdishmantennae. Assessment. New 250'tower, new buildings, DRAFT EIR THIS DOCUMENT IS INADEQUATE IN THE FOLLOWING AREAS OF CONCERN. Providing this essential information is a matter of meeting "full disclosure" needs of CEQA and NEPA. It must be c..lsted :•:; th the draft ET_°. amt simpl;- passed off ir, a F-^-al i Z ' ~ ~- EIR. 1. Need for project - alternatives, demand documentation. THERE IS NO DATA. What do competitors say is the need for this project? In order to better protect the exceptional rare species habitat on San Bruno Mt., why not expand other Watson Tele-communication facilies in the Bay Area? Would 6 dish antennae serve the "need" rather than the 32 and then 6 listed on Page 1? This entire project and the threat it represents to a rare and endangered community is based on a presumed 'demand' for which there is no factual support. 2. General Plan - Conservation Element. What are the conflicts here? Is the Conservation Element to be ignored whenever economic benefits can be conferred by a project? What are the stated goals and requirements of this and other pertinent elements of the General Plan. 3. ENVIRONMENTAL IMPACTS - Relocation of 250' Tower into the single most important area of San Bruno elfin habitat based upon census population. (Page 30) Consider worst and best case scenarios of construction period impacts - of high winds with blowing dust settling on cushion plants with broad leaves, and larvae at their base. On Page 43, Bldg. E and Tower (last paragraph) is described as providing an expanded area in which to house new high definition television transmitters! What possible chemical leaks, electrical fields, lighting, and other operational impacts will this have on the rare species? What studies have been done or need to be done to know impacts of 'new high definition equipment'? To assume there is none is very worrisome. 4. Building construction alternatives. San Mateo County Parks has an unused maintenance facility available for long term lease near this project. What would be the impacts if this facility served the proposed building needs? Construction impacts-are not assessed even though this is highly sensitve habitat in an extremely windy, steep area. The butterfly host plant species are directly on the road banks. 5. Clarify Radio Road use. Is this a public right-away? Is there a County road easement or other long term agreement? Why does the County pay for any road work if it is privately owned? How much does the County pay for such services benefitting this private company? 6. Leach line impacts - what are they? Do they extend into public open space? Why isn't there mitigation? What accidental overflows, misuse are possible with what consequences? 7. The San Francisco Campion population near the parking lot at the top of San Bruno Mt. appears to have significantly diminished over the years? Does HCP research confirm this? What reasons have been given? Is it connected with expansion of facilities? What about other nearby rare or host plant and rare species have these declined over the past years in this area? Does the HCP contractor have baseline data on these plant populations in terms of size and location? 8. Scenic values. How is it that a new 250' tower location is to have no scenic impacts - or new buildings with 15,000' of structures added is not to be noticed by park users when the Summit Trail goes through the complex and it can be seen from long distances? Is this realistic and without bias? 9. Variances permitting structures to abut open space can allow more development on this site than would be possible and are certainly more intrusive to open space users. Again there is lack of reasonable objectivity in this section of the document. Data is weak if non-existent. No sightlines, no photos. ENVIRONMENTAL ASSESSMENT FOR AMENDMENT OF HCP. This document is incomplete in assessing both the need for this project and its impacts. USFWS on P. 44, B describes the benefits to the natural values of San Bruno Mt. with no amendment to Habitat Conservation Plan. These benefits include no new 250' tower in a new location. As the construction and operational impacts have not been analyzed, it would seem that USFWS could not, in any case, approve an HCP amendment based upon this document. Denying the HCP amendment would eliminate the loss of 1.2 acres of native vegetation. PLEASE REQUIRE MORE SUBSTANTIVE DATA. Susan M. Smith ~, ~ TO 93cn40c4 DEC-05-1894 16~G0 FROM PLANNING & EUILDING -W ~ ~IEAI~'I'H SERVICES AGENCY ~ ~ $' ENVIIZONI~tENTAI, HEALTH S1rRVjCES DIVISION ~~ ~ MEMORANDUM DATE: August 23, 1994 TO: Sam Herzberg, Planning Department FROM: Stan L,ow, Environmental Health Q~ ~~ r;R for Watson Comm_uao~c.~t.ion Srrstems SUBJECT: U~ Enclosed are my comments for the abovementioned project. P.04 On Page 34, under Building C; Non-potable water from the roof and gutter system is being proposed to be collected in a holding tank. The non-potable water will then be used in the basin, toilet and showers. However, the Uniform PlumbingT °dusenaf a ho d n tank must be connected o the public to the basin, toilets and showers h 8 water supply or domestic well as a water source. 2 A soil percolarion test was conducted on April 14 and April 15,1994. The data from the test will need to be submitted along with a plot plan showing the location of the test holes. The applicant's consultant will Held to submit the design anal sizing of the septic systems tv this office for review and approval. [,:Vandinecc~t+erntxrg.sl SAN iVIATEO COUNTY BOARD OF SUPERVISORS RUBEN BARRALES • MARY GRIFFIN • TUM HUENING • 1'>rll E,EM1'EKf • MICHAEL. D. NEV1N HEALTFI SERVICES AGENCY DIxEC'IOR MARGARET' TAYLOR ENvIRONMENTAL }{<;,0.LTH SERVICES DIVISION DIRbCTOR BRIAN ZAMORA, MPH. REHS 590 HAMILTON STREET, REDWOOD CITY, CALIFORNIA 940b3 rKOrrL (415) 3G3-4305 • Tno (4151 573-3ZOG • rwx (415J 3~3-7882 ATTACHMENT A TOWER HEIGHTS ._ *M. ... ~, ~l ~ m z :D z R• ~ " 0 ~ `. 0 z A 0 s ~ .. z ~ M r G °a 4 ~ w 'w ;yw ~ V p ~ ~ . ~~ , ~~~ ~ ~ \ O e~ ~i q ~ V ~ ~ ~ I ' ~ ~ ~ Q ~. re. ro.sw ~ m ~ ~ Q ~ h ~ / ~ ~ ~ J ~ v O Q O ~ ' a ~ O ~ 1e ~ R Q L) ~ V ve e~l ~~ a~ O ~ ` 2 0~ v ~ h 1 ^ ~ Z • IV'' V Q I~I~~~ W .+1 ~ ~~~~0 •+ -~ Q 4 v~ ~ 4 I ~ '' ~~ + ® Qa m > ~ ~ j •~ , e ~ , ~ . e ,,r ,, ~: ~' ~ r. a ~ , . ~ e ~ , ire . ,~ ~~ / r~ ^L'rac:s ' ~a : ~ ~ ~ ~~ ^ t .w ^^r\/ ~ Q N pr ~ + r w `~ ~ 1 ,t } F b ~ ~ ~ 4.r}r ' 1 a I ~ 3 G o ~ " Q ~n ~ (V ~a y ,-~ \ ' j ~ ~ a ~ m ' 4 \ a • •a• titi ' i '! e e-e ~~ ` ^ ^ 1 ti + ~ ~ M1 ^e G~ ~) r I ~ O ~ 9 ~ Q~ e 7a 1 ~ ~ s ~~• i P-I i~ ~ a ~ • ,. ~ •.~~ I. ~ • •.. 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KyOf-TY - M1NpR-fM ;7 at 15; 122 26 04 In4' 1315/1499 b 2-rsr 37 t1 t5; 742 2b Ot X50' 1225/1315 c, nTSf•TV, CTCt i7 a1' il; t?2 16 OS 259' 1260/1539 1J r;OTV - KCSt•1 37 qt 07; 122 26 01 215' 1251/14G6' • Q,::2fdrenCe i`4la:aaaavlntloCitionlOn "San Bruno' 122 26 04.097 ;~ at 15.017; par USGS MWNT SAN NRUNO "` ~.. 'r~ ~ ~ ~ / ~ \ 1 ~ \ p / O } ~ 1 i 1 D ~` r1 1 1 \~ ~ ~ ~J v i ,,;n; )-22-80 1 , SAN t3RUN0 Cp~1AUN I CAT t ON5 r~ ATTACHMENT B VISUAL ANALYSIS 0. ~ ._ ~' ~~ C~ 3 ` ~~~ ~~ ~ ~ - ° .. p ~ 'O ~ w _ . .._ .... ~~ ~./' ~ ~ ~• c 00 ~ ~, N ~ $ ~ ~ m W ~ ~ ~~ ~ c "•y ~ ~ _ ~ ~ U ~ ~- ~ ~ v ~ ~, ~ c~ ~+ V S". ~ ~ ~ ~ s' bA ~ ~ .s ~ ~ "~ 'C ~ ~ 'O cC ~ ~~'' ~ O ~_ ~ V C~ _._. _ ...,..~-s.~ y ~ O, ~ ~ ~ ~ ~ ~ ~ ~ '~ ~ ~ ~'~ +-+ ~ ,: ~ ~ ~ ~ c a ~ o ~ .. . ~' +~r„_~ ~~ ~~`, ~ fl.. c ~ '3 c a• 3 -- -o c a~ c ~ a~ U ~ r~/7 ^ ~ O . ~ y ~ > _ _ ~ _ .M O t+ C • v ~ `~ w _ 3~~i ..- ~ y ~ U •] 'O C3 ~ l` y s ~, ~ _.. ~ '~ = ;... r o '~ ~.. ~ ~ :J ~ 3 ~ ~ v v L .~ y ~ cs ~ ,~ s T~ ~! ~ ,_ 3 ... :~ 00 O N a 0 x a m U 3 m M a c o~ 0 N N ~ _ .~; _ ,, . ~ -v a ~ :: a~ ~ ., C], ~ 3 ,.,_, ,,_, ~ °~ " Q. ~ :, '~ . mom/ ~ ~'~ , ? ~ ,~ ~ c~ '~ ~ ~ ~_ '~ ~ " ... "C N c~ j„ v~ O 3 -~ i, ... i -, ~~-+ o y ~~:+ ~. ~ t. b O N ___.. _ - ~ "C ~ O ~ ~ bA ~ ,~,~// ~ ~, Fri a ~ ~ '~ ~. S ~ fem.' X ~ ~ ~ _..-- ~~. N ~" ?o ~ SZ' c~ 3 ~ ~ ~ ~~~ ~~b 1 ~ N U ~ ~ ~ ~ ~ 'C 3 ~ a~ ~ ~ ~ ~ ~ ~ t ~ .ti C~" k ~ Q) O ~ ~ i 3 ,~ ~~ ~ ~ o 0 Q~~ ~ .~ ~ ~ ~ ~ c ~ o ss, .~ ... ~ ~ U ~• ~ ~ a ~ .~ ~ H ~ .3 ~, V t. 3 a~ °_? ~ o ~ a 3 ATTAC~:[MENT C ~. WATSON COMMUNICATIONS FACILITIES .._. ~. ~_ id ij ~~ i~ ~~ ~ ~ -~_ ~ ~-- ~ N ~~ N CQ ~ ~ ~ ~- ~ ~ ~ ~° ~~ ~ ~ ~ ~ ~ ~ O ~ ~ u -~-- ~ '' m ~- ~-N ~ ~ ~ ~ ~ ' _ ; ~ I ~ ~ ~ ~ ~ ~ ~ ~ ca i ~ ~ - ' ~ »~ ~- -~ ~ m ~ ~. cfl a Q '~ ~ U L L t ~ L t ~ ~~~~ L t u~ ~~ N N N CCI CC! C91 l91 ~1 CCI CO CSC Cf! Cq l4 CCI Cq W •,_.-' •~-• •-" W LL ~ ~` '~ `V la l~ '~ '~ ~ I W' CSI W lLl CO l9 i ~~ i ~ i i i ~ O I I ~ ~ a~ c ~ i i ~ ~ L ~ ~ _ ~ ~ ~ j O o~`~ i r- ... c ~ ~ cn j i ~ i i I! ~~ ~ i I~~ ~` ~~ ~ ~ ~ ~. w ~q m ~ `n ~ ~ ~ ~ ~ i i i _ °- °- ~ ~ i X i ~~-~---- i ~ ~ ~~ ~ v ~ ~I ~ Z ~ i~ ~ ~ i In __ ~i ~ ~ i ~ v o ~ ~ i i ~ ~ --- - I~ U ~~ ~~ ~~ ~m ~;~ ~~ --~-- ~ ~ p U ~ m Q U ~ ~ C11 ~ ~_ .._ ~_ c ATTACHMENT D RESTORATION PLAN ~• PACIFIC OPENSPACE, INC. ENVIRONMENTAL PLANNING 3 RESTORATION Curtis Eisenberger Eisenberger and Associates 2845 Noriega Street San Francisco, CA 94122 October 24, 1994 RE: Watson Communications San Bruno Mountain Transmission Facility Restoration Plan Dear Mr. Eisenberger: This letter describes the revegetation and erosion control methods to be used at the construction sites along Radio Road on San Bruno Mountain. Restored Vegetation The present vegetation along the upper portions of Radio Road is scrub, along with perennial grasses and herbaceous perennials. The main shrub is Coyote Bush (Baccharis pilularis consanguinea), and the second most common plant is Sand Reed Grass (Calamagrostis nutkaensis). There are no trees present on any of the project areas. A species. list is enclosed, showing the plants located during a site survey on October 21, 1994. The replacement shrubs and herbaceous perennials will be planted from container stock. The spacing will be 2.5' - 3' on center. Planting will take place during the winter months, preferably late November to January. Erosion Control The restoration sites are all susceptible to erosion. Very small sites on flat ground may not require erosion control, however, erosion control is necessary on 'most of the - disturbed ground, particularly the hillsides. Native grasses will be seeded to provide groundcover until the shrubs mature and establish roots to stabilize the soil. Due to the high winds, hydromulch alone may not provide adequate moisture retention to permit germination. I recommend erosion control carpet be tacked over the seeded areas. P.O. BOX 744, PETALUMA CA 94953 • 707 769.1213, FAX 707. 769.1230 Ravines 1 and 2 present a logistical problem. 4n large slopes such as these. I generally recommend tackified straw or hydromulch, as it is less expensive than using erosion control carpet. On these sites, however, the satellite dishes preclude the use of hydromulch or blown-on straw. Therefore, erosion control carpet is the most practical alternative. Site Preparation It is assumed that all of the ground will be prepared by the crews constructing the pads for the new satellite dishes. The soil should be smooth, with no large soil clods, aril no significant undulations that may trigger erosion. The Building C site requires special attention. The original vegetation behind Building C, where the restoration will occur, must be completely removed, because it is overrun with German ivy. This highly invasive plant will ruin any restoration in the area. acid will spread into adjoining natural areas. The removal should ensure that all the German ivy is eradicated before restoration begins. I have not included a quote t',,r pravin~. because the grading alone may eliminate it. 'Che need for spraying will he reasse.;,~•~t during construction. Irrigation Assuming normal seasonal rainfall, the plants would not require irrigation during their first winter. The peak of San Bruno Mountain is very windy and dry duriri~ tti~• summer months. The grasses that are seeded on the site will generally survive their tir;c prolonged dry season, but the container stock would be at high risk. The newly installed plants would likely die of dessication unless they are watered every two to three weeks through their first summer. I recommend temporary irrigation systems on planting projects such as this, however. there is no existing water supply at the top of San Bruno Mountain. It is possible to hand water all the plants, but it can be prohibitively laborious and expensive. I would like ro automate the process as much as possible; possibly using holding tanks and irlstallirr~,~ ;, temporary irrigation system wherever feasible. I have not submitted an estimate for irrigation in this letter. I will plan an irrigation program after further conversations aircl planning meetings with you. Parent Stock for Plant Materials All container stock will be raised from materials collected on San Bruno :Mountain We have found from previous experience that there are riot sufficient quantities of rrat~"• grass seed on San Bruno Mountain for a project of this size. For that reason, we would i,~~ buying native grass seed from commercial sources. The seed we buy would he fr~~ur E., -t Bay parent stock. Cost Estimate The cost estimate for erosion control and replanting is summarized below. Area Cost of Cost of # of Cost of (sq ft) (ac) seeding erosion plnts plntng cntrl Site H 900 0.02 110.77 381.35 144 720.00 Site E 2700 0.06 227.31 1144.05 432 2160.00 Bldg C 6500 0.15 293.88 2754.21 1040 5200.00 Ravine 2 21780 . 0.50 1581.60 9228.71 2420 12100.00 Ravine 1 22500 0.52 1594.21 9533.79 2500 12500.00 1.25 6536 Total 1212.12 3531.36 8248.09 22910.31 22628.00 59529.88 I estimated the areas of Sites H, E, and C that would require treatment during a site visit on October 21, 1994. For Ravines 1 and 2, I measured the total areas of each ravine from the map you provided, then divided by 2. The actual • square footage for each treatment site will differ from my estimate, and the restoration price would be adjusted accordingly. Ravines 1 and 2 are large areas that are costly to repair. This is largely the expense of hand planting the container stock, but it is also the cost of installing the erosion carpet. It may be possible, depending on the construction schedule, to lower the cost substantially by using tackified straw, rather than carpet. For this to occur, we need to apply seed and apply erosion control after the pads have been set, but before the new antennas are installed. The erosion control would need to be applied in September or October. The cost would also, of course, be lowered if the disturbed area is less than estimated. Thank you for requesting a restoration estimate from Pacific OpenSpace. I would be pleased to answer any questions you may have about the proposed work. Sincerely, Dave plow Plants Identified at the Restoration Sites Site Visit -October 21, 1994 H E (Bldg 6) (Bldg 4) Ravine 2 Ravine 1 rasses Calamagrostis nutkaensis Sand reed grass X X X _ Elymus g autos B ue wi rye X X Festuca ru ra Re escue Perennials Anaphalis margaritacea Pearly everlasting X Aster chi ense Aster X Herat eum lanatum ow parsnip X _ Iris douglasiana Iris X Rubus ursinus B ac erry X X ~m spat u ifo ium eum Shrubs Artemisia californica Coast Sagebrush X X X Bacc ris p~ u ris consanguineum oyote rus X X X X Bacc ris p' u aril p' u ris oyote rus (prostrate) X eanot us t yrsi orus a ' ornia i ac X riop y um staec ifo ium Lizar tai X Ho o iscus isco or teen spray X Mimu us aurantiaucus o e ower X X X R amnus ca ifornicus o ee erry X Vaccinium ouatum uc a erry X ATTACHMENT E ~. RADIATION HAZARD REPORTS _, ,~,~t ~ San Bruno Mountain Earth Station by E. H. Villaseca 29 August 1984 .. u • NEAR FIELD RADIATION LEVELS FOR AN EARTH STATION ANTEN1dA BACKGROUND The prediction of electromagnetic polder density distribution for an earth station antenna can be accurately computed using Geometrical Theory of Diffraction (GTD). Conceived by J. B. Keller in the 1950's and developed continuously since then, GTD is now established as a leading analytical technical in the prediction of high frequency diffraction phenomena. Basically, GTD is an extension of geometrical optics. GTD adds diffracted rays to the geometrical optics Which uses direct rays Prom the source and reflected rays. The diffracted rays account for the effect of surface discontinuities such as edges, corners or verticies. The diffracted rays describe the diffracted field. This diffracted field smoothes out all the otherwise abrupt boundary transitions in classical geometrical optics. Figure 1 shows the geometrical optic boundaries for 2n earth station antenna. In the figure, the collimated beam is bounded by the reflection boundary. Within the collimated beam are the parallel reflected rays from the main reflector. The near field of the collimated beam contains virtually all the energy within a cylindrical shape with the same diameter as the main reflector. On the other side of the reflection boundary are found direct rays from the source and diffracted rays from the main reflector and the subreflector. The shadow boundary separates the region of reflected rays of the subreflector and the direct rays of the feed Prom the region of total ray blockage by the main reflector. At the main reflector edge, diffracted ~ ~' -- Collimated Beam 1 I 1 I I I i Source ~~- Reflection Boundary Reflected Ray ~ ~~ ~ ~ Direct Ray ~ ~ ~ Sub ~ ' ,~~ ~ eflector ~ ~ i _ ~/Shadow Boundary ~5 Main Reflector Figure ~ Reflection and Shadow Boundaries ~~ ,, ~ rays are generated with the strongest component along the reflection and shadow boundaries. These main reflector diffracted rays together with contributions from the subreflector diffracted rays provide the continuous transition through the reflection and shadox boundaries. The diffracted rays play a major role in creating the difference Detxeen the near field and far field patterns. Only in the far field does a fully developed structure of mainlobes and sidelobes appear, although these lobes begin to form at shorter distances. To an observer in the near field. the diffracted rays from the main and subreflector are non-parallel. These non- parallel diffracted rays produce phase and amplitude differences at the observer. The phase difference is caused by the difference in ray path length. The amplitude difference is caused by angular sensitivity of the diffraction coefficient. The net result is a loxer gain xhen the rays are added together for the total field. In the far field, the diffracted rays are parallel. These parallel rays are in phase and have amplitudes xith similar diffraction coefficients. 'The net result is a higher gain xhen the far field rays are added together. An overestimation in the calculation of the near field radiation levels can result xhen the far field gain is used. This overestimation occurs because the far field gain is higher than the near field gain ir. the boresight region. The diffracted rays from the main reflector are the major contributors to the far field pattern from boresight to the first few lobes. Beyond the first fex~lobes, the diffracted rays from the subreflector and direct rays from the source are the major contributors in both near and far fields. As the observer moves farther from the antenna, the sharply defined collimated beam in the near field rill begin to spread out as the main reflector diffracted N rays along the reflection boundary become stronger. To develop a radiation pattern requires the tracing of individual rays starting with the direct ray from the source and following the ray as it is reflected or diffracted from the antenna surfaces or edges until it reaches the observer. One ray path may be composed of only the direct ray from the source to the observer. Additional rays from the source to the observer will have more complex paths of direct, reflected, diffracted and all high order combinations of these. The ray path will be composed of multisegments where each segment is that part of the path from one surface to the next. For each segment, a divergent coefficient is computed to modify the amplitude and phase of the ray along the segment. The divergent coefficient value depends on whether the source of the segment path is a direct, reflected or diffracted ray. At the source of each segment, a reflection or diffraction coefficient is computed depending on the type of segment source. These coefficients modify the amplitude and phase of the ray from the previous segment and generate the source for the present segment. b'ot all combinations of direct, reflected, or diffracted rays can react, the observer. Some of these rays are blocked Dy parts of the antenna. Those rays that reach the observer are added together to form the total field at this location of the observer. Anew observer location is selected and the ray tracing process is repeated until sufficient field points are generated for the pattern. The Geometrical Theory of Diffraction technique is well suited for computer implementation. A powerful computer program has been developed at Hughes and is used in the solution of electromagnetic design problems. For the earth station antenna. the size and position of Lhe main reflector and the subreflector as well as the characteristics of the horn illumination must be M carefully selected for input to the computer program in order to simulate a particular antenna design. Amore descriptive approach of GTD is provided in Appendix A. San Bruno Mountain Earth Station Antennas The San Bruno Mountain earth station will have three antenna pads. A 11.3 meter dual reflector antenna with characteristics shown in Table 1 will be installed on each antenna pad. The San Bruno site will have the capability to communicate with synchronous satellites GALAXYI, GALAXY2, GALAXY3, and INTELSTAT. Although each antenna will be dedicated to a particular satellite, it is important that any of the three antennas can be ad3usted in azimuth and elevation to communicate with any of the four satellites. Table 2 gives the four satellite azimuth and elevation angles for the San Bruno mountain site. In addition, the table gives the angular margin the antenna collimated beam will clear the terrain in order to communicate with each satellite. Two worse case conditions were analyzed. In the first case, the Redwood city environmental document UP81-36 was addressed. This document identified a minimum elevation angle for the earth station antenna at 30 degrees. Since the 30 degree elevation angle was extremely conservative, a minimum angle of 10 degrees was selected on a flat terrain to demonstrate that there was no hazardous exposure to personnel moving on the flat terrain even at close distances. In the second case, the condition of an antenna not on a flat terrain was considered. Personnel moving along the hilly terrain such as at San Bruno could enter the collimated beam. To analyze this, a collimated Deam running parallel to a hill was selected. The first 60 meters of the collimated beam was analyzed since this is the limit of the San Bruno hill. The analysis demonstrated that there was no hazardous exposure to personnel within certain restrictions. The analyses used the transmitting frequency range of 5.925 to 6.425 GHz with an antenna radiated power of 3.2 kilowatts. For the first case of the earth station antenna, a 10 degree elevation TABLE 1. SPECIFICATIONS FOR 11.3 METER EARTH STATION ANTENNA Receive Transmit Frequency 3.7-4.2 GHz 5.925-6.425 GHz Gain (Nidband) 51.9 dBi 55.2 d8i YSidR 1.30 :1 1.30:1 Beamr~i dth -3 dB 0.42° 0.32° -15 d8 0.85° 0.65° First Sidelobe Level -15 dB -15 dB Radiation Pattern Neets FCC docket 81-704 for 2° satellite spacing. TABLE 2. SAN BRUNO ANTENNA PADS Angular Margin Satellite Terrain Angular Exceeds Blockage Pad ~ Satellites' Blockage (deg.) (deg.) 5 Galaxy t Clear Clear 2 20° 3.6° 3 11 ° 25.5° INTELSTAT Clear Clear 7 Galaxy 1 Clear Clear 2 18° 5.6° 3 18° 18.5° INTELSTAT Clear Clear 8 Galaxy 1 Clear Clear 2 t8° 5.6° 3 20° 16.5° INTELSTAT Clear Clear *Galaxy 1 AZ - 199.8°, EL - X14.3° 2 AZ - 118:5°~ EL - 23:6° 3 Az - 137°. EL - 36.5° I?;TELSTAT AZ - 252°. EL - 14° angle xas selected. The loxest edge of the main reflector xas 0.3 meter above the ground. A txo meter high linear trajectory xas taken parallel to the ground and in the direction of maximum radiation. The trajectory started five meters from the antenna and ran to 900 meters. Figure 2 shoxs the power density at the start of the trajectory xithin the collimated beam is 1.826 millixatts/cm2 and rapidly falls off as the tra3ectory leaves the collimated beam. Thus for distances greater than five meters from the antenna, the poxer density xas xell belox 1.826 millixatts/cm2 and there xas no hazardous exposure to personnel. For the second case of a collimated beam parallel to a hill, the region of radiation exposure can be much larger. The poxer density remains fairly constant xithin the beam from 6.6 meters out to 60 meters because the beam stays highly collimated. This high degree of collimation can be seen in the near field E- and H-plane pattern at 6.6 meters from the antenna, Figures 3 and 4. In both figures, the half angle for the collimated beam is 58 degrees. Beyond the collimated beam the field drops rapidly. In the near field E and H-plane pattern at 60 meters from the antenna, the high degree of collimation can also De seen, Figures 5 and 6. In both figures, the half angle for the collimated beam is 5.~ degrees. Beyond the collimated beam, the field drops rapidly. Note the 14 dBi gain at 6.6 meters increases to 32.5 dBi at 60 meters to compensate for the increase in distance and thus hold the poxer density fairly constant. The poxer density levels inside and outside the collimated beam xere computed starting at the antenna and out to 60 meters along tra3ectories parallel to the antenna boresight. Figure 7 shoxs the location of these tra3ectories xhich are plotted in Figures 8 through 13. Note that the poxer c7 N ('7 ..~ t9 r o~ x3 ..; -o u" Zz _f ~.~ Oa ~W _~ x~ ,. ~ .Y W 0 V .i - - 0 _o.. ~. _. e •o ~v -r ~ ~ ~ N L C9 ~ t.7 Gl 6! G +~ c d , eo L -' w e -- N H ; ~ w ~ A ~ 7 v d > 00 C a +1 rl 8 ~ -- W ~sa r7 N - - L CJ u ~ B O ~ .-~ - y u -~ G 47 L 0'I rl Q L _~ _ . _ 0 L U - ~--f ~ I r H N E U m L u 3 r-1 'rCl _ _ F N - - .-r ~ O r-~- -- - -- u'1 _ - _ C ., ~ ~ 1 ~ __ (SP) iar-od an~lBjag i H ~~ic 1 i N Z l z ~i V V h O Z v e e O ~ , l ~ I I I e e ~, l I I I 1 H f .- N E ' u a+ 8 ~ ~ ~ u .T 3 +~ .c B ~ eo ,-I a ~o ca rn I I d! I I .~ t I L ~' a m m .~ ~~ .~ rl I '~`~ 1 rl d ~ I ~ I I I K ~ ~.~ x ~ I ~ ~ ~a ~~E I ts, ,Z W t~ P: I I I e, e. I I I I I I I ' I I I I i I , I i I ! 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(HP) iae+od an~lETag _ -- C N M .-~ tD W Z U~ 2~ o~ Xo •. ~ =O u" z~ N ~W 0~ J O W V X~ oY yW i ~ ~-- (6P) a~ae1s~Q anl~Elag density levels within the collimated Deam have loxer oscillations than outside of the collimated beam. Table 3 shows the maximum power density levels on the trajectories over the first 60 meters of the collimated beam. The table shoxs a rapid drop in power density outside of the collimated beam. The power density inside of the collimated Deam is fairly constant along the beam out to 60 meters from the antenna. Except for regions near the center of the beam, the power density does not exceed 10 milliwatts/cm2. For the actual San Bruno earth station antenna. the collimated Deam will be at a higher elevation angle in order to more than 3ust clear the terrain. Thus the terrain radiation levels xill be lower. Conclusion The minimum elevation angle of 30 degrees required in the Redwood City environment document is unnecessarily restrictive. Loxer elevation angles can be used while e2sily limiting personnel exposure to less than 1C milliwatt/cm2. M elevation angle of 10 degrees. for example, will have off- collimated beam power densities less than 1.826 milliwatts/cm2 for distances from the antenna greater than five meters. For the first 60 meters of the collimated beam running close Lo the San Bruno hills, the power density level on the hill rill not increase significantly because the radiation level outside of the collimated beam falls off rapidly. Only by entering the beam by more than two meters will radiation levels exceed the 10 milliwatts/cm2 standard. TABLE 3. MAXIMUM P0~1ER DENSITY LEVELS INSIDE AND OUTSIDE OF THE NEAR FIELD COLLIMATED BEAM FOR A 60 METER DISTANCE Location of Trajectory Mi111Watts/em A. 1 meter outide of tube 0.072 B. 1/2 meter outside of tube 0.124 C. At edge of tube 1.59 D. 1 meter inside of tube 1.12 E. 2 meters inside of tube 2.83 F. 4.4 meters inside of tube 16.126 Power Densit~ INTRODUCTION TO THE GEOMETR 1 CAL THEORY OF DIFFRACTION by E. H. Villaseca INTRODUCTION TO THE GEOMETRICAL THEORY OF DIFFRACTION Successful electromagnetic poN•er density predictions of sophisti- ' sated antenna reflector systems have been achieved using Geometrical Theory of Diffraction (GTD). GTD is a high freouency ray optical solution to electromagnetic scattering. lYhen the radiating object is large in terms of a wavelength, the scattering and diffraction is found to be essentially a local phenomenon identifiable vrith specific parts of the object, e. o. , points of specular reflection, shadow boundaries, and edges. In order to obtain the radiation pattern of an arbitrary reflector antenna system, it is necessary to supplement the traditional Geometrical Optics (GO) contributions with the diffracted contributions provided by the Geometrical Theory of. Diffraction. In general, the total radiated field E is given by the sum of the incident, direct or primary field from the radiator E~, the reflected fields from the body Er and the diffracted fields Ed which originate from edges, vertices, and various other structural discontinuities. Then, E =E~+Er+Ed. Using the geometrical optics approach, the main components of the incident field (E~) can be described in terms of an astigmatic bundle of rays as shown in Figure 3-I. One may write an expression for the fields at ~ in terms of 3- 2 d ~o Cl~USTICS 1 2 _ _---- PZ ~P d~ FIGURE 3-1. -- ASTIGMATIC BUNDLE OF RAYS 3- 3 the fields at a reference point 0 as follows: EB' (s') E8, (0) E~ (s') E~, (0) Where: e lk~ (0) (s')e jks' (I) • B' and ~' are the parallel and perpendicular co:nponerts in the ray-fixed coordinate system. • s' is the distance along the ray path • Ai(s') is the divergence coefficient along the ray path. It pit and p~Z are the principle radii of curvature of the wavefront at the reference point, the divergence coefficient is: i i Ai(s') = plp2 (p~ ~ + s')(P ~ + s') • k i s the free space Meve nuttier. 1 n the sartE warner (tssi ng the geomt:t ri cal optics approach) the com- ponent s of the field reflected by the ctrved metallic strface of F care 3-2 are gi ven by: 3- 4 F FIGURE 3-2 __ _ _ __. _ - _ _ REFLECTION -FROM A DOUBLY CURVED METALLIC_SURFACE _._..______. 3-3 EB, (s) 1 0 EBB, EQ, (s) 0 - 7 EQ, A (s)e 1 ~ (~) Yhere: • s i s the di stance along the reflected ray from the structure. • Eg' and E~, arethe incident fields at the soecui ar poi nt gi ven i n the tno pri nci pl a ort tngDnal cortporerris i n the reflected ray- f i xed coordi nat a system I 0 • The rtet ri x ~ i s the ex{xesssi on for 0 -I the ref 1 ect i on coef f i ci ent . • ~(s) i s the di vergence coeffi ci errt of ong the reflected ray and i s gi ven by: r r A (s) = p1 p2 (pl r +s) (pZr + s) and p~ r, pZr are the rad i of curvature of the refJ ect ed vievef ront . The diffracted fi el d eonsi sts of diffracted rays originating at the edges of a given structure as illustrated in Figure 3-3. ~ ~1~\S~ I S~ SOURCE POINT 510E VIEW FIGURE 3-3 -- DIFFRACTION FROA1 A WEDGE 3-6 _ D~FFRAC7IGN FO1NT ` Z S A A D ~o n DIFFRACTED RAYS x~ ~2-n)r Y 3- 7 According to the theory postulated by Keller the diffracted field of the wedge of Figure 3-3 is given by: Ed (s) -Ds 0 E~ B' 13 ,~ Ad(s)e jks (3) EO (s) 0 -Oh E~ !~ Where • s is the distance from the observation point to the diffraction point . • EB and Ee are the principle orthogonal diffracted components in the diffracted ray-fixed coordinate system. • E~B~ and Ei~, are the principle oKhogonai components of the incident field in the incident ray-fixed coordinate system. • Ds and Dh are the scalar diffraction coefficients for the parallel and perpendicular field components incident on the wedge. •• .. 3-S • Ad(s) is the divergence coefficient along the diffracted ray and is given by: Adis) = P s(p+s) where p is the distance between the caustic at the edge and the second caustic of the diffracted ray and can be written as n ^ n p p i R sin~Bo e where peg is the radius of curvature of the incident wavefront n at the diffraction point, n is the associated unit normal vector to the edge, R, is the radius of curvature of the edge, and Bo is the angle between the incident ray and the tangent to the edge as shown in Figure 3-3. The terms DS and Dh were first evaluated by Keller who proceeded to describe the diffracted field in terms of rays with the diffraction co- efficie~ts performing much the same function as the rEflection ,coefficients in the reflected field problem. A1any improved wedge diffraction solutions have evolved since Kelley's fundamental work such as the solutions .de- veloped by Kouyoumjian and Pathsk2 which more accurately describe the fields near the transition regions (regions where the traditional geometric optics contributions disappear). •, .,. 3- 9 Figure 3-4 shox•s the significant ray traces that reach the observer from various parts of a typical dual reflector antenna configuration Case #1 is the direct or incident ray from the feed horn directly to the observer. Case ~2 is a reflected ray from the main reflector to the observer. To be radiated by this ray trace, the observer must be located in the collimated region of the beam. Case #3 consists of diffracted ray traces from the main reflector. Case ~~ consists of the primary diffracted rays from the sub- reflector. ltese rays originate from thestrong fields at the center of the feed horn and thus have a significant effect on the power density at the observer. Case ~5 consists of the secondary diffraction rays from the sub- reflector. At each Location of the observer, a summation is made of •the power density contributions from each ray trace. At some locations of the observer, some ray traces are blocked by -the geometry of the antenna or other scattering bodies. In addition to the antenna, other scattering bodies contribute to the power density at the observer. Each ray trace given in Figure 3-4 may first hit a scattering body and then be reflected or diffracted to the observer. As the number of scattering bodies increases, so do the number of possible rays reaching an observer. In this particular problem, the computer program uses the geometry of the dual reflector antenna and the top of the metal fence which surrounds the ground site. See Figure 3-S which shows all the significant ray traces from the dual reflector and a fence. .. , ,, 3-10 i - -•--o P ~ i w~ ~' ~ ' 1. pi.~ct rsv lrvm !Md hor++ 3. Ral1~c~~d rsy !-v oaln raflettor F • I! ~ ~ ~1 ~ ~ ~i ~ `~ ~~~_~~~~f ~ ~ t ! ~, ,, 3, pilfracta0 nys tnan ~. Prlaury dlftrsctad rsy~ amain nflactor frs~ rethttor - rQ r' t~ ~/ 1 i~I ~ ~. ~ ~ r ~ ~ -----_--------- -- -- - ------ f. secondary dlftroctod rays Irv aubr+ilacvr ilpYrf ~3. pual I~atl~eier AMarrvs flawlnp i1~nltlcaM Ray Trscw ~o Obawwr .. 3-11 y~ If Irr /f '~ ~ / t~ / 1~ /~ / ~ 1 / !~ / / 11 ~ ~ I ~ / ! ~ I i / ~ ~ / I ' ' ' ~ I ~ i ~ ~~ ~ 1 ' r ' 1 I d . 1 I I ~~~ 11 ~ ~ ! 11 '' 1 1' /~ ~ I i t I~ ~ I ~ i ' , ~ ~ ~ i 1 / r / ~, 1 1 ,r ~ / ~ / ~~ 1 ~ ~ ~ i / i 1 1 / / ~~ 1 / ~/~ y ~ ~ ~ /~ ` 1 1 i / " , ~ 1 / / ~~1~ ~ ~~~~ ~ 1 // ~~:•_ 3 c° c 0 u V ~ N • Y Q C ~ • a " ~ u c u 0 • • . ~ •j 3-1Z The flow diagram shown in Figure 3-6 is the simplified computer program used to calculate po~•er density by the Geometrical Theory of Diffraction (GTD) approach. The parameters that need to be established are the cor- rua_ated feed horn, the physical dimensions of the dual reflector antenna, the pointing angle of the antenna, the height and location of scattering bodies (the fence in this problem), and the trajectories along vehieh the power density calculations are to be made. For each pass through the trajectory program loop, the path to the observer of a particular ray trace is calculated. The direct or incident ray and the most significant reflection/diffraction ray traces to the observer are considered. Each ray trace is checked against the geometry of the antenna and other scattering bodies (the fence in this problem) to determine if the trace is blocked. I f the trace is not blocked, the power density at the observer is calculated. After all the significant ray traces at one point on the trajectory have been examined, a summation is made of the power density contributions fran ~s then taken and the process each ray trace. Anew point on the trajectory repeated until all the trajectory is covered. A plot of the power density along the trajectory is then printed. Earlier versions of this GTD computer program have been applied to several Electromagnetic problems in the past five years. Initially the program was successfully employed to determine the complete radiation pattern (5) (3~ ~ 4) and hourglass reflector antennas. parabolic reflector antennas ram was also utilized in the study of the near field and far field monostatic - The grog __.- _ _ _ _ _ - -{5) ~7) -The Program was further radar cross sections of complex targets. •~ .l (.START ~ ESTA6LISM PARA-![7ERS t) RADIATIOw SOURC[ TYPL 7) LOCATION AND GEOyCTRY OF SCATTERtNL EJOI[S 11 TRAJECTORY PATH ENTER TRAJECTORY LOOT: 1) ALLOM OBSERVER TO MOVE ALONG TRAJECTORY ~) DETERMINE All RAYS FROw SOURCE TO 08SERVER ALCULATE TRACE Oi INCIDFwT RAY FROV SOURCE TO OGS[RYER e J ~J CALCULATE TRACE OF A RAY DOES rtMOSE -ATN MAS SIN;,LE OR T1EE GEOMETR ,,ES ULTIPLi REFLECTIDNS AKDIOR ~ tDLOCK TMtS StwGLE Oa M:JITIPLE ~ RAPE DIFFRACTIONS FROV SOURCE T OB ER NO CALCULATE POI-'ER ~ } DENSITY PAODUCFO eY TMIS RAY AT pBSERVER -'NAVE BALL THE ' PRINCIPAL M\ 0 RAY TRACES r RETURN eEEk ..USEDT YES SUV THE FI[LDS AT THE OBSERVER P A ODU[ED er / ~ ` INCIOEI:IiFII AC71nw aAFVS CTION/ MOVE THE OBSETTRVER TO ANOT TRAIECTOR~w THE AAJECTORY Np FINISHEDI YES -LOT *OM'ER DENSITY VERSUS ptSTANC[ ALONG TRAJECTORY CE«D-l Figure 3-6. Computer Program for Satellite Earth Terminal Power Density Calculations, Flow Diagram. ~~ . ~, y 3- 1 v modified to determine the performance of adaptive arrays mounted on air- crafts. (8) (9) Research vrork at !-IAC has continued to develop the potential of this G7D program and has resulted in the capability to perform complete evalu- ations of complicated dual reflector antenna systems in comalex environments. c ~ . • ~• ~i REFERENCES (. J. B. Keiler, "The Geometric Optics Theory of Diffraction", Proceedings of the Symposium on Alicrov-•ave Optics, Part 11, A1cGilt University (1953). Astia Document AD-211500, pa. 207-210. 2. R. G. Kouyoumjian and P. H. Pathak, Proceedings of IEEE 62, pp. 1448-1461, November 1974. 3. E. Villaseca, D. Lomaalio and H. Delia, "The Geometrical Theory of Diffraction in the Analysis of ReTlector Antennas", Alta Frequenza, July 1976, pp. 427-420. 4. E. Villaseca, E. K'. Smith and R. L. Moye, "On the Applicaton of GTD for Complete. Parabola Radiation Patterns", Antennas and Proaa- gation International Symposium, Stanford University, June 1977, pp. 37-40. 5. E. Villaseca, "Antenna Pattern Predictions of Hourglass Antenna Using GTD", Antennas and Propagation international Symposium, University of A'aryland, May 1978, pp. 98-101. 6. E. Villaseca, D. Lomoglio, "The A~odern Geometrical Theory of Dif- fraction for the Radar Q'oss Section Prediction of a Complex Target", Alta Frequenza, July 1976, pp. 418-426. 7. E:. Villaseca, "Application of the Geometrical Theory of Diffraction to the Determination_ot Near-Field Radar Goss Sections of Complex Targets",EIGHTH ARPA/TRI SERVICE MILLIMETER WAVE CONFERENCE, Eglin Air Force Base, Florida, April 3-S, 1979. ~~~ '~; K • 8. E. Villaseca, "Computer Alodelling of Adaptive Arrays Using Geometrical Theory of Diffraction", Antennas and Propagation International Sym- posium, University of A;aryland, May IS-19, 1978. 9. E. Villaseca, "The Applicaton ofthe Geometrical Theory of Diffraction to the Performance Assessment of Alounted Adaptive Arrays", IEEE 1979 National Aerospace S Electronic Conference, A1ay 1979, op. 55-65. ,. . HUGHES COMIIZUNICATIONS SATELLITE SERVICES, INC. POST OFFICE BOX 92424 WORLDWAY POSTAL CENTER LOS ANGELES, CALIFORNIA 90009 (213) 607-4000 September 13, 1984 J. Michael Lofthouse, Architect JML Ltd. 1333 Willow Pass Road 201 Concord CA 94520 Dear Jay: For your information, I am enclosing a copy of the radiation hazard study for San Bruno, prepared by Ed Villaseca. I hope this will be useful in your dealings with the county. Very truly yours, R. L. Scraffo d RLS:dw TELECOMMUNICATIONS PROPERTIES SAN BRUNO MOUNTAIN TELECOMMUNICATIONS SITE SAN FRANCISCO, CALIFORNIA SURVEY OF RADIO-FREQUENCY ELECTROMAGNETIC FIELDS June 23, 1988 Hammett do Edison, Inc. Coosultiag Engineers Sao Francisco SAN BRUNO MOUNTAIN TELECOMMUNICATIONS SITE SAN FRANCISCO, CALIFORNIA STATEMENT OF WILLIAM F. HAMMETT, CONSULTING ENGINEER The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained by Telecommunications Properties, manager of the telecommunications site on San Bruno Mountain, California, to determine the levels of electromagnetic radiation throughout the site in regard to effecting compliance with the appropriate guidelines for limiting human exposure to such fields. ELECTROMAGNETIC FIELD EXPOSURE STANDARDS In General Docket 79-144, the FCC adopted the radio frequency protection guide of the American National Standards Institute Standard C95.1-1982, "American National Standard Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 300 kHz to 100 GHz" ("ANSI"). The effective date for applying the ANSI limits to broadcast stations was January 1, 1986. A summary of the limits of the ANSI Standard is shown in Figure 1. The most restrictive power density level for unlimited time exposure is 1 mW/cm2 at frequencies between 30 and 300 MHz, where FM and VHF television stations operate; the limit is higher at frequencies above and below this band of frequencies, as shown. The radio frequency protection guide of ANSI is based upon time averaging over a six-minute period. Thus, exposures to fields above the limit are permissible, if the exposure time is restricted to a proportionally shorter period. For example, exposure to fields three times the ANSI limit is permissible for two minutes, provided the remaining four-minute period does not include any exposure. The FCC has provided direction to the broadcast industry on determining compliance with the ANSI Standard in the Office of Science and Technology Bulletin No. 65, "Evaluating Compliance With FCC-Specified Guidelines for Human Exposure to Radiofrequency Radiation" ("OST-65"), and in the Public Notice dated January 28, 1986, "Further Guidance for Broadcasters Regarding Radiofrequency Radiation and the Environment" ("Notice"). Restrictions on access to strong fields may be achieved in different manners for public exposure and for occupational exposure. Persons who are authorized to be at a broadcast site can be educated to follow procedures that will limit time-averaged exposures to levels within the ANSI guidelines. SAN BRUNO MOUNTAIN TRANSMITTING FACILITIES San Bruno Mountain was, until the construction of the Sutro Tower in 1973, the preferred transmitting location for most of the television and FM stations in the central San Francisco Bay 880531 Hammett & Edison, Inc. Consulting Engineers PAGE 1 SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA Area. Today, four UHF television stations and ten FM stations maintain their transmitting facilities there, in addition to an increasing number of land mobile and common carrier operations. Ten major towers stand along the ridge of the site, extending about one-half mile, and there aze seven major buildings housing the transmitting equipment of the various site users. This area, shown in the map attached as Figure 2, is accessible to the public by caz via Radio Road through the San Bruno County Regional Park entrance, which is open only during daylight hours, and by foot at all hours. Figure 3 attached lists the stations, their relative locations, and some of the engineering specifications of their operation. The satellite dishes on the west slope of the Mountain are separately fenced to prevent public access; those areas aze not included in this study. COMPUTER STUDY Hammett & Edison has developed a computerized technique for applying the formulas given in OST-65 to calculate ground level power densities at multi-user broadcast sites. Numerous site elevations are provided to an intermediate program which interpolates to find the approximate site elevation at each point on an azbitrary rectangulaz grid. At each grid-point, the main program then calculates the fraction of the appropriate ANSI guideline contributed by each broadcast source at the site and sums the individual fractions to determine the total predicted power density at that location. By repeating this procedure at each grid-point, the computer can then print out a map showing by symbol the predicted ambient power densities at the site. Use of this technique at numerous other multi-user sites has shown it to give generally conservative predictions of ambient fields, as subsequently measured by field survey. Figure 4 attached is the printout for operation under normal conditions, overlaid onto the map from Figure 2, and it shows that the entire site has calculated fields below the ANSI guideline. The majority of the site calculates to less than one half of ANSI, and these areas did not need to be exhaustively surveyed. In an arc about Tower 1, the fields aze calculated to be greater than one half of ANSI, and this azea was most carefully surveyed for the existence of ambient fields that might exceed ANSI. Similaz studies have been made of the operation under auxiliary conditions for those stations which have auxiliary transmitting antennas. Even under simultaneous worst-case operating conditions, appreciable change in the level of calculated power density is observed in only two azeas: ~ at the base of Tower 8, due to the auxiliary operation of FM Station KYUU, and at the base of " Tower 5, due to the auxiliary operation of FM Station KITS. These two areas were carefully surveyed under auxiliary operations for the existence of ambient fields that might exceed ANSI. Hammett & Edison, Inc. PAGE 2 880531 Consulting Engineers SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA MEASUREMENT EQUIPMENT Equipment used to measure the electromagnetic fields was a Holaday Industries, Model HI- 3001 Broadband Exposure Meter, Seria] No. 39202, with the GRE-O1 electric field probe, Serial No. 210A, and the CH-O1 magnetic field probe, Serial No. 088. This combination detects electromagnetic radiation in the frequency range from 0.5 MHz to 6 GHz and indicates in units of V2/m2 or A2/m2, depending on the probe used. The instrument and probes were calibrated by the manufacturer on January 6, 1987, and May 10, 1988. The probes for this instrument are isotropic, meaning that they can directly measure the intensity of complicated fields independently of orientation of the probe or polarization of the fields. The data supplied by Holaday sets forth the frequency response of the probes as tl dB and accuracy and isotropicity as t0.5 dB. Also used was a Narda Microwave Corporation Model 8616 broadband meter, Serial No. 21061, with Model 8621C electric field probe, Serial No. 22130, calibrated by the manufacturer in September 1986. Data supplied by Narda sets forth the frequency response of this • combination to be within -3 to +1.25 dB over the range from 300 MHz to 40 GHz, the calibration .s: to be accurate within t0.5 dB, and the isotropicity to be within ±1.0 dB. MEASUREMENT PROCEDURES Field measurements at the site, including the separately-reported measurements taken within several of the transmitter buildings, were taken on four different dates between the times noted: Friday, April 29, 1 to S pm; Sunday, May 1, 6 am to 3 pm; Wednesday, May 4, 1 to 4 pm; and Thursday, June 9, noon to 4 pm. All broadcast sources impacting the areas measured were confirmed to have been in operation at that time, and all other radiofrequency radiation sources are believed to have been operating normally. I was assisted for all of these measurements by Mr. Frederick Spaulding of Hammett & Edison. The site was examined with the Holaday meter using the electric-field probe in order to determine if there were ambient fields in excess of ANSI and in order to identify any localized fields ("hotspots") that exceeded ANSI. While such hotspots are typically highly localized, i.e. the field is limited to a small region within a few inches of a re-radiating metallic object, and while they might qualify for exclusion from ANSI due to the low likelihood that they could produce whole-body specific absorption rates exceeding the limits, ANSI specifically cautions that "In no case could a routine field survey determine conformance with the criteria of this part of the exclusion." Thus it is our policy to identify and record all fields found to be in excess of the ANSI guideline. 880531 Hammett dt Edison, Inc. Consulting Engineers PAGE 3 SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA Areas in relatively close proximity to radiating elements or reradiating objects were also examined with the Holaday meter using the magnetic-field probe in order to determine if the induced magnetic field might be causing either ambient fields in excess of ANSI or hotspots of larger extent than were measured with the electric probe. Accessible areas near microwave antennas or near to the beam of these antennas were also examined with the Narda meter to determine if radiofrequency fields beyond the frequency range of the Holaday meter were causing ambient fields or hotspots in excess of ANSI. No measurements were taken which would have required climbing of a tower. Measurements were made on all the roofs of buildings which had unrestricted access; these results are also reported separately in the reports for the buildings involved. MEASUREMENT RESULTS No ambient fields in excess of the ANSI guidelines were found at the site under normal operating conditions. Representative ambient measurements are shown on Figure 5 attached. A number of hotspots were observed under normal operating conditions, and these are addressed specifically in the recommendations section below. The most critical of these reradiating sources is the metal gate across the roadway to Building A, which has fields in excess of ANSI extending as far as eight inches and is likely to produce frequent human contact. With KYUU operating on its auxiliary antenna, the area around the base of self-supporting Tower 8 was found to exceed ANSI to a distance of up to five feet from the tower piers, and sizeable hotspots were observed on the nearby ENG structure used by TV Station KPIX. Figure 6A attached shows more accurately the extent of the ambient field. With KITS operating on its auxiliary antenna, the ANSI guideline was found to be exceeded in an area about 14 feet by 26 feet located southeast of self-supporting Tower 5. Figure 6B attached shows more accurately the location of this field in relation to the tower. ON•TOWER EXPOSURES The ANSI Standard applies to all areas of the site which are accessible both to members of the public and to workers at the site. Towers 1, 2, 3, 5, 6, 7, and 8 have no access restrictions at their bases, and all but Tower 6 have climbing ladders or pegs reaching to ground level, which means that, on these towers, both public exposure and occupational exposure are at issue. Hammett & Edison has developed a computerized technique for applying the formulas given in OST-65 to calculate the total exposure levels on the towers at a multi-user site. The power level of each source can be adjusted individually, so that the total calculated exposure level for a particular height on a Hammett & Edison, Inc. PAGE 4 880531 Consulting Engineers SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA tower can be brought to a level below ANSI by selectively reducing the power of certain stations. While the technique uses the 1.6 field reflection factor recommended by OST-65, field surveys have found that reradiation from non-energized antennas can be significant and the calculated fields may be understated for this reason. It is good practice to short the elements of an individual antenna bay of anon-energized antenna to the tower or to the antenna interconnecting feedline if work is to be done near that bay. Reduced power operations by the San Bruno broadcast stations necessary to maintain the calculated power density levels below ANSI have been determined for each antenna and tower on the mountain. Figure 7 attached displays these results as a function of each main and auxiliary antenna or, in the case of Towers 6 and 7 which have no active broadcast antennas, as a function of certain heights on the tower. The tower space occupied by each antenna is shown on each row of the chart. Shown first are the heights above ground below which the calculated fields are less than ANSI for normal conditions and for worst-case conditions including certain auxiliary antennas. Next are shown the calculated operating power percentages for which the total calculated power density from the fourteen broadcast stations is below ANSI at the given tower space. Each station would thus ~ read across to determine what power cutbacks by various stations are specified for access to its own antenna(s), and it would read down to find out what recommended power cutbacks are specified when antenna spaces are being accessed on other towers. Since persons on the towers at most of the antennas would almost certainly be exposed to fields in excess of ANSI if power cutbacks were not accomplished, the various licensees will need to adopt a cooperative program of adherence to such cutbacks. The specific power levels shown are not the only combination of reductions that would bring the calculated fields at the specific location below ANSI, but they are what I believe would disrupt the least number of stations and be the most easily implemented. Should an individual station relocate or otherwise alter its operation, the calculated power cutback requirements would be subject to revision. RECOMMENDATIONS The FCC has provided guidelines to assist broadcasters in achieving compliance with ANSI , and this guidance forms the basis for the recommendations below of specific steps to bring the San Bruno Mountain transmitting site into ANSI compliance. In its Notice, the FCC specifically noted ~~ The circumstances [at a particular site] may require corrective action to reduce exposure or the application [for new or modified facilities or for license rencwalJ may -~ be denied. Legal releases signed by workers willing to accept high exposure levels 880531 Hammes & Edison, Inc. Consulting Engineers PAGE 5 SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA are not acceptable and may not be used in lieu of corrective measures. The foregoing also applies to high RF levels created in whole or in part by reradiation.... Fencing and warning signs may be sufficient in many cases to protect the general public. Unusual circumstances, the presence of multiple sources of radiation, and operational needs will require more elaborate measures. Intermittent reductions in power, increased antenna heights, modified antenna radiation patterns, site changes or some combination of these may be necessary, depending on the particular situation. Accordingly, I recommend that the following actions be taken: 1. Remove the gate (and two associated posts) across the roadway to Building A. [Alternatively, add 8-inch wooden spacers to the gate and post warning signs.] 2. Post signs on the gate across the roadway south of Building B leading to the satellite antenna site. 3. Fence the base of Tower 8 and the Channel s ENG facilities. [Alternatively, remove the bottom six bays of the KYUU auxiliary antenna and reroute its transmission line.] 4. Fence the base of Tower 2. 5. Fence the base of Tower 5, including the previously noted area to the south. 6. Add 6-inch wooden spacers to the fourth cable rack support post south of Tower 2, add 2-inch wooden spacers to the fifth post, and post warning signs on each. 7. Remove the scrap coaxial cable on the ground about 75 feet to the south of Tower 2. 8. Shield the ground cable on the north face of Building B with a dielectric material at least one inch thick. 9. Post warning signs at both gates in the fence around the base of Tower 4. 10. Shield the ground-level run of the KYUU transmission lines with a dielectric material extending at least two inches from the metal. 11. Post a warning sign on the microwave dish at the northeast comer of Building A. 12. Replace the two power pole guy wires located to the west of Building A with dielectric material. [Alternatively, shield both guys with a dielectric material extending at least two inches.] 13. Adopt a formal power cutback agreement between tenants with implementation of auxiliary operation notification procedures. 14. Prevent or restrict public access to Towers 1, 3, and 7. Note that any new fences should be constructed of dielectric material to avoid the creation of new hotspots. Note also that standard RF warning signs are available through the National Association of Broadcasters. Hammett & Edison, Inc. PAGE 6 880531 Consulting Engineers SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA CONCLUSION Based on the studies and measurements described above, I conclude that if the recommendations listed above are implemented, publicly-accessible areas of the San Bruno Mountain transmitting site will comply by calculation and measurement with the ANSI Standard C95.1-1982. No conclusion can be made for those buildings at the site which were not measured. Recommendations to achieve ANSI compliance at the buildings which were measured are reported separately. For occupational exposure within the several fenced compounds, I conclude that if the recommendations listed above and in the separate building reports are implemented, those areas of the site will also comply by measurement with ANSI. For occupational exposure on the transmitting towers, I conclude that, if the recommendations listed above aze implemented, if each tenant properly educates its employees and contractors as to the significance of ANSI and of the various compliance measures adopted, and if such measures aze followed, those azeas will comply by calculation with ANSI. The above conclusions are applicable only to the transmitting facilities in operation as of June 9, 1988; any subsequent material change in transmitting facilities may invalidate these conclusions. LIST OF FIGURES In canying out these engineering studies, the following attached figures were prepared by me or under my direct supervision: 1. Summary of ANSI Standard 2. Map showing relative location of towers and buildings 3. Tabulation of engineering specifications of broadcasting operations 4. Map showing calculated ground level fields 5. Map showing representative measured ambient fields 6. Maps showing ambient areas exceeding ANSI under auxiliary operations 7. Tabulation of reduced power calculations. HAMMETT & EDISON, INC. Consulting Engineers June 23, 1988 880531 illiam F. Hamm tt, P.E. Hammett & Edison, Inc. Consulting Engineers PAGE 7 AFFIDAVIT State of California ) ss: County of San Mateo ) William F. Hammett, being first duly swornn upon oath, deposes and says: 1. That he is a qualified Registered Professior_al Engineer, holds California Registration No. M-020676 which expires June 30, 1989, and is a principal in the firm of Hammett & Edison, Inc., Consulting Engineers, with offices located near the city of San Francisco, California, 2. That he graduated from Dartmouth College with a degree in Engineering Sciences in 1977 and from the University of Illinois with a degree of Master of Science in Mechanical Engineering in 1978, has completed two years of employment by the Standard Oil Company and five years of employment by Dean Witter Reynolds in various engineering, computer, and management capacities, and has been associated with the firm of Hammett & Edison, Inc., in the practice of consulting engineering since 1985, 3. That the firm of Hammett & Edison, Inc., Consulting Engineers, has been retained by Telecommunications Properties, manager of the telecommunications site on San Bruno Mountain, California, to determine the levels of electromagnetic radiation throughout the site in regard to effecting compliance with the appropriate guidelines for limiting human exposure to such fields, 4. That such engineering work has been carried out by him or under his direction and that the results thereof are attached hereto and form a part of this affidavit, and 5. That the foregoing statement and the report regarding the aforementioned engineering work are true and correct of his own knowledge except such statements made therein on information and belief, and as to such statements, he believes them to be true. (~ ~ - William F. ammett, .E. Subscribed and sworn to before me this 23rd day of June, 1988 OFFICIAL SEAL ~\ __. ___.!.. __ _ _ `"" ~ , ERNEST B. MONTANER NOTARY PUBLIC • CALIFORNIA ~ i SAN MATEO COUNTY ' My Comm. E:p~re~ June 3. 1991 ~ '. ~ V AMERICAN NATIONAL STANDARD SAFETY LEVELS WITH RESPECT TO HUMAN EXPOSURE TO RADIO FREQUENCY ELECTROMAGNETIC FIELDS, 300 KHZ TO 100 GHZ RADIO FREQUENCY PROTECTION GUIDES Frequency Ran e Electric Field Magnetic Field Equivalent Far-field g oared v Squared Power Density (MHZ) ( 2/m2) (A2/m2) (mW/cm2) i a 0.3 - 3 400,000 2.5 100 3 - 30 4,000 x (900/f2) 0.025 x (900/f2) 900/f~ 30 - 300 4,000 0.025 1 0 300 - 1,500 4,000 x (f/300) 0.025 x (f/300) . f/300 1,500 - 100,000 20,000 0.125 S.0 Note: f =frequency (NII~iz). 10~ N~ 3 lo~ e 10 z w A ~~ 0.1 ~. ~ HAMMETT & EDISON, INC. SAN BRUNO MOUNTAIN CONSULTING ENGINEERS SAN FRANCISCO TELECOMMUNICATIONS Sl I SUMMARY OF ANSI C95.1-1982 STANDARD 880531 FIGURE 1 I 1 i lU 10` 10' 104 105 FREQUENCY (MI~iz) y r.~ f ..1 F ~ ~ z 0 ~ F O ~ z 1„ ~ z ~ ! m ~ Z E. ~, y ~ 6. !! G l~~W ~ C_ H ~ GO V 00 p ® C ..n o F ~~ o~ d 0 F 1, U 1~ 11 /1 I/ 11 l~ 11 ~ ~ ~~ a F O D ~O A ~ Q` .; ,.~-~~ ~_ e 9 E- 0 0 N h f~ O h N N 0 r N O Ci 'O .? .:__; ;. g~~ ®.1 ~i ii N ~~ Q ~ ~ ~ 1~ e ~® 1 o ~ ~~ ~° E. ~ ~~ 1` O ` ~0 ~ .ono ®., ~ ~ 0 F N 1~w W 5 (,j m C 7 ~. ~ w~ ~ a •~ e ~' ~ R ~U ~C O O .~ .` 1Cr7 _ W MM H o~p eN J OD C ~ 'O 1. SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA SUMMARY OF BROADCAST TRANSMITTING FACILITIES t Effective Antenna Antenna COR STATION hannel ~l in Radiated Power Make & Model Tower Height, AMSL KDTV(TV) 14 G MAIN: 2570.0 kW Andrew 63534 10 443 m KTSF('TV) 26 F MAIN: 2510.0 RCA TFU-30JDAS 9 461 KWBB(TV) 38 F MAIN: 2570.0 RCA TFU-30JDAS 8 449 KCSM-TV 60 G MAIN: 1550.0 Andrew 63506 10 432 KQED-FM 203 B MAIN: 110.0 ERI FMH-6AC6 2 433 KYA(FM) 227 A MAIN: 7.5 Jampro JHCP-1 2 417 KSAN-FM 235 B MAIN: 30.0 Jampro JSCP-4 3 425 AUX: 23.0 ERI GSCPS-3AE 3 413 KKHI-FM 239 A MAIN: 6.9 Collins GSCPS-A1 2 451 AUX: 2.6 Collins 37CP-2 2 405 KYUU(FM) 259 F MAIN: 45.0 ERI FMH-4AC 8 436 AUX: 45.0 RCA BFC-10 8 417 KIOI(FM) 267 A MAIN: 61.0 Jampro JSD-2P/3 1 419 AUX: 61.0 Jampro JSCP-6 1 405 KBLX-FM 275 C MAIN: 6.6 Collins GSCPM-2E 4 451 KI'fS(FM) 287 C MAIN: 15.0 Jampro JSCP-4 5 425 AiJX: 1 S.0 Jampro JSCP-4 5 387 KMEL(FM) 291 A MAIN: 69.0 Jampro JSCP-7 1 440 AUX: 20.0 Jampro JHCP-1 1 426 KSOL(FM) 299 C MAIN: 8.9 ERI GSCPS-4 S 412 AUX: 4.0 ERI GSCPM-2 4 447 880531 Hammett & Edison, Inc. Consulting Engineers FIGURE 3A SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA SUMMARY OF BROADCAST TRANSMITTING FACILITIES TOWER Base Elevation 1 372 m, AMSL 2 371 3 4 373 369 5 6 7 8 9 10 ~~'t A B C D E F G 373 373 375 401 390 381 Site Elevation 371 m, AMSL 369 369 373 375 381 378 Antenn s KMEL(FM) main & auxiliary KIOI-FM main & auxiliary KKHI-FM main & auxiliary KQED-FM main KYA(FM) main KSAN-FM main & auxiliary KBLX-FM main KSOL(FM) auxiliary KSOL(FM) main KITS(FM) main & auxiliary Cellular radio Land mobile KWBB(I'V) KYW(FM) main & auxiliary KTSF(-TV) KDTV('I'V) KCSM-TV Tenants KMEL(FNt), KIOI-FM KQED-FM, KSAN-FM KBLX-FM, KSOL(FM), KITS(FM) Cellular radio Land mobile KTSF('TV), KWBB(TV), KYUU(FM) KDTV(TV), KCSM-TV Hammett & Edison, Inc. 880531 Consulting Engineers FIGURE 3B • a .•' `!~• ~ ~:::o•:. ... .. a ... • . oa .. .. o y A .d - - ~ v In .~ . N a+ .`"c v ° o a. ~ ~ ~ o ~' ~ ~_~ • =- z z a aN -- W ,,, as e w Z F °ca~ c ~ ~y •r~' .., woo In Z ~ ~ ., o ! ! M 4 O H O +H Ill Y- W vii ~ ~ b C C E., • ~, t, W .~ r . N O O h ~ A V ITV ~ ~ O W p ..7 ~ ! h7 4~ 9 h 9 h m ~ . • . • N Qp~~ • pl tl 7 'O M my ~ • . •~ '% ~~. • ;,. .. ,,, . ;~ ..• . ; ~ ~ ; • ~ - ~. ,.,-__ ,, • ®t.... • ,~• • • ~-~. a~• • :~~'. • . ~~ . • , ~ . .. ~. }, .., . ~~. • • '~ ~'iF :• ®• • , 8 0 ®~ Q ~ pN ~ S ~ O R1 [~[~. S O I.rl e' N y W ~ r. A o a I r 3 S e o 0 F ~' r ~ z .. .. o $ ~ m o z a=c ~ o n ~ z ~ `~ N H ~ O C „ N aq y r ' e Y N O F e' .e N c 0 F O N a. e m a 0 0 ~ ~. e o ~ ~~ e II ~ ~ ~.. e~f ~ ~ ~ / o N/ e ., ~ ~ ~~ o ,,® ~~,~ ~ ,~ _:e ~ ~ I; ~® „ ,~ - I j I. ~ ~ .I ~1 1 i i®~'~ ~e i ~'~ `. '~ $ 0 ,e ~ ~~ N ~ g a ~~ '~o_o e a T N~ N E H .5 u oC ~~ ~ ~~ U ~~ SAN BRUNO MOUNTAIN EXTENT OF TOWER 8 AMBIENT ELECTROMAGNETIC FIELD IN EXCESS OF ANSI C95.1-1982 UNDER SPECIAL OPERATING CONDITIONS KYUU Auxiliary Antenna Tower 8 '~~~~:::::5 ft:::::~:~:~: y Measurements taken May 1, 1988, with FM Station KYUU operating on its auxiliary antenna. Hammett & Edison, Inc. 880531 Consulting Engineers FIGURE 6A SAN BRUNO MOUNTAIN EXTENT OF TOWER S AMBIENT ELECTROMAGNETIC FIELD IN EXCESS OF ANSI C95.1-1982 UNDER SPECIAL OPERATING CONDITIONS d footpath down i i i _ . ~~~ KTTS Auxiliary Antenna ~ ~ ~ i r•.,. '•••' '' t~' ~' ~' ~'. ~~ . • • .,•' • ' ~ ~ 16 ft level area ~ .. . dirt road leading to Radio Road ti~~~ Measurements taken May 3, 1988, with FIVi Station KITS operating on its auxiliary antenna. Hammes 8t Edison, Inc. 880531 Consulting Engineers FIGURE 6B Tower 5 SAN BRUNO MOUNTAIN ON-TOWER EXPOSURE CALCULATIONS o000 0000 00 00 000 00 0 000 0 00 0000 0000 00 00 000 00 0 000 o t .~ ..... ~. -.... -.. ~ ~, r, r.... .~ ~- ..., ., ~. .. ., ~... .~ u 0 ~ `~ r 0000 0000 00 00 000 00 0 000 0 0o u a 0000 0000 00 00 000 00 0 000 0 " ~ r, .~ .~ ., .~ ....~ .. .~ ... ~, ... ... ~, .~ .... r» .~ .... r, ~ o .. c o000 0000 0o v~v~ o00 00 0 0000 0 00 0000 0000 00 ~e~ o00 00 0 .-oo 00 ~ c o'd .~ .r .... .... ..• .... -r ..-~ .r ...~ ...~ ..r ... ..-~ ...~ ...~ .•. ..~ ..a ...~ ~ h N • • ~ N L! d ~ 0 0 0 0 C O O L 0 0 O O 0 0 0 O O O G O O O 0 0 u u 3 0000 0000 00 00 000 00 0 0 0o a "uEc ~' ~~`'b A y 3 v O O O O O O O O O O Vl O 0 00 N O O O O O O O O O C u O0 0000 0000 00 ~O~O 000 NO O ~p .... p 0 a 30 ~ ~,u r.. ~..~ -.. -..., ..... ., r. .... ~, .. ... .~ ~, v r 3 ~ ~y ', " j~ + • O to V C I,.Q~ CCCC CCCC CO CC OCC CC O CCC C CO y ~ tCy A y ~ 0 0 0 0 O O O O O O O O O O O O O O O O O O 0 0 .~ C w -..-..-..... ..r ~..~ ..r -..-. ..-... .......~ -...r ... -...r .~ .. .-...-. C ~ ~ ~ A 3 _ ~ c u 00 O O 00 O O O O 00 O O O O O O 0 0 0 O O O c `^ `~ u O O O O O O O O O O O O O O O O O O O O O O O 0 0 C ~~ ~~ 0. -. -.. -.... -..., .» r» .-.... ... ......» ... ~.. ... ..., .... .. ~. -.. ~ u o .~ ° c ~ ~ ~ o000 0000 00 00 000 00 0 000 0 0o E~°° ~ °•3 U o000 0000 00 000 00 0 000 0 00 .~°,'~ ~~ ~ ..., 0 u `~ 3 u .. ~~~ov~ w ~ o000 0000 00 00 000 00 0 000 0 00 3 ",o' p~ o000 ov~~oo 00 000 00 0 000 0 00 ~~'v ~ a~ .-..~ ...~ .~ .~ .~ .. .-...... .-..-. .~ .. .-. ... r. m u o A e a vi `=- c C~O~ `, _H -ur O O O O O N O O < h O O O O O O O O O O O O 0 0 ~°~` A~ O Z - N ~^ y .r .-.... .. .r ..r -r ..r .r ..n .r .~ .r .+ .-~ ..r .-. ~.. -.. K C U ~ L ru, a cV C y ~7 (:~~y'4Jy] OOv'f O v1000 00 00 000 00 O 000 O OO ~v u ~ ~ p NNNO -~ .-.oo .-.h V'y1/~ X000 00 O 000 O 00 '~ ~ C ~ •~ .~ .r .~ ~ .~ ....~ .r .r .-...+ K m C 00 t ~.. .- A T + u~ueu3 0000 000o v~o 00 000 00 0 000 0 00 ~Oo 0 0000 ov~oo ro 00 000 00 0 000 0 0o gU.o ~'o~ ..........., ... ..... .-. ..... ..» .., .-. ... r. .. .......-. ... .~ .-. U u - u ~. y • • • • • • V Z_ ~ •V ~p u (3^~Vy O O O O O O O O O O O O O O O O O O O O O O O O --- oov~o 00 00 000 00 0 000 0 00 ~•; ~ aoao .... ~, .... r., ..» ., ...~ _. r, -.. .~ .. ~. r. .... • • • • • o c ; ~`+ e o000 ov~+oo 00 00 000 00 0 00o O oo A o'c u.ur --o v~~ooo 00 00 000 00 0 000 0 00 "'Or•=°E ~ .r .-. .--~ .~r .-..~ .-..-.... .•r .-. .-. ......... r.. ~.._. ~ G y L Y ~ v ~ u O •. J u u u ~- tO~~ ; u 3 ~ N N h .. A C V -`-~ Q ~ "" N .•. ~ C h C C O e+f t+1 ~ E ~ ; •~i ~ d. J •v .~ .U s ,~ •~ u a~ „~• V > > > ~ ~ u o ~.] Q u u u ~ A A e o u ~ ~ E ., ~ .. ~ u t fn ° u y ~ N !~1 f~1 f~f !rl 3 Y1 ~ ~ ~ f~1 f+l C C .~ ~ C .,., ~~y~.= z z z "-° K ~ u t p ~ K K K K K ~ a A u cCO .'•' _ _ _ 3 oo "~a as ~o ~~ 3°m° ~ ~~ 3 vi " ~ ~~~~C ~aaeX~ XX X~C ~~4 FU aL?Cx ~ ICY Z e a Hammett & Edison, Inc. 880531 Consulting Engineers FIGURE 7 ENVIRONMENTAL CONSIDERATIONS REGARDING LAND MOBILE RADIO FACILITIES The firm of Hammett & Edison, Inc., has been retained by Telecommunications Properties, Inc., to prepare this statement concerning certain environmental considerations at typical business radio transmitting sites. What types of facilities are located at these sites? Communications via radio waves is an important aspect of the operation of such diverse users as cellular telephone networks, medical and other information relay systems, trucking companies, taxicab and delivery companies, and public safety services (police and fire). These users are sometimes referred to loosely as "land mobile". Amateur radio operators, common carriers, and low-power or full-service FM and TV broadcast stations also make use of radio wave transmissions. Transmitting sites are generally located at relatively high elevations, to facilitate service over a broad area. Some radio services are "broadcast" communications systems, meaning that a base station sends information or announcements to the various receivers tuned to receive it. Other services are "two- way" communication systems, meaning that individual receivers (typically mobile receivers) have the ability to transmit information back to the base station. And finally, some services are "point- to-point" communications systems, meaning that there is only a single fixed-location receiver for each transmitter. What is electromagnetic radiation? The application of voltage across a coil of wire creates an electrostatic field and a magnetic field. If the applied voltage is varied between negative and positive, then the resulting "electromagnetic" field also varies. For example, the power supplied through a home electrical outlet (called "alternating current") is varied at a rate of 60 times each second; this is called 60 "Hertz" in honor of Heinrich Hertz (1857-1894) and abbreviated as 60 "Hz". Most home appliances will emit small electromagnetic fields at 60 Hz. They are said to be "radiating" an electromagnetic field or producing "electromagnetic radiation". When the variations in applied voltage occur much faster, at a rate of one million times each second, for instance, an electromagnetic field still results, but now its frequency is called 1 mega- Hertz and abbreviated as 1 "MHz". Communications facilities operate in this manner, each generating a transmitted electromagnetic field in acarefully-controlled range of frequencies assigned to it by the Federal Communications Commission ("FCC"). Audio and video receivers (i.e., radios and televisions) sense these fields and can translate the information encoded on them into sounds and pictures. Hammett tit Edison. Inc. Consulting Engineers August 24, 1988 San Francisco page 1 of S Ionizing radiation is the term used to describe radiation which can cause a dissociation of atomic chemical bonds in living tissue exposed to it. The ultraviolet rays in sunlight are an example of ionizing radiation, causing tanning or sunburn, while light from a fluorescent or standard incandescent light bulb is non-ionizing. All RF radiation (including microwave radiation) is non-ionizing; its wave energy by itself cannot cause an atomic change in living tissue. The principal effect of exposure to non-ionizing radiation is an increase in temperature; energy is being received by the body, causing it to heat Microwave ovens work by exposing food to high-power, concentrated non-ionizing radiation for a sufficient period that it heats to the point of irreversible physical change, recognized as "cooking". Who sets the limits for exposure to RF radiation? Various government agencies and industry groups have, at one time or another, set standards to limit human exposure to electromagnetic radiation. The Occupational Safety and Health Administration ("OSHA") has for many years used a limit of 10 mW/cm2 or occupational exposure by workers to electromagnetic fields above 10 MHz. (The units here are milliwatts per square centimeter, a measure of the amount of energy flowing into a certain area.) Researchers have identified that level as the minimum exposure required to generate a rise in body temperature. A human body at prolonged exposure to such levels is widely believed to have the ability to give off enough heat, through perspiration and air-exchange, to show no cumulative effects, i.e., there is no uncontrolled temperature rise and therefore no known health hazard. Although research in the field has been almost entirely in the area of thermal affects, some researchers have tried to identify non-thermal effects of exposure to electromagnetic fields; it is generally felt that such rescarch has thus far been inconclusive. The American National Standards Institute ("ANSI') is an independent group which sets voluntary standards for a large variety of construction and measurement procedures. In 1982, ANSI adopted its C95.1 Standard for "Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields" covering the frequency range of 0.3 to 100,000 MHz. In adopting this Standard, ANSI added a safety factor of 10 to the OSHA requirement for fields in the FM and VHF TV frequencies, where research had shown that the human body absorbs radiation morc efficiently, and a safety factor of 2 in the microwave frequencies. Thus, the ANSI Standard C95.1-1982, widely recognized as the prevailing guideline, sets its most restrictive limit to 1 mW/cm2 for exposure of unlimited duration to RF radiation. The Environmental Protection Agency ("EPA") has not issued a standard for human exposure to electromagnetic fields. While the EPA has recently requested comments on several possible standards that it might adopt, including limits equal to the ANSI Standard as well as limits several times more stringent, it is not known when the EPA will issue its own standards, if at all. Hammett & Edison, Inc. Consulting Engineers San Francisco August 24, 1988 page 3 of S What about interference from transmitting sites? All non-military and non-Federal Government communications facilities are licensed by the FCC and each has an obligation under the terms of its license to help resolve any interference problems that might arise from its operation. Often, such steps as the addition of RF filters and the rearrangement of antennas are taken at the time of installation to prevent interference between the various on-site communications facilities themselves, so consequently there will be a lesser likelihood of interference to nearby facilities. How does one get more information? The communications companies using radio transmitting sites are usually willing to provide information on their facilities to interested parties. The FCC has field offices located throughout the U.S., and the staff of these offices can answer questions, provide literature, and investigate problems. Consulting engineering firms can be retained for similar functions, as well as for specific studies of radiation levels or for recommendations to address specific interference problems. HAI\~IlV1ETT & EDISON, INC. Consulting Engineers • William F. ett, P. . Subscribed and sworn to before me this 24th day of August, 1988 OFFICIAL SEAL - -- - - - - -- ERNEST [l. MONTANER NOTARr PUFII,IC CAUfORN1A SAN 6AATE0 COUNTY MY ~.~ Eapirw lmr 7 1 V91 Hammett dC Ed1SOR, LIC.. Consulting Engineers August 24, 1988 San Francisco page S of 5 TELECOMMUNICATIONS PROPERTIES SAN BRUNO MOUNTAIN TELECOMMUNICATIONS SITE SAN FRANCISCO, CALIFORNIA REPEAT SURVEY (1991) OF RADIOFREQUENCY ELECTROMAGNETIC FIELDS March 19, 1991 ~, '~ Hammett & Edison, Inc. Consulting Engineers Sao Francisco 'r SAN BRUNO MOUNTAIN TELECOMMUNICATIONS SITE SAN FRANCISCO, CALIFORNIA STATEMENT OF WILLIAM F. HAMMETT, CONSULTING ENGINEER The firm of Hammett & Edison, Inc., Consulting Engineers, has been retained by Telecommunications Properties, manager of the telecommunications site on San Bruno Mountain, California, to re-evaluate the site for its present state of compliance with the the appropriate guidelines for limiting human exposure to radiofrequency electromagnetic fields. ELECTROMAGNETIC FIELD EXPOSURE STANDARDS In General Docket 79-144, the FCC adopted the radio frequency protection guide of the American National Standazds Institute Standard C95.1-1982, American National Standard Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 300 kHz to 100 GHz ("ANSI"). The effective date for applying the ANSI limits to broadcast stations was January 1, 1986. The most restrictive power density level for unlimited time exposure is 1 mW/cm2 at frequencies between 30 and 300 MHz, where FM and VHF TV stations operate; the limit increases at higher frequencies, including the LTHF TV band. The radio frequency protection guide of ANSI is based upon time averaging over a ' six-minute period. Thus, exposures to fields above the limit aze permissible, if the exposure time is restricted to a proportionally shorter period. For example, exposure to fields three times the ANSI limit is permissible for two minutes, provided the remaining four-minute period does not include any exposure. The FCC has provided direction to the broadcast industry on determining compliance with the ANSI Standard in the Office of Science and Technology Bulletin No. 65, Evaluating Compliance With FCC-Specified Guidelines for Human Exposure to Radiofrequency Radiation ("OST-65"), and in the Public Notice dated January 28, 1986, Further Guidance for Broadcasters Regarding Radiofrequency Radiation and the Environment ("Notice"). Restrictions on access to strong fields may be achieved in different manners for public and for occupational exposures. For example, persons who aze authorized to be at a broadcast site can be educated to follow procedures that will limit time-averaged exposures to levels within • • the ANSI guidelines. 1988 FIELD SURVEY & RECOMMENDATIONS A comprehensive field survey was conducted in May of 1988 at the San Bruno Mountain antenna farm, at which time the entire site was examined for the presence of high ambient or localized RF fields that might approach the ANSI guidelines for public or occupational Hammes & Edison, Inc. 910307 Consulting Engineers PAGE 1 SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA exposures. Based on an inventory of the transmitting facilities then existing at the site, calculations were performed of on-tower exposure conditions and a table (attached as Figure 7 to the report on that work) was prepared showing the necessary power reduction percentages for calculated compliance with ANSI at each of the broadcast antennas. My report, dated June 23, 1988, gave fourteen recommendations, adoption of which would have, in my professional opinion, brought the site into compliance with the ANSI and OST-65 criteria for limitations on public exposure to RF fields. These recommendations were: 1. Remove the gate (and two associated posts) across the roadway to Building A. [Alternatively, add 8-inch wooden spacers to the gate and post warning signs.] 2. Post signs on the gate across the roadway south of Building B leading to the satellite antenna site. 3. Fence the base of Tower 8 and the Channel 5 ENG facilities. [Alternatively, remove the bottom six bays of the KYW (now KFRC-FM) auxiliary antenna and reroute its transmission line.] 4. Fence the base of Tower 2. 5. Fence the base of Tower 5, including the previously noted area to the south. 6. Add 6-inch wooden spacers to the fourth cable rack support post south of Tower 2, add 2-inch wooden spacers to the fifth post, and post warning signs on each. 7. Remove the scrap coaxial cable on the ground about 75 feet to the south of Tower 2. 8. Shield the ground cable on the north face of Building B with a dielectric material at least one inch thick. 9. Post warning signs at both gates in the fence around the base of Tower 4. 10. Shield the ground-level run of the KYUU (now KFRC-FM) transmission lines with a dielectric material extending at least two inches from the metal. 11. Post a warning sign on the microwave dish at the northeast corner of Building A. 12. Replace the two power pole guy wires located to the west of Building A with dielectric material. [Alternatively, shield both guys with a dielectric material extending at least two inches.) 13. Adopt a formal power cutback agreement between tenants with implementation of auxiliary operation notification procedures. 14. Prevent or restrict public access to Towers 1, 3, and 7. SAN BRUNO MOUNTAIN TRANSMITTING FACILITIES ~ ; Since the 1988 work was done, there have been several changes in the transmitting ' facilities at the site. Figures 3A and 3B attached are updated versions of the corresponding figures in the 1988 report, incorporating these changes. There are now three UHF TV stations broadcasting from the site, with a pending proposal for a network affiliate VHF station to Hammett & Edison, Inc. 910307 Consulting Engineers PAGE 2 SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA construct a new auxiliary facility there, too. The number of FM stations is still ten, although one, KYA(FN1), now has just auxiliary facilities there. The site remains accessible to the public by car via Radio Road through the San Bruno County Regional Park entrance, which is open only during daylight hours, and by foot at all hours. 1991 REPEAT SURVEY On February 12, 1991, I conducted a survey of RF power density levels in those areas of the antenna farm that had been observed previously to exceed or approach the ANSI guidelines for exposures of unlimited duration. I was accompanied during this survey by, among others, Mr. Ron Sadler of Telecommunications Properties. The survey equipment and procedures were similar to those used in 1988, with the Holaday HI-3001 broadband exposure meter Serial Number 39202 having been recalibrated several times in the interim, most recently on October 5, 1990. During this survey, field verification was made of the antenna changes noted in Figure 3. IMPLEMENTATION OF 1988 RECOMMENDATIONS Thirteen of the fourteen recommendations required that some action be taken, whether to create access restriction barriers, to add RF warning signs, or to remove sources of localized RF fields. The 1991 survey revealed that, with one exception, all thirteen of these actions had been taken in sufficient degree to resolve, to my satisfaction, the several conditions allowing possible human exposures in excess of the ANSI guidelines. That exception was recommendation 3 in the list above: Fence the base of Tower 8 and the Channel S ENG facilities. [Alternatively, remove the bottom six bays of the KYW (now KFRC-FM) auxiliary antenna and reroute its transmission line.] It was apparent during the recent survey that the unlocked gate at the base of the stairway leading up to Tower 8 was not adequate to prevent public access to the area of high RF fields, which the measurements showed still to exist. Those fields are in close proximity to the de- energized KFRC-FM auxiliary antenna and likely result from reradiation of energy from the KFRC-FM main antenna above it on the same tower. The other nine FM stations, located some distance away at the north end of the San Bruno Mountain antenna farm, aze all very small contributors to the RF fields at the base of Tower 8. I understand from my discussions with personnel at several of the stations that recommendation 13, the adoption of mutual power cutback agreements, has been implemented. Hammett 8t Edison, Inc. 910307 Coruulang Engineers PAGE 3 SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA I believe, moreover, that most of the FM stations at the site have already attested to this fact in their original or supplemental filings for license renewal. This report contains additional, more detailed data, attached as Figures 8A through 8G, for use by these stations in implementing their power cutback agreements. These power cutback schedules are applicable only to the transmitting facilities described in this report; any subsequent material change in facilities may invalidate these schedules and require recalculation. Figure 7 has also been revised, now showing the most restrictive cutbacks for access to any height on each tower. CONCLUSION Based on the studies and measurements described above, and based on my understanding of the adoption by the FCC of the ANSI Standard C95.1-1982, I conclude that, for the nine FM stations located at the northern end of San Bruno Mountain, each complies with the ANSI Standard for limitation of public exposure conditions. These stations are: KQED-FM, Channel 203B, San Francisco KYA(FM), Channel 227B, San Francisco KSAN-FM, Channel 235B, San Francisco KKHI-FM, Channel 239B, San Francisco KIOI(FM), Channel 267B, San Francisco KBLX-FM, Channel 275B, Berkeley KITS(FM), Channel 287B, San Francisco KMEL(FM), Channel 291B, San Francisco KSOL(FM), Channel 299B, San Mateo. LIST OF FIGURES In carrying out these engineering studies, the following attached figures were prepared under my direct supervision: 3. Tabulation of engineering specifications of broadcasting operations 7. Revised table of worst-case power reductions for on-tower ANSI compliance 8. Tables, by tower and by elevation section, of ANSI-compliant power reductions. March 19, 1991 QRpFESS/pN ~~Q~~P,t~ F Hq,~~F 2 `~'' v E-13026 ~ 2 W 3 ~A-2CG7u ~ ~, ~~ Exp 8'30'9 * ~ ~ Zi~F~~GP~. d+Igr FcHAN~GP ~~P F ~F CAI~E~ HAMNIETT & EDISON, INC. Consulting Engineers William F. Hammett, P.E. Hammett & Edison, Inc. 910307 Consulting Engineers PAGE 4 AFFIDAVIT State of California ) ss: County of San Mateo ) William F. Hammett, being first duly sworn upon oath, deposes and says: 1. That he is a qualified Registered Professional Engineer, holds California Registrations Nos. E-013026 and M-020676, which expire on June 30, 1993, and is a principal in the firm of Hammett & Edison, Inc., Consulting Engineers, with offices located near the city of San Francisco, California, 2. That he graduated from Dartmouth College with a degree in Engineering Sciences in 1977 and from the University of Illinois with a degree of Master of Science in 1978, has completed two years of employment by the Standard Oil Company and five years by Dean Witter Reynolds in various engineering, computer, and management capacities, and has been associated with the firm of Hammett & Edison, Inc., since 1985, 3. That the firm of Hammett & Edison, Inc., Consulting Engineers, has been retained by Telecommunications Properties, manager of the telecommunications site on San Bruno ~, Mountain, California, to re-evaluate the site for its present state of compliance with the the appropriate guidelines for limiting human exposure to radiofrequency electromagnetic fields, 4. That such engineering work has been carried out by him or under his direction and that the results thereof are attached hereto and form a part of this affidavit, and 5. That the foregoing statement and the report regarding the aforementioned r engineering work are true and correct of his own knowledge except such statements made therein on information and belief, and as to such statements, he believes them to be true. William F. Hammett, P.E. Subscribed and sworn to before me this 19th day of March, 1991 ORIGINAL COPY NOTARIZED SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA ~; ~, ~~, SUMMARY OF BROADCAST TRANSMITTING FACILITIES Effective Antenna Antenna COR Station ~~j Buildin g Radi ated Power Make & Model Tower Height. AMSL KDTV(TV) 14 G MAIN: 2570 kW Andrew 63534 10 443 m KTSF(TV) 26 F MAIN: 2510 RCA TFU-30JDAS 9 461 AUX: 95.5 Andrew ATW2G1-HSS 8 428 KCSM-TV 60 G MAW: 1550 Andrew 63506 10 432 KQED-FM 203 B MAIN: 110 ERI FMH-6AC6 2 433 AUX: 28.0 Harris FMH-2AC 3 399 KYA(FM) 227 A AUX: 7S Jampro JHCP-1 2 417 KSAN-FM 235 B MAIN: 30.0 Jampro JSCP-4 3 425 AUX: 23.0 ERI GSCPS-3AE 3 413 KKHI-FM 239 A MAW: 6.9 ERI2AE-SP 2 451 AUX: 2.6 Collins 37CP-2 2 405 KFRC-FM 259 F MAIN: 45.0 ERI FMH-4AC 8 436 AUX: 45.0 RCA BFC-10 8 417 KIOI(FM) 267 A MAIN: 125 Jampro JSD-2P/3 1 419 AUX: 61.0 Jampro JSCP-6 1 405 KBLX-FM 275 C MAIN: 6.6 Collins GSCPM-2E 4 451 KITS(FM) 287 C MAIN: 15.0 Jampro JSCP-4 5 425 AtlX: 15.0 Jampro JSCP-4 5 387 KMEL(FM) 291 A MAW: 69.0 Jampro JSCP-7 1 440 ALJX: 8.6 Jampro JHCP-1 2 411 KSOL(FM) 299 C MAW: 8.9 ERI GSCPS-4 5 412 AUX: 4.0 ERI GSCPM-2 4 447 Note: Tower and building identifiers refer to maps contained in the Hammett & Edison survey report dated June 23, 1988. 910307.1 Hammett & Edison, Inc. Consulting Engineers FIGURE 3A SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA SUMMARY OF BROADCAST TRANSMITTING FACILITIES Tower 1 Base Elevation 372 m, AMSL Antennas KMEL(FM) main KIOI(FM) main & auxiliary 2 373 KKHI-FM main & auxiliary KQED-FM main KYA(FM) auxiliary KMEL(FM) auxiliary 3 373 KSAN-FM main & auxiliary KQED-FM auxiliary 4 369 KBLX-FM main KSOL(FM) auxiliary 5 373 KSOL(FM) main KTTS(FM) main & auxiliary 6 373 Cellular radio 7 375 Land mobile 8 401 KFRC-FM main & auxiliary KTSF(TV) auxiliary 9 390 KTSF(TV) main 10 381 KDTV(TV) KCSM-TV ~~I i ~. ~' f' $111j~1IIE A Site Elevation 371 m, AMSL Tenants KMEL(FM), KIOI(FM) B 369 KQED-FM, KSAN-FM C 369 KBLX-FM, KSOL(Fbi), KITS(FM) D 373 Cellular radio E 375 Land mobile F 381 KTSF(TV), KFRC-FM G 378 KDTV(TV), KCSM-TV Note: Tower and building identifiers refer to maps contained in the Hammett & Edison survey report dated June 23, 1988. 910307 Hammett & Edison, Inc. 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'~ ~' E o ~' U t~ O t+'f O O~ RFR.TOWER'~ CALCULATION METHODOLOGY DETERMINATION BY COMPUTER OF ANSI COMPLIANCE CONDITIONS The U.S. Congress has required of the FCC that it evaluate its actions for possible significant impact on the environment. Tn General Docket 79-144, the FCC adopted the American National Standards Institute Standard C95.1-1982, "American National Standard Safety Levels with Respect to Human Exposure to Radio Frequency Electromagnetic Fields, 300 kHz to 100 GHz". The guidelines in this Standard are now applicable to all FCC- licensed broadcast stations. The most restrictive guideline is 1 mW/cm2, applying at FM and VHF television frequencies; at UHF television frequencies, the guideline increases with increasing frequency, up to 5 mW/cm2, applying at microwave frequencies and above. The exposure guideline at AM frequencies is 100 mW/cm2. Exposures are to be averaged over asix-minute period, allowing, for example, a two-minute exposure to fields three times the limit if the remainder of the six-minute period does not include any significant exposure. The FCC Office of Science and Technology Bulletin No. 65 (October 1985) gives the formula for calculating power density from an individual radiation source: 2.56 x 1.64 x 100 x RFF x 0.4xVERP + AERP) power density $ = 4rtD ( , in mW/cm2, where VERP = total peak visual ERP (all polarizations), in kilowatts, AERP = total aural ERP (all polarizations), in kilowatu, RFF =relative field factor az the direction to the actual point of calculation, unitless, and D =distance from the center of radiation to the point of calculation, in meters. The factor of 2.56 accounts for the increase in power density due to ground reflection, assuming a reflection coefficient of 1.6 (1.6 x 1.6 = 2.56). The factor of 1.64 is the gain of a half-wave dipole relative to an isotropic radiator. The factor of 0.4 converts peak visual ERP to an average RMS value; for FM stations, of course, the value of VERP is zero. The factor of 100 in the numerator converts to the desired units of power density. This formula has been built into a computer program by Hammett & Edison that calculates the total expected RF power density at any point on a tower structure. The program allows for multiple sources on multiple towers in order to accurately model multiple-user antenna sites. Appropriate horizontal and vertical antenna patterns are used; actual vertical antenna patterns may be specified, or the pattern envelopes developed in "An Engineering Assessment of the Potential Impact of Federal Radiation Protection Guidance on the AM, FM, and TV Broadcast Services", U.S. Environmental Protection Agency, April 1985, may be used. To be conservative, no vertical antenna pattern may have a minimum of less than 15 percent relative field. For nearby sources, the energy is assumed to radiate proportionally from each bay of the antenna to account conservatively for near-field effects. The results of the program are typically presented in tabular form, with the each row representing the ANSI-compliant operating restrictions for a particular height or zone on one tower, as noted in the fast column. Subsequent columns give, under the heading of the station call letters. the maximum amount of operating power that each station may use in order for calculated RF fields at that tower section to remain less than the ANSI guideline for exposures of unlimited duration. The operating power is expressed as a percentage of full licensed power, and all stations with amounts less than 10096 must reduce power simultaneously in order to meet the calculated conditions. The reduced-power operating conditions shown are those that have been determined to be most equitable in forking the largest contributors of RF power density to reduce power the most. In some situations, several equally attractive configurations may exist, in which case different options will be shown in the table, identified by sequential lower case letters next to the tower height az which the power reductions are shown; each is an acceptable method of achieving compliance. Certain tables of results will include separate columns for the main and auxiliary antennas, when a licensed auxiliary exists; the station may operate from either antenna, at the appropriate power level shown. Unusual situations may require specifications that do not conform to the standard table format described here; in those cases footnotes on the table will explain special conditions necessary to achieve compliance. It is specifically noted that the determinations of compliance with ANSI reported in the table of results are based on calculations of ambient expostre conditions. It is expected that localized exposure conditions may exceed calculated ambient conditions, particularly near non-broadcast antennas or guy-wire and cross-arm attachments. No attempt has been made to predict the effect of those localized effects, beyond the "ground" reflection factor included in the OST-65 formula. Measurements of actual ambient and localized fields would take precedence over any predictions of those fields, and such measurements may be desirable in areas of prolonged or frequent access. Hammett dl: Edison, Inc. 910307 Consulting Engineers FIGURE 9 HAMMETT & EDISON, INC. ~ CONSULTING ENGINEERS RAD[O AND TELEVISION May 22, 1991 Elizabeth Rudnick, Esq. Telecommunications Properties 1333 Willow Pass Road, Suite 201 Concord, California 94520 Deaz Elizabeth: ROBERT L. HAMMETT, P.E. EDWARD EDISON, P.E. Consultmtts to the Finn WILLIAM F. HAMMETT, P.E. HARRl50\~ J. KLEIN, P.E. ROBERT P. SMITH DANE E. ERICKSEN, P.E. GERALD E. SPILLMAN, P.E. GERHARD J. STRAUB, P.E. Enclosed aze fifteen copies of the San Bruno Mountain Engineering Statement figures which we have revised as you requested. This material replaces Figures 3A, 7, 8A, 8B, 8C, and 8D of our March 19, 1991, engineering statement, which have been revised to include the change in auxiliary power for FM Station KMEL. We appreciate the opportunity to be of service. Please call us if we can be of further assistance. Sincerely, i % c«. i Nathan Hamilton it Enclosures (15) cc: Mr. Ron Sadler (w/o encls.) Mr. Paul Black (w/o encls.) Telephone: Mail: Shipping: (4151342-5200 San Francisco Box 280068 1400 Rollins Road (202) 396-5200 DC 14151 342-8482 Facsimile San Francisco, California 94128-0068 Burlingame, California 94010-2304 s~2Zl~ SAN BRUNO MOUNTAIN SAN FRANCISCO, CALIFORNIA SUMMARY OF BROADCAST TRANSMITTING FACILITIES Effective Antenna Antenna COR Station Channel Building Radi ated Power Make & Model Tower Height AMSL . KDTV(TV) 14 G MAIN: 2570 kW Andrew 63534 10 443 m KTSF(TV) 26 F MAIN: 2510 RCA TFU-30JDAS 9 461 AUX: 95.5 Andrew ATW2G 1 •HSS 8 428 KCSM-TV 60 G MAIN: 1550 Andrew 63506 10 432 KQED-FM 203 B MAIN: 110 ERI FMH-6AC6 2 433 A[JX: 28.0 Harris FMH-2AC 3 399 KYA(FM) 227 A AUX: 7S Jampro JHCP-1 2 417 KSAN-FM 235 B MAIN: 30.0 Jampro JSCP-4 3 425 AUX: 23.0 ERI GSCPS-3AE 3 413 KKHI-FM -239 A MAIIV: 6.9 ERI2AE-SP 2 451 AUX: 2.6 Collins 37CP-2 2 405 KFRC-FM 259 F MAIN: 45.0 ERI FMH-4AC 8 436 AUX: 45.0 RCA BFC-10 8 417 KI O I (FM) 267 A MAIN: 125 Jampro JSD-2P/3 1 419 A[JX: 61.0 Jampro JSCP-6 1 405 KBLX-FM 275 C MAIN: 6.6 Collins GSCPM-2E 4 451 KITS(FM) 287 C MAIIV: 15.0 Jampro JSCP-4 S 425 AUX: 15.0 Jampro JSCP-4 S 387 KMEL(FM) 291 A MAIN: 69.0 Jampro JSCP-7 1 440 AUX: 8.6 Jampro JHCP-1 2 411 KSOL(FM) 299 C MAIN: 8.9 ERI GSCPS-4 5 412 AUX: 4.0 ERI GSCPM-2 4 447 I~1ote: Tower and building identifiers refer to maps contained in the Hammett & Edison survey report dated June 23, 1988. 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J~ ~~ 0 ~ ~ ° ~ _, r~~ ATTACHMENT G HCP DEVELOPMENT TABLE 1994 PROJECT STATUS BY ADMINISTRATIVE PARCEL (IN ACRES) AS OF DECEMBER 1994 Administrative Parcel Present 0 en S ace Conserved Habitat Permanent Disturbance Temporary Oisturbence Status See Notes OUADALUPE HILLS 111 O1 Be Rid a 53 31 22 3 UNDER 02 Carter St. 5 5 DONE 03 Linde Vista II 19 12 7 2 UNKN 04 Levinson Pro art 28 UNPL 05 Brisbane Office Park 30 5 5 1 UNKN 06 Parcel Z 11 4 7 UNKN 07 Northeast Rid a Pro act 228 135 93 39 UNDER 08 Guadalu a Valle West 49 49 CONS 09 State Perk 288 288 CONS 10 Guadalu a Can on Pkw 6 6 NA 11 PGBE Transmission Lines 40• NA 12 PGBE Fee 34 UNPL 13 Water Pi clines 9' UNKN 14 Linde Vista I 15 2 13 2 DONE 15 Water Tank 0 NA ___ :r=_~~ ________________ TOTAL FOR GUADALUPE MILLS _____3_____ 749 ________ 537 _________ 147 _________ 47 ___CONS_ ____ SOUTHEAST RIDOE 121 O1 uarr 70 70 CONS 02 Owl and Bucke a Can ons 91 91 CONS 03 Brisbane Acres 154 UNPL 04 Terrebe Pro act 337 202 135 68 UNDER OS Count Perk 575 575 1.5 CONS 06 Hillside School 0 NA 07 PGBE Transmission Liners 35` NA 08 Juncus Ravine 162 162 1.5 CONS 09 Water Pi ellnes 12• UNKN 10 Fire Breaks TOTAL FOR SOUTHEAST gIDGE -----~---~- 1 389 -----~-- 1 100 --------- 135 --------- 71 ---NA------ RADIO RIDGE 131 O1 Telecommunications Site 15 15 DONE 02 Count Perk 866 866 CONS 03 Guedelu a Can on Pkw 0 NA 04 PGBE Transmission Lines ____ TOTAL FOR RADIO RIDGE ____ 28_____ 881 ________ 881 _________ _________ ___NA ______ SADDLE 141 O1 Pointe Pacific 35 35 DONE 02 Ville a-in-the-Park 2 2 DONE 03 "47 Units" 9 2 7 2 UNDER 04 State Perk 184 184 DONE OS Guedelu • Cen on Pkw 0 NA 06 Water Tanks TOTAL FOR SADDLE p 230 223 7 2 NA GRAND TOTAL 3,249 2,741 289 120 NOTES FOR PROJECT STATUS TABLE: DONE = PROJECT CONSTRUCTION AND/OR GRADING COMPLETED UNPL = UNPLANNED PARCEL WITH NO PENDING STATUS CHANGE UNKN = UNKNOWN PLANNED, NO DEVELOPMENT APPLICATIONS PENDING CONS = DESIGNATED AS CONSERVED HABITAT UNDER THE HCP NA = NOT APPLICABLE UNDER = PROJECT UNDER CONSTRUCTION * = EASEMENT NOT ADDED INTO TOTALS OR SITE ACTIVITY FORMS