Hi all,
That the campaign against the proposed KOWS antenna structure on Pleasant Hill Road has been marked by controversy should come as no surprise - this is a fairly common response to any new construction project in a neighborhood. A friend described to me the recent opposition to a proposed traffic circle in Forestville at the intersection of 116 and Mirabel Road and said the reaction seemed as though there were a proposal to put a nuclear reactor in that spot. People don't like change.
The primary organizer for the neighborhood opposition to the KOWS antenna went on record today in the public comments to the recent City Council hearing to suggest that "in this post 9/11 world" it might be prudent to ask whether a disgruntled KOWS programmer who lost their show might be inspired to commit a terrorist act against the two 3 million gallon water tanks on the Pleasant Hill city property if KOWS had the sort of access to the site that would be required if KOWS had an antenna structure there. The conversation on this matter has grown exaggerated beyond the point of absurdity.
The following is an excerpt of the statement I presented on behalf of the KOWS Antenna Relocation Committee during the May 3rd City Council meeting reviewing the appeal to the approved Use Permit granted by the Sebastopol Planning Commission (the referenced City of Sebastopol City Council Staff Report can by found here and the full range of submissions both pro and con can be found here):
To begin, KOWS-LP Community Radio would like to thank the Sebastopol City Council and the City Planning Director for this opportunity to come before you and discuss our proposed antenna relocation project. As you know, KOWS is an FCC-licensed Low Power FM radio station that began broadcasting in 2008 in Occidental. The mission of KOWS from its inception is to provide a unique voice in West Sonoma County that highlights the diversity of talent and sources of information available in our community. We are an entirely volunteer organization supported through a combination of membership dues from all hosts, underwriting support, community memberships, and grants.
As the number of KOWS listeners, show hosts, and underwriters has increased over the last eight years, we have found growing interest to improve the broadcast reach in key areas of West Sonoma County such as downtown Sebastopol.
Our current antenna is located in a tree on the OAEC property on Coleman Valley Road in Occidental. Though this antenna location has served the Occidental area over the years, it has limited reach in Sebastopol due to the shadowing effect of the ridge line between Occidental and Sebastopol. So over the last several years, the KOWS Steering Committee and Antenna Relocation Committee have worked diligently on a plan to bring greater KOWS coverage to the larger Sebastopol community.
This meeting tonight really is about a possibility and an opportunity: The possibility we invite the City Council to consider is: a Sebastopol-based community radio station that acts as a magnet that draws and brings together the many different voices and talents of West Sonoma County; a community radio station that enhances the brand of the City of Sebastopol as a cultural center and a destination. We ask you to consider a Sebastopol-based community radio station that showcases our local musicians and artists; acknowledges the support of local businesses; hosts in-depth conversations about the region’s top political, social, and spiritual issues; and gives voice to members of the community who might not otherwise have avenues for expression.
With the recent move of our studio from downtown Occidental to the Sebastopol Methodist Church, we have already seen the growing ability of our community radio station to touch the lives of the local residents. KOWS recently coordinated with students from Analy and El Molino, creating the monthly High School Students Forum where students discuss issues of concern to youth – and our extended community. KOWS also provides a regular forum for older members of our community, called “Growing an Elder Culture.” In addition to a wide range of innovative music and talk shows, KOWS also provides live coverage of local events, including the Apple Blossom Festival and California Bluegrass Festival. The mission of KOWS-LP is to support and expand community in the City of Sebastopol and the surrounding West Sonoma County. The possibility that we invite you to consider is the possibility of an authentic voice of Sebastopol on the airwaves.
The opportunity that we invite you to take action on here tonight is to sustain the Sebastopol Planning Commission’s approval of a Use Permit to relocate the KOWS antenna to the Pleasant Hills reservoir property and to deny the appeal submitted against that considered decision. When KOWS radio leadership began the process of exploring alternative antenna sites to the current OAEC location, our criteria included what is allowable by the FCC and sites that maximize potential listenership in the West County area. The details of this process, the constraints that limited possible sites, and the many alternatives we explored are described in the supplemental material we presented in response to the Appeal. In this process, we identified an ideal location on City-owned land, zoned only for community facilities, that provides a significant boost to KOWS signal coverage in the Sebastopol area.
The purpose of this Use Permit is to locate a 70-foot, 24 inch wide, lattice structure on the site of 1281 Pleasant Hill Road and to mount a 4 bay low power antenna on this structure that will provide an FM signal to effectively reach all of Sebastopol and the surrounding West County area. The multi-bay antenna structure is designed to minimize the RF (radio frequency) field strength in the local residential area to levels significantly below that of EMF field strengths typical in modern households. By shaping the signal with the multi-bay design, this structure will still retain the ability to reach a primary population of 210,000 potential listeners and a secondary population of another 110,000. This represents a significant increase over the number of listeners we reach via the existing antenna structure at OAEC. For an effective Sebastopol-based community radio station, the signal must be capable of reaching as many community members as possible. Our proposed antenna structure on the Pleasant Hill reservoir site achieves this result with a minimal impact on the neighboring community.
KOWS acknowledges the concerns raised by the Appellants who seek to reverse the approval for the Use Permit granted by the Planning Commission on February 23rd. We recognize the appellants on their organization and energy. However, we also maintain that in their enthusiasm, the appellants have exaggerated the situation out of proportion to the facts and turned this antenna proposal into an existential battle. The City Council Staff report does an excellent job in responding to the key issues raised in the appeal and shows that each of the concerns has been addressed by the Planning Department and the KOWS Use Permit application.
We would like to clarify a detail regarding the potential impact of Electromagnetic Frequencies emitted by the antenna. The City Council Staff report is clear that the proposed KOWS antenna design approved by the Planning Commission is significantly more conservative than the FCC Radio Frequency emission safety requirements for residential areas. KOWS submitted with its original Use Permit application a Non-Ionizing Electromagnetic Radiation (NIER) report written by an FCC-certified radio engineer. In addition to conducting a NIER study on our approved 4-Bay antenna design broadcasting at 25 watts, the engineer also did a study on a single bay antenna, broadcasting at the hypothetically maximum allowable Low Power FM level of 100 watts. The Appellants confuse this study and the accompanying data in their attachment to their appeal, seeking to imply that the hypothetically maximum case figures were somehow representative of what the proposed antenna would produce.
We ask the City Council to allow us to clarify this situation with actual numbers from the report. Though the City Council Staff report is correct in stating that the proposed KOWS antenna meets the FCC NIER requirements for general population/uncontrolled exposure, we want to emphasis that our proposal is in fact less than 1/2500th of the FCC NIER requirements for the residents in the vicinity of the antenna. The Appellants raised a concern in their attachment about the strength of the RF signal on an undeveloped parcel immediately adjacent to the proposed antenna site. The KOWS NIER report shows that at the fence line, the power density from the antenna is less than 1/750th of the FCC NIER requirements and that this value quickly falls off to less than 1/2500th of the FCC requirement at any likely home site on this parcel.
Another area of concern the Appellants raise is the environmental and visual impact of the proposed antenna structure. The City Council Staff report does an excellent job in putting the proposed antenna structure in context with the realities of the rural residential environment around the Pleasant Hill reservoir. 50-foot high PG&E wooden utility poles carrying high voltage current with large step down transformers line Pleasant Hill Rd, Blackney Rd, and Elphick Rd with a density of about one pole every 150 feet. These utility poles traverse the nearby open landscape with far more visual exposure above the surrounding vegetation and they disrupt the natural landscape much more thoroughly than the proposed antenna. As the simulated views that KOWS presented in its response to the Appeal show, it is virtually impossible to find a vista in this area that is not dominated by one or more of these utility poles projecting far into the skyline. The City Council Staff report indicates that our proposed 24” wide lattice antenna structure even at a height of 70 feet will not be significantly distinguished from the many utility poles lining the rolling hills of the area.
The Appellants go so far to claim in their attachments that it is by virtue of the large number of utility poles that no one in the community notices them. They claim the KOWS antenna structure will be singular and therefore draw undue attention. We suggest this is actually an example of a more general phenomenon: the typical response to any proposed construction change in a neighborhood is for residents to exaggerate the impact of what will be different and to discount the impact of what has already been present for years. This is why no one in the neighborhood notices the 60-foot antenna structure at the Gold Ridge Fire Station right around the corner of Pleasant Hill Rd from the reservoir property. This antenna is clearly visible at the corner of Pleasant Hill and Watertrough Roads, and is located next to two schools. This is why the many PG&E utility poles in the area are virtually invisible to residents. The simulations that KOWS provided in its response to the Appeal also show that given the varying terrain of this area and the over 500’ setback from the road, the proposed antenna structure will not in fact be easily visible from most viewpoints. Additionally, the requirements imposed by the Planning Department - to paint the structure to blend in with the background - will further enhance the antenna’s integration into the surroundings.
Notwithstanding all of the aforementioned, KOWS sincerely wants to minimize the visual impact of the proposed antenna structure. We want to be the best neighbors we can while still achieving our goals. So even after gaining the approval of our Use Permit from the Planning Commission, KOWS continued to research different options for antenna structures to further limit the visual impact of our installation. After much research, we have developed an option, detailed in the Staff report, which represents a 60- foot tapered lattice structure from Trylon that starts out with a 30” width at the base, tapers to 21” at 30 feet, 15” at 50 feet, and 12” at 60 feet. On top of this will be a 2” wide 5’ extension pole for a total height of 65 feet. This structure will be lower in height, thinner in profile, and yet afford a similar signal reach to the greater Sebastopol area. In addition, this structure is sized so that no additional antennas may ever be added, thus eliminating the potential for co-locating future antennas on this structure. As the Staff report states, we offer this solution as a way to mitigate concerns about visibility and impact of the proposed antenna.
I would like to make the following concluding comments:
On December 30th, 2015, KOWS Community Radio submitted an Antenna Use Permit Application to the Sebastopol Planning Department. In this Application, KOWS specifically addresses a number of issues and concerns directly related to our proposed antenna project. These include: existing site uses; rationale for location; neighbor notification; construction steps; reduction of visual impact; broadcast operations, equipment and signal; tower specifications; antenna specifications; benefits to the Sebastopol community; and more.
The Sebastopol Planning Commission approved our Use Permit on February 23rd of this year. KOWS has recently submitted to the Planning Department a comprehensive, detailed Response to the Appeal of this decision, filed by some neighbors. This Response is included in the City Council Staff Report. In our Response, we directly address a number of issues raised by the Appellant: CEQA; co-location; radio frequency emissions; KOWS listening audience; other possible locations; notification of neighbors; KOWS financial stability; visual impact; and other concerns.
We very much appreciate your consideration of our antenna project proposal. We ask the City Council to sustain the Planning Commission’s approval of the KOWS Use Permit and deny the appeal. We have demonstrated in our extensive documentation for this project that the Radio Frequency electromagnetic radiation emission levels fall significantly below even the most conservative safety standards; the visual impact is minimal and can be further mitigated with an alternative design; our proposed use is appropriate for the zoning of this property; and the benefits for the Sebastopol community are many, varied, and substantial. We ask you to take advantage of this opportunity to support the KOWS antenna relocation project and make the possibility of a Sebastopol-based community radio station a reality.
Thank you for your consideration
- Stuart Goodnick, KOWS Antenna Relocation Committee