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HomeMy WebLinkAboutSEPA EPIC-1-91 - CELLULAR ONE / RHODE CAROL - CELLULAR ONECELLULAR ONE ALLENTOWN CELLULAR COMMUNICATIONS SITE TEMPORARY FACILITY 12560 51ST PLACE SOUTH EPIC -1 -91 ▪ a ■ ■ ■ ■ ■•o ■■■■ • ■•■ ■■ ■ ■ ■ ■ ■ ■■ • d■• ■ ■ ■■ • ■■■■■ • ® m■■■■M Cellular December 21, 1990 Mr. Jack Pace Community Development Department City of Tukwila 6200 Southcenter Blvd. Tukwila, WA 98188 Re: Temporary Use Permit for Cellular One Facility located at 12560 51st Place S, Allentown, WA. Dear Mr. Pace: Included with this letter are drawings and an Environmental Checklist. Cellular One is requesting an expedited approval to install a temporary cellular radio base station (cell site) in Tukwila at 12560 51st Place S. A Conditional Use Application and a Board of Architectural Review Application will be submitted for a permanent facility at the same location. Request: Cellular One seeks to install a 100 foot telephone pole a electronic equipment vault to house electronic monitoring equipment, electrical service and telephone service. The wood pole would be erected and 12 directional antennas would be attached, but would not exceed the top of the telephone pole. The 12 by 28 foot vault would contain the necessary electronic equipment and would be placed on the ground. Fencing (6' chainlink with 2' of barbed wire on top) for security purposes would be installed to enclose the telephone pole and equipment vault. Installation of a temporary facility is expensive, but necessary to provide service in the immediate area. Service to the area is presently provided by the Tempress cell site. This site, however, will reach capacity in the spring of 1991 and service in the area will be inadequate and is already experiencing a degradation of service. Cellular One is therefore requesting that the temporary facility be approved and allowed to remain until the permanent facility is approved and installed. If for some reason the permanent facility at this location is not approved, then the temporary facility should be allowed to remain until another location is found and approval obtained. 617 Eastlake Avenue East P.O. Box 9159 Seattle, WA 98109 206/624 -5700 • • Jack Pack Proposed Temporary Use December 21, 1990 Page -2- Reason for Request: Currently, Cellular One is experiencing some rapidly worsening bouts of interrupted service in the Allentown area. This area is currently serviced by the Tempress cell site which is reaching capacity rapidly, and is unable to supply adequate service to the area. This is primarily due to increased usage of mobile telephone service in the Allentown area. We are in the process of preparing an application for the required Conditional Use and Board of Architectural Review approvals. We are aware that a backlog of applications for various approvals make it unlikely that we could come before the Planning Commission before April. Provided we obtained approval from the Planning Commission, the construction period to install the equipment is expected to take from one to two weeks. Given our bouts of system overloading and interrupted service, we are compelled to seek some immediate relief in the form of this request for approval of a Temporary Use for our facility. Background: The United States Congress, through the Federal Communications Commission (FCC), has mandated that Domestic Public Cellular Radio Telecommunications Service be provided through the issuance of two licenses in each of the 305 Metropolitan Statistical Areas and the 428 Rural Statistical Areas of the United States. One of these license is automatically granted to the local wireline telephone company, the other to an independent. McCaw Cellular Communications, Inc., (Cellular One) headquartered near Seattle, Washington, is the largest cellular telephone company in the United States. Through its regional and local subsidiaries, McCaw provides cellular telephone service to many areas of the country, serving a total population of over 40 million people. McCaw's size and national presence create opportunities and competitive advantages not available to smaller cellular telephone companies permitting the development of new technologies, improved customer service programs and favorable service rates. Cellular telephone service is a form of telecommunications capable of high quality, high capacity service to and from vehicle- mounted and hand -held radio telephones. The cellular concept was developed in order to provide quality mobile telephone service to a large subscriber base with nationwide Jack Pace Proposed Temporary Use December 21, 1990 Page -3- interconnect compatibility. A cellular system consists of several major elements. These are a Mobile Telephone Switching Office (MTSO), cell base sites (antennas), cell site interconnect facilities (which connect the MTSO with the cell sites), and cellular telephones. The McCaw Cellular Communications system in the Puget Sound area (as elsewhere) depends on a network of strategically placed cell base sites. A switching office monitors the signal strengths of calls in progress. As a caller moves from one cell base site and the signal strength of a call decreases, the computers automatically switch the call to the next cell base site which provides a stronger signal. A large well- designed cellular system is capable of handling thousands of calls at the same time, and can provide transmission quality comparable to conventional landline telephone service. Cell base sites are oriented geographically in a hexagonal grid pattern. Each cell site is located a certain distance from neighboring cell base sites so that it will provide service to a geographic area, based on multiple factors including traffic distribution, topographical features, radio interference concerns and quality. Accordingly, cell site locations are characteristically located in areas where the cell site is nearby to freeways or heavily travelled arterials where the line of sight between roadway and cell site is minimally obstructed and preferably away from hilltops and other prominent land features where radio towers are typically located to avoid inter - system interference. To provide system coverage in densely populated areas, the search area for a cell base site is quite small, often one -half mile or less in diameter, depending upon topographical factors, i.e., the presence of valleys, hills, bodies of water which either stop or extend radio coverage causing either a loss or "skipping" of radio propagation for long distances and thus destroying service by causing inter- system interference. In addition to the technical factors, McCaw must also locate property owners within these search areas which are willing to accept cell site facilities on their properties. McCaw Cellular Communications is experiencing increased demand for cellular telephone service in the Allentown area on Tukwila. There are approximately 50,000 cellular users in the Seattle area. This number is doubling every two and a half • • Jack Pace Proposed Temporary Use December 21, 1990 Page -4- years. Due to the fact the cell base site which services the Allentown area will reach capacity in the spring of 1991, the net result of the increased demand is rapidly worsening bouts of interrupted service in the area. To improve the existing network of cell sites to meet expanding demand, McCaw has received approvals to construct an additional 42 cell sites in the following jurisdictions: Bellevue, King County, Pierce County, City of Seattle, Snohomish County, Tacoma, City of Lynnwood, City of Redmond, Island County, San Juan County and the City of Tukwila. An additional 23 approvals are pending in Everett, Clallum County, Renton, City of Kent, Skagit County, Snohomish County and the City of Seattle. McCaw is also sensitive to aesthetic issues and has cooperated with a number of jurisdictions to minimize any undesirable visual impact of a cell site facility by altering the design of the tower and /or moving the sites where technical and physical limits allow. Cellular communications is an extremely low -power use, employing only a fraction of the power used by television and radio broadcasters. Thus, cellular communication systems are not a source of interference with consumer electronic equipment such as radios and televisions. On rare occasions such interference tends to be caused by high -power broadcast sources like radio and television broadcasters. The FCC has specific regulations and exclusive authority to regulate and require elimination of interference from such sources. Multiple cell site locations are needed to provide the coverage required by our FCC license for the Puget Sound area. McCaw Cellular Communications is currently operating over 80 cell sites around Puget Sound with no cases of television or radio interference reported. Any microwave transmission is also strictly controlled by the FCC in a similar manner so that interference is avoided. McCaw Cellular Communications has experienced no cases of interference relating to any of its currently operating microwave or cellular facilities. The primary users of cellular mobile telephone service area members of the business community and the public sector. The mobile telephone becomes a useful tool for the business community leading to increased productivity. The larger groups of cellular users include business owners and executives, professional managers, construction industry personnel and sales professionals. Additionally, mobile telephone service is extensively used in the public sector and others providing emergency services such as doctors, police and fire department • • Jack Pace Proposed Temporary Use December 21, 1990 Page -5- personnel. Public mobile telephone systems have become an essential portion of the public communications network. (See attached list of governmental agency users.) In particular they represent the most secure form of communication available for widespread usage to security and law enforcement officials. Cellular mobile telephone service allows police and others to conduct discreet (cellular frequencies cannot be easily monitored like normal police and federal law enforcement radio channels) communications in the field. Those having cellular mobile telephone service can and do contact the 911 to report accidents, fires and medical emergencies. The recent natural disasters of Hurricane Hugo in Charleston, S.C., and the earthquake in the San Francisco Bay Area attest to the reliability and performance to service rescue workers and the public alike (see attached letter from California Public Utility Commission). These are just a few of the uses of cellular mobile telephone service. We have included with this letter the above background material which we hope will be helpful in understanding the cellular technology and operational requirements under which Cellular One operates. If there are further questions, please contact me at 389 -5300. We respectfully request some indication from your office as to when we might expect to receive a response from the City on our request for approval of the temporary use. Sincerely, One lar • ■ ■■ ■ ■ ■• ■o. NUM I •••• ■ ■■s•■ • a■■■••■ • •1111■ •• • ■ ■MINIM Jack Pace Department of Community Development City of Tukwila 6200 Southcenter Blvd. Tukwila, WA. 98188, Dear Mr. Pace Cellular One is requesting permitting for a second cell site (Allentown) in the City of Tukwila. To describe the design criteria for this site, I will again refer to the four par -, ameters highlighted in my letter regarding our Southcenter application. 1) CAPACITY The Federal Communications Commission has granted cellular carriers a fixed amount of frequency spectrum. To utilize this allocation efficiently, a creative frequency plan, must` be developed and adhered to. Throughout a cellular system, frequencies are assigned to cell sites in a pattern that , allows for frequency reuse and smooth system growth. To::main tain this equilibrium, we must limit the number of channels': per cell. When traffic requires more channels at a cell than is designed, a new cell is required. In Spring of 1991, this scenario will occur in North Tukwila / South Seattle. The attached map shows the proposed Allentown cell in red. The S.E. sector of cell 29, highlighted in orange, will be congested in Spring of 1991. This sector serves I -5 from the Michigan street exit to the crest of I -5 as it descends to the 518 / I -405 exit. To alleviate this traffic congestion,,. the Allentown cell must be placed to serve the southern half of the described portion of I -5, thereby "sharing" the load with cell 29. Note: Cell 62 is located in Rainier Beach, behind Beacon Hill and cannot serve I -5. 617 Eastlake Avenue East P.O. Box 9159 Seattle, WA 98109 206/624 -5700 1 • I hope this explanation and the material presented in the Southcenter application helps in your department's assessment of our technical requirements as part of the Allentown appli- cation. Please contact me at 206 - 389 -5277 should you have any questions. Sincerely, Philip Cfxley Cellular Engineering Manager • • 2) INTERFERENCE PROTECTION The transmission pattern for cellular frequencies can best be described as "line of sight ". To minimize potential interfer- ence in the Puget Sound area, local terrain should be util- ized to restrict a cell's radiation pattern from extending beyond its designed service area. The proposed Allentown site meets this criteria. Beacon Hill to the north, Riverton Heights to the West, the Tukwila Hill to the South and the Skyline Hill to the East effectively contain the radiation pattern of the topographically low site in Allentown. 3) TRAFFIC DISTRIBUTION The proposed Allentown site has been chosen between I -5 and highway 599 to distribute traffic efficiently amoung its 3 sectors. The north and southeast sectors split responsibility for I -5 service and the southwest sector serves highway 599 & higway 99. Placement of the Allentown cell southeast of I -5 or southwest of 599 would result in congestion of one sector and a need for an additional capacity cell in a timeframe shorter than planned. 4) QUALITY OF SERVICE The Allentown cell is part of a lone term quality project that will allow for the deinstallation of two nearby cells that, if left on the air, will create frequency reuse prob- lems as our system grows. This scenario would cause a deg- radation of service quality system wide. Cells 5 and 11 were constructed in 1985 as part of the initial system configu- ration. These cells were designed to cover large service areas since subscribers (and revenues) were smaller.They have radiation patterns that are not contained by local topography and, therfore, do not meet the design criteria of cells such as Southcenter and Allentown. To deinstall tall sites such as these, smaller cells must be carefully placed to meet the coverage and capacity requirements that the tall sites pro- vide. As the small cells are constructed, the tall sites will be deinstalled sector by sector. Allentown will allow for re- moval of the north sector of cell 5 and the southwest sector of cell 11, highlighted in yellow. 27 39 • • 29 62 Ar 5 45 71 11 gn CITY OF TUKWILA COMMUNITY DEVELOPMENT DEPARTMENT Environmental Checklist -/oi - / - 9l7- 411g1A0oo A. BACKGROUND 1. Name of proposed project, if applicable: Allentown Cellular Communications Site Temporary facility 2. Name of applicant: Interstate Mobilephone Company d /b /a Cellular One 3. Address and phone number of applicant and contact person: Carol Rohde Cellular One 617 Eastlake Avenue East Seattle, WA 98109 389 -5300 4. Date checklist prepared: December 20, 1990 5. Agency requesting checklist: City of Tukwila, Community Development Department 6. Proposed timing or schedule (including phasing, if applicable): Temporary Site Construction - one to two weeks 7. Do you have any plans for future additions, expansion, or further activity related to or connected with this proposal? If yes, explain. Yes. The applicant will apply to place a permanent communication facility at the same site. The temporary facility will be removed once permanent facility is operational. An environmental checklist for the permanent facility will be provided with the application for the permanent cell site. 8. List any environmental information you know about that has been prepared, or will be prepared, directly related to this proposal. 1 • • A soils analysis is being prepared by Rittenhouse Zeman Associates, and will be submitted with the permanent application. 9. Do you know whether applications are pending for governmental approvals of other proposals directly affecting the property covered by your proposal? If yes, explain. None known. 10. List any governmental approvals or permits that will be needed for your proposal, if known. Temporary Use approval Conditional Use approval for the Permanent Facility Architectural Review Board for the Permanent Facility FAA pending 11. Give brief, complete description of your proposal, including the proposed uses and the size of the project and site. There are several questions later in this checklist that ask you to describe certain aspects of your proposal. You do not need to repeat those answers on this page. (Lead agencies may modify this form to include additional specific information on project description.) Place a 100' wooden telephone pole with 12 directional antennas not to exceed the height of the telephone pole, and install a 12' X 28' electronic equipment vault. The approximate 2,500 square foot lease area (50'X50') will be cleared of vegetation. A 6' high security fence with 2' of barbed wire on top will surround the site. The cleared area inside the fence will be finished with gravel. A landscape plan for perimeter shrub plantings will be provided with the permanent application and will screen the equipment vault and base of the telephone pole. The permanent cell site will occur at the same location. A permanent wooden telephone pole and electronic equipment vault will be part of the permanent site. The environmental information related to the permanent site will be provided in an environmental checklist which will accompany the permanent site application to the City of Tukwila. 12. Location of the proposal. Give sufficient information for a person to understand the precise location of your proposed project, including a street address, if any, and section, township, and range, if known. If a proposal would occur over a range of area, provide the range or boundaries of the site(s). Provide a legal description, site plan, vicinity map, and topographic map, if reasonably available. While you are not required to duplicate maps or detailed plans submitted 2 • • with any permit applications related to this checklist. Site lies northwest of 51st Place S and north of 124th Street. It is located directly southwest of Northern Pacific Railroad Company right -of -way. Site address is 12560 51st Place S, Allentown, WA. 13. Does the proposal lie within an area designated on the City's Comprehensive Land Use Policy Plan Map as environmentally sensitive. No. B. ENVIRONMENTAL ELEMENTS 1. Earth a. General description of the site (circle one)(lat hilly, steep slopes, mountainous, other �— rolling, • b. What is the steepest slope on the site (approximate percent slope) ? Less than 2% on site. Northeast of the site is an approximately 15 foot high railroad embankment. c. What general types of soils are found on the site (for example, clay, sand, gravel, peat, muck)? If you know the classification of agricultural soils, specify them and note any prime farmland. The soil is generally sandy. A soils report is being prepared and will be submitted with the permanent application. d. Are there surface indications or history of unstable soils in the immediate vicinity? If so, describe. No surface indications of unstable soils are present. e. Describe the purpose, type, and approximate quantities of any filling or grading proposed. Indicate source of fill. Some clearing will occur to remove grass and shrubs. f. Could erosion occur as a result of clearing, construction, or use? If so, generally describe. A minimal area of approximately 2,500 square feet of area will be cleared. A temporary erosion control fence will be added around the southeast and northeast portions of the leased site to filter silt and sediment. Storm water is expected to sheet flow to an existing open ditch conveyance system to the northeast side of the site, or to be absorbed into the ground. The site is flat, and not susceptible to erosion by its 3 • topography. If erosion occurs during construction, straw bales or other erosion control materials will be placed at the edge of the property line to filter out any sediments that result from construction. g. About what percent of the site will be covered with impervious surfaces after project construction (for example, asphalt, or buildings)? The temporary facilities will introduce approximately 350 square feet of impervious surface for the electronic equipment vault and base of the wooden telephone pole. The balance of the site will be covered with gravel, shrubs and grasses. The property contains 10,005 square feet. The cellular facility will add 350 additional square feet of impervious surface for a total coverage of approximately 3.5% square feet of the entire property. h. Proposed measures to reduce or control erosion, or other impacts to the earth, if any: Typical erosion and sedimentation control measures (hay bail or other appropriate materials and a temporary erosion control fence on the northeast and southeast portions of the site) will be implemented in accordance with City regulations for the building permit. 2. Air a. What types of emissions to the air would result from the proposal (i.e., dust, automobile, odors, industrial wood smoke) during construction and when the project is completed? If any, generally describe and give approximate quantities if known. Light vehicular traffic during 1 to 2 weeks of construction. Approximately one trip every other week (2 vehicle trips per month) will be generated by the facility for maintenance purposes. b. Are there any off -site sources of emissions or odor that may affect your proposal? If so, generally describe. None known. c. Proposed measures to reduce or control emissions or other impacts to air, if any: None. 3. Water 4 a. Surface 1) Is there any surface water body on or in the immediate vicinity of the site (including year -round and seasonal streams, saltwater, lakes, ponds, wetlands)? If yes, describe ,type and provide names. If appropriate, state what stream or river it flows into. The Duwamish River is located approximately a quarter of a mile north of the site. The site does not lie within a floodway or floodplain of this river. 2) Will the project require any work over, in, or adjacent to (within 200 feet) the described waters? If yes, please describe and attach available plans. No 3) Estimate the amount of fill and dredge material that would be placed in or removed from surface water or wetlands and indicate the area of the site that would be affected. Indicate the source of fill material. Not applicable 4) Will the proposal require surface water withdrawals or diversions? Give general description, purpose, and approximate quantities if known. No 5) Does the proposal lie within a 100 -year floodplain? If so, note location on the site plan. No 6) Does the proposal involve any discharges of waste materials to surface waters? If so, describe the type of waste and anticipated volume of discharge. No. This is an unmanned site and requires no waste disposal. b. Ground 1) Will ground water be withdrawn, or will water be discharged to ground water? Give general description, purpose, and approximate quantities if known. No 2) Describe waste material that will be discharged into the ground from septic tanks or other sources, if any (for example: Domestic Sewage; industrial, containing the following 5 • chemicals...; agricultural; etc.). Describe the general size of the system, the number of such systems, the number of houses to be served (if applicable), or the number of animals or humans the system(s) are expected to serve. None. No waste material is produced by this proposal. The site is unmanned, thus no water or sanitary sewage service is required. c. Water Runoff (including storm water): 1) Describe the source of runoff (including storm water) and method of collection and disposal, if any (include quantities, if known). Where will this water flow? Will this water flow into other waters? If so, describe. Negligible runoff will result from the addition of approximately 350 square feet of impervious area around the base of the temporary pole and under the electronic equipment vault. There is an open ditch conveyance system on the northeast side of the site which will handle roof runoff. 2) Could waste materials enter ground or surface waters? If so, generally describe. No waste materials will be generated on the proposed site. d. Proposed measures to reduce or control surface, ground and runoff water impacts, if any: A temporary erosion fence will be installed for the temporary installation. It will consist of a mesh fence 1' into the ground and extending 3' above ground. Granular rock will be placed on top of the mesh fencing to help filter silt and sediment caused by water runoff. 4. Plants a. Check or circle type of vegetation found on the site: deciduous tree: alder, maple, aspen, other X evergreen tree: fir, cedar, pine, other X shrubs X grass pasture crop or grain wet soil plants: cattail, buttercup, bullrush, skunk cabbage, other water plants: water lily, eelgrass, milfoil, other 6 • • other types of vegetation b. What kind and amount of vegetation will be removed or altered? The construction of the wooden telephone pole and installation of the electronic equipment shelter will require removal of grasses, berry vines and shrubs. c. List threatened or endangered species known to be on or near the site. None known. d. Proposed landscaping, use of native plants, or other measures to preserve or enhance vegetation on the site, if any: Landscaping will be placed around the perimeter of the cellular facility after construction of the permanent facility is complete. The landscaping will provide screening for the electronic equipment vault and the base of the wooden telephone pole. 5. Animals a. Circle any birds and animals which have been observed on or near the site or are known to be on or near the site: birds: hawk, heron, eagle, other: mammals: deer, bear, elk, beaver, other: fish: bass, salmon, trout, herring, shellfish, other claps 4 e iy b. List any threatened or endangered species known to be on or near the site. None known c. Is the site part of a migration route? If so, explain. Not known d. Proposed measures to preserve or enhance wildlife, if any: Not applicable 6. Energy and Natural Resources a. What kinds of energy (electrical, natural gas, wood stove, solar) will be used to meet the completed 7 • • project's energy needs? Describe whether it will be used or heating, manufacturing, etc. Electrical. The telephone pole will require 20 -40 watt service. There will be 12 directional antennas located on the top of the temporary pole. Electricity and telephone service for electronic equipment will be necessary. b. Would your project affect the potential use of solar energy impacts, if any: No. The temporary pole will not obstruct sunlight from other structures. c. What kinds of energy conservation features are included in the plans of this proposal? List other proposed measures to reduce or control energy impacts, if any: None 7. Environmental Health a. Are there any environmental health hazards, including exposure to toxic chemicals, risk of fire and explosion, spill, or hazardous waste, that could occur as a result of this proposal? If so, describe. No material that could cause fire or explosion are known. Cellular radio power density levels are regulated by government as a potential environmental concern. Radio frequency emissions from the Allentown "cell site" facility will be at 869 to 880 megahertz and 18 gigahertz for the radio link transmissions to the mobile telephone switching office in Seattle. The transmissions will be low power with less than 45 watts for cellular radios and 0.1 watts for the 18 gigahertz radio link. As such, the radio frequency power density levels near the cellular telephone pole (10 feet above ground below the telephone pole) will be extremely low and several magnitudes below existing maximum permissible human exposure standards. The maximum cellular radio transmission radio frequency power density will be 1.3 microwatts per square centimeter at the telephone pole base while the maximum 18 gigahertz radio link radio frequency power density would be less than 0.0014 microwatts per square centimeter. By comparison the recommended maximum exposure levels by the Federal Communications Commission and American National Standards Institute (ANSI) are 2,800 microwatts per square centimeter. King County, for instance, has proposed a much more conservative standard of 200 microwatts per square centimeter which still 8 • s exceeds the highest level emitted by the proposed Allentown "cell site" by a factor of 154. These very low power levels and ultra high frequencies at which the "cell site" transmissions occur also eliminate any potential for interference to other electronic devices such as radio, television, VCR's, telephone and medical devices such as pacemakers (which are internally shielded by the manufacturers to withstand over 2,800 microwatts /sq. centimeter. This is born out by our cellular telephone network which has experienced no reported cases of interference to such devices. More over, should any obscure circumstances result in interference from the cell site transmissions the Federal Communications Commission exercises absolute and exclusive authority to require us to immediately correct any such interference even if it means turning off the offending transmitter. 1) Describe special emergency services that might be required. None required. Emergency services will be enhanced by cellular phone service by providing emergency service vehicles with mobile communications potential. 2) Proposed measures to reduce or control environmental health hazards, if any: None are anticipated to be necessary. b. Noise 1) What types of noise exist in the area which may affect your project (for example: traffic, equipment, operation, other). None. The existing noises will not affect this project. 2) What types and levels of noise would be created by or . associated with the project on a short -term or a long- term basis (for example: traffic, construction, operation, other)? Indicate what hours noise would come from the site. There will be some traffic noise associated with the installation of the cellular telephone pole and electronic equipment vault which will occur during the one to two week construction period. Minimal noise impact shall be generated by the cell site and would consist of twice monthly maintenance visits and sound from the air conditioning units in the electronic equipment vault. 9 • • 3) Proposed measures to reduce or control noise impacts, if any: Hours of construction will be limited to between 7:00 AM and 7:00 PM, Monday through Saturday. 8. Land and Shoreline Use a. What is the current use of the site and adjacent properties? The property currently contains approximately 1/3 of an existing house on the northern property line. The remainder of the property is a vacant lot. North - single family home South - single family home West - single family home East - Northern Pacific Railroad right -of -way b. Has the site been used for agriculture? If so, describe. No c. Describe any structures on the site. The southern 1/3 of an existing single family home. d. Will any structures be demolished? If so, what? No e. What is the current zoning classification of the site? M -2 (Heavy Industrial) f. If applicable, what is the current comprehensive plan designation of the site? g. Heavy industrial If applicable, what is the current shoreline master program designation of the site? Not applicable h. Has any part of the site been classified as an "environmentally sensitive" area? If so, specify. No i. Approximately how many people would reside or work in the completed project? 10 J • • None. This site will be unmanned. Semi - monthly maintenance visits will involve one person. Approximately how many people would the completed project displace? None k. Proposed measures to avoid or reduce displacement impacts, if any: None 1. Proposed measures to ensure the proposal is compatible with.existing and projected land uses and plans, if any: The immediate surrounding land uses to the west, north and south are single family residential houses. However, approximately 100 feet to the northwest on 51st Place S is a construction company (see photos). Along the eastern side of the site is located the Northern Pacific Railroad Trucking Company (see photos). The pole and equipment vault would be compatible with these uses. Wooden telephone poles presently exist in the immediate area of the site. The cellular telephone pole would be compatible with these existing poles. The site will be located at the rear of the property as far away from the single family residences as possible. An existing 15' high embankment will be located along the eastern side of the site and further help to minimize the visual impact of the site. Landscaping will be added to the perimeter of the site to help buffer and screen the electronic equipment vault and base of the telephone pole. 9. Housing a. Approximately how many units would be provided, if any? Indicate whether high, middle, or low- income housing. Not applicable b. Approximately how many units, if any, would be eliminated? Indicate whether high, middle, or low- income housing. Not applicable c. Proposed measures to reduce or control housing impacts, if any: Not applicable 10. Aesthetics 11 • • a. What is the tallest height of any proposed structure(s), not including antennas; what is the principal exterior building material(s) proposed? The height of the temporary telephone pole will not exceed 100'. The telephone pole will be treated wood. Located at the top of the wooden telephone pole will be 12 directional antennas which will not exceed the top of the pole. The equipment vault will be under 10 feet. b. What views in the immediate vicinity would be altered or obstructed. None. c. Proposed measures to reduce or control aesthetic impacts, if any: The structures will be setback from the road and as far from any residences as possible. Vegetative screening will be provided around the perimeter of the cell site (just outside the proposed security fence). This screening will conceal the fence, vault and base of the telephone pole. The temporary facility will be replaced by a proposed permanent cellular telephone pole and electronic equipment vault. 11. Light and Glare a. What type of light or glare will the proposal produce? What time of day would it mainly occur? The height of the pole has been filed with the FAA and no determination has been received. The telephone pole will not be lighted unless required by state or federal agencies. No other light will be generated by the proposal. b. Could light or glare from the finished project be a safety hazard or interfere with views? No c. What existing off -site sources of light or glare may affect your proposal? None d. Proposed measures to reduce of control light and glare impacts, if any: 12 • • None are anticipated to be necessary 12. Recreation a. What designated and informal recreational opportunities are in the immediate vicinity? Not applicable b. Would the proposed project displace any existing recreational uses? If so, describe. No c. Proposed measures to reduce or control impacts on recreation, including recreation opportunities to be provided by the project or applicant, if any: None 13. Historic and Cultural Preservation a. Are there any places or objects listed on, or proposed for, national, state, or local preservation registers known to be on or next to the site? If so, generally describe. None known b. Generally describe any landmarks or evidence of historic archaeological, scientific, or cultural importance known to be on or next to the site. None known c. Proposed measures to reduce or control impacts, if any: Not applicable 14 Transportation a. Identify public streets and highways serving the site, and describe proposed access to the existing street system. Show on site plans, if any. 51st Place S, S 124th Street and S 122nd Street serve the site. I -5 and Martin Luther King Jr. Way S serve the area surrounding the site. b. Is site currently served by public transit? If not, what is the approximate distance to the nearest transit stop? Not applicable c. How many parking spaces would the completed project have? 13 • How many would the project eliminate? The project will provide one parking space for the semi- monthly maintenance visits. These maintenance visits will require one car to be parked in the proposed parking area with no adverse impacts. d. Will the proposal require any new roads or streets, or improvements to existing roads or streets, not including driveways? If so, generally describe (indicate whether public or private). No e. Will the project use (or occur in the immediate vicinity of) water, rail, or air transportation? If so, generally describe. The site will not require these transportation means. There is an existing Northern Pacific Railroad right -of- way to the east of the site. f. How many vehicular trips per day would be generated by the completed project? If known, indicate when peak volumes would occur. One vehicle semi - monthly. g. Proposed measures to reduce or control transportation impacts, if any: None will be required as a result of low impact by proposed construction. 15. Public Services a. Would the project result in an increased need for public services (for example: fire protection, police protection, health care, schools, other)? If so, generally describe. No. The electronic equipment vault is unmanned with self - extinguishing fire protection (halon system). The equipment shelter and pole are alarmed and monitored 24 hours a day 7 days a week by an operations center. b. Proposed measures to reduce or control direct impacts on public services, if any. None are anticipated to be necessary. 16. Utilities 14 a. Circle utilities currently available at the site: septic system, other. b. Describe the utilities that are proposed for the project, the utility providing the service, and the general construction activities on the site or in the immediate vicinity which might be needed. Electricity - Puget Power Telephone - U. S. West Communications C. SIGNATURE The above answers are true and complete to the best of my knowledge. I understand that the lead a•_ ncy is relying on them to make its decision. Signature: Date Submitted: 15 • • 7 E. SUPPLEMENTAL SHEET FOR ALL PROJECT AND NON PROJECT PROPOSALS The objectives and the alternative means of reaching the objective for a proposal will be helpful in reviewing the aforegoing items of the Environmental Checklist. This information provides a general overall perspective of the proposed action in the context of the environmental information provided and the submitted plans, documents, supportive information, studies, etc. 1. What are the objective(s) of the proposal? The goals of the proposal are: o to provide improved cellular service and alleviate traffic congestion in the North Tukwila and South Seattle areas; o to locate both the temporary facility and the permanent facility on the same site, and remove the temporary site once the permanent cell site is activated. 2. What are the alternative means of accomplishing these objectives? Alternative means to these objectives are not currently available. Cell sites are oriented geographically in a hexagonal grid pattern. Each cell base station is located a certain distance from neighboring cell base sites so that it will provide service to a specific geographic area, based on multiple factors including; traffic distribution, topographical features, radio interference concerns and quality. Accordingly, cell site locations are characteristically located in areas where the cell site is nearby to freeways or heavily travelled arterials, where the line -of -sight between roadway and cell site is minimally obstructed, and preferable away from hilltops and other prominent land features where radio towers are typically located to avoid intersystem interference. To provide system coverage in densely populated areas, the search for a cell base site is quite small, often one -half mile or less in diameter, depending upon topographical factors, i.e. the presence of valleys, hills, bodies of water which either stop or extend radio coverage causing either a loss of service or a "skipping" of radio propagation for long distances and thus destroying service by causing intersystem interference. The Allentown area is presently serviced by the Tempress cell site. This site has almost reached capacity, and will be unable to provide quality transmission service to the north Tukwila /south Seattle areas. The result will be a loss of call integrity, causing mobile phone subscribers to experience • • "dropped" calls while in the Allentown area. The proposed Allentown site has been chosen between I -5 and Highway 599 to distribute traffic efficiently. The I -5 corridor in this area is a key factor in locating the site at the proposed location. Much like the growth pressure experienced from new businesses locating in Tukwila, McCaw Cellular Communications is experiencing increased public demand for cellular telephone service. There are approximately 60,000 cellular users in the Seattle area. This number is doubling every two and one -half years. In the Tukwila area, the net result of increased demand is the rapidly worsening bouts of interrupted service in this area. Once a grid pattern is located, site acquisition looks at individual properties within the search area to locate the optimum cell site. These properties must be of adequate size to contain the 350 square foot electronic equipment shelter and a structure upon which the cellular radio antennas and interconnecting cell site radio link antennas are mounted. The cell site property search follows a set of order of location preferences based upon a desire to maximize the cell sites compatibility with surrounding land uses and zoning codes. These location preferences are listed below by preference. 1. existing broadcast communications structures; 2. existing water towers 3. existing high rise office, commercial and industrial buildings where antennas can be mounted on roof tops and electronic equipment within; 4. bare /open land zoned for industrial, commercial or public utility use which can be leased or purchased; 5. property with the least residential population density and /or property that will provide natural screening to the public at large. Each site must also be determined to be technically feasible for covering the cell based upon engineering elevation requirements and actual signal strength measurements made from a temporary test cellular radio transmitter and antenna placed at the site. The site's physical characteristics are also evaluated and approved by surveyors, soils testing, title search and field investigation by architects and civil engineers who will prepare final site and building plans. 3. Please compare the alternative means and indicate the preferred course of action. The majority of the search area for this site were zoned residential. An exhaustive search for appropriately zoned properties was conducted. Given this in depth search for a suitable location, no alternative to the proposal will achieve the objectives. The preferred course of action is the proposal. • • 4. Does the proposal conflict with policies of the Tukwila Comprehensive Land Use Policy Plan? If so, what policies of the plan. There are no specific goals and policies of the Tukwila Comprehensive Plan which address this type of utility. However, the proposal does improve the overall cellular system by increasing capacity and providing the users traveling to, from or through the Allentown area with improved quality of service which is a general goal of the Comprehensive Plan for the Transportation /Utility Element of the Plan. Proposed measures to avoid or reduce the conflict(s) are: No conflict will occur. LEGAL DESCRIPTION OVERALL PROPERTY DESCRIPTION Lots 9, 10, 11 and 12, Block.11, Plat of Allentown addition to City of Seattle, according to the plat thereof recorded in Volume 12 of Plats, Page 100, records of King County, Washington; Except the Northwesterly 13 feet of Lot 9, Situated in the County of King, State of Washington. LEASE DESCRIPTION That portion of Lots 9, 10, 11 and 12 Block 11, Plat of Allentown addition to the City of Seattle, according to the Plat thereof recorded in Volume 12 of Plats, Page 100, Records of King County, Washington, described as follows: Commencing at the Northwest Corner of the above - described parcel; Thence S 32 degrees 31' 24" E along the Southwest line of said Block 11, A distance of 47.00 feet; Thence N 57 degrees 28' 36" E, a distance of 53.47 feet to the point of beginning; Thence N 32 degrees 31' 24" W, a distance of 25.00 feet; Thence N 57 degrees 28' 36" E, a distance of 50.00 feet; Thence S 32 degrees 31' 24" E, a distance of 50.00 feet; Thence S 57 degrees 28' 36" W, a distance of 50.00 feet; Thence N 32 degrees 31' 24" W, a distance of 25.00 feet; To -the Point of Beginning. INGRESS, EGRESS, AND UTILITY EASEMENT DESCRIPTION That portion of Lots 9, 10, 11 and 12, Block 11, Plat of Allentown addition to City of'Seattle, according to the plat thereof recorded in Volume 12 of Plats, Page 100, records of King County, Washington, included in a 15.00 foot wide strip of land lying 7.50 feet on each side of the following described centerline: Commencing at the Northwest corner of the above described parcel; Thence S 32 degrees 31' 24" E along the Southwest line of said Block 11, a distance of 47.00 feet to the Point of Beginning of said centerline and said easement; Thence N 57 degrees 28' 36" E, a distance of 53.47 feet to a terminus of said centerline and said easement. STATE OF WASHINGTON GEORGE B. TELLEVIK Chief WASHINGTON STATE PATROL General Administration Building, AX -12 • Olympia, Washington 98504-0612 • (205) 753 -6540 • (SCAN) 234 -6540 July 31, 1990 Mr. Craig Latticer Director of Community Development Snohomish County 5th Floor Administration Building Everett, WA 98201 Dear Mr. Latticer: This letter is in reference to an application for a new cellular cell site in the Lake Stevens area of Snohomish county. This is to inform you that the Washington State Patrol communications centers, on a statewide basis, are the primary answering points for emergency 9 -1 -1 calls made from mobile cellular telephones. During fiscal year 1990, our Everett office received an average of 830 of these calls per month. Sincerely, CHJ EF GEORGE B. TELLEVIK thJ( �� L David K. Gosk Communications Director DKG:blj cc: Major R. A. Morris, Telecommunications Division • • International Chaplains' Ministry Fiarnor Scare 110 West Dayton Street Post Office Box 476 Edmonds. Washington 98020 -0476 (206) 774 -9544 May 3, 1990 CELLULAR ONE 210 Elliott Avenue West Suite 220 Seattle, WA 98119 Dear Friends: It really seems hard to believe but it has been almost five years now since Support 7 was first introduced to the community - and your gift of the cellular telphone service was made available to us and so graciously received. I can't begin to tell you how many times over these few years I have been at the scene of some event of crisis and thought of you and offered thanks for your significant part in this distinct vehicle of ministry and service. It is still extremely well- maintained and cared continues to be housed at Lynnwood's Fire Station #1. 7 regularly appears with its special crew at scenes of the "heaviest of events" - fires, major accident along with a variety of search and rescue operations. Though we have tried to keep somewhat of a "low profile" to maintain a degree of integrity with our service - often the unit becomes the subject of news articles, such as the enclosed story that appeared in this month's edition and national publication of American Fire Journal. Also, you might be interested in the enclosed letter received this week which further expresses the continued appreciation from emergency service organizations. Friends, may I just pause again to tell you thanks - thanks for all you have done to make this program and ministry eeffective - especially to families to whom a sudden crisis has come. for and Support of some sights, Serving Fire and Medical Aid Departments Emergency Medical Services Search and Rescue Units Office of Coroners and the Communities They Serve • • CELLULAR ONE May 3, 1990 Page Two If you would like any further update details or information, please don't hesitate to call me. Beca se of His grace, aydos P.S. Being at the "death sce e" so many, many times in the course of a month, I realize the brevity of life and the suddenness of which that life can be taken. A friend, Charles Swindoll, has written some very provocative thoughts about the subject of life and death. This book has been significantly meaningful to me and I want to pass it along to you. Enclosures KG /lr • . SNOHO ISH COUNTY SHERIFF'S OFFICE J. I. SCHARF, Sheriff LP. REED, Undersheriff Chaplain Ken Gaydos P.O. Box 476 Edmonds, Washington 98020 Dear Chaplain Gaydos: FOURTH FLOOR COUNTY COURTHOUSE EVERETT, WASHINGTON 98201 -4060 • (206) 388 -3393 April 23, 1990 I want to take this opportunity to thank you and your Support -7 team for your outstanding work during our recent search for two men and their vehicle missing in the Snohomish River. Your prompt and professional response to that incident was a great comfort to family and friends of the missing men. Further, I am aware that your refreshments and portable telephone were also made available to the divers, support personnel and the media. The goodwill and positive image presented by you and your team had a beneficial impact on everyone involved. Your help with the family and friends of the victims during the critical recovery phase was particularly important. The strength, comfort and refuge which was provided for those in grief significantly contributed to the completion of the recovery process. Finally, I want to express my gratitude for the support provided to the members of the Sheriff's Office dive team. Throughout the search, these men were hampered by foul weather, poor underwater visibility and the scrutiny of media. Your gestures on their behalf are greatly appreciated. You and your entire Support 7 team are a valuable resource to Snohomish County. Keep up the good work! JIS:EAW:an Sincerely, ;4 ES I. SCHARF Snohomish County eriff AMERICAN FIRE JOURNAL INNOVATIONS • • ('ninon tulewski, Support 7 attendant, siaJjs the canteen. Support 7 Caul be set up cu the emergency site. Chaplain Program, "Shelter Van" Provide Bereavement Aid in WA We have all experienced it. It can happen anywhere, on the streets, in someone's home, at a local business. It is a sick and empty feeling. Nor - mally, you are lost for words. It' you dig deep enough you manage to put together a few consoling sentences. Afterwards, you assure yourself, and perhaps your partners, that you did the hest you could. No matter how well you did your job, it is never an easy task when you must comfort the relatives and loved ones of a patient that you have treated or auentpted to treat. How do you tell a young Mother and children that their husband and father could not he saved? Huw do you tactfully obtain report information from a lonely 70- ycar -old than who has just lost his wife of 5(1 years in an automobile accident? flow do you cairn the parents of a little girl who was badly burned in a house fire? "(lie answers to these questions are not likely found in training films or hardbound textbooks. Generally, the :answers are found in our hearts and our souls. Sonic of us have a natural ability to compassionately express our deep sorrow for someone's Toss. Others have difficulty in choosing the right words and may come across uninten- tionally as cold and insensitive. The Edmonds t=ire Department has taken an innovative approach to deal - ing with the victim's family and loved ones. Since the early 1970s, its Chap- 1 n.• Jrnmcd April 10911 By BOB SCHMITT Senior FF. Edmonds (WA) F.D. Photos courtesy of Intl. Chaplain'• Ministry. lain Program has been a vital part of this community's lire department de- livery system. The Chaplain Program has been so successful, that the concept has gradually spread to surrounding communities throughout the state of Washington. It is presently recog- nized on a national and Canadian level. The Chaplain Program places highly skilled individuals at the scene of tragedy within minutes of the first - arriving fire department personnel. While the EMTs and paramedics tend to victims, the duty chaplain cares for the victim's family and loved ones. The key person behind this success- ful program is Ken Gaydos. In 1971, Gaydos became the department chap- lain. Upon accepting the post, Gaydos asked that he be allowed to expand his service beyond the usual cere- monial role. It took only one house fire for Gay - dos to realize what direction his ex- panded services should follow. As he stood by with a pajama -clad family watching their house go up in flames, he felt helpless that all he could offer were a few sympathetic words. Within a year, the Chaplain Pro- gram had evolved to include a small corps of volunteers who had secured support from the community of Ed- monds. Local merchants provided a network of resources to meet the im- mediate needs of families in crisis. Lodging, food and clothing were now available to the homeless, pajama - clad families. TIC Red Cross and the Salvation Army also established ties with the Chaplain Program. The name "Chaplain Program" may be misleading. Even though all the volunteers have deep religious be- liefs, they are not all ordained min- isters, priests or chaplains. The in- dividuals do not impose their beliefs on the families of the victims. The chaplains try to determine the needs of the families in crisis. Some may have spiritual needs, but others may only require physical help. Over the years, the program con- tinued to grow. Neighboring com- munities and counties were modeling their chaplain programs after the pro- gram in Edmonds. Eventually, be- cause of the overwhelming amount of inquiries throughout the states, Gaydos quit his runtime career as a radio and television broadcaster. He now directs International Chaplain's Ministry, which organizes similar programs in Canada and the United States. It is estimated the ministry has helped or assisted in establishing chap- lain programs in over 200 communi- ties ranging from small, rural all - voluntary fire departments to large metropolitan tire departments. In 1984, Gaydos queried Chief Weinz about the disposition of an about- to -be- retired aid van. Gaydos Continued on page 50 , INNOVATIONS Continued from page 26 1 • had the idea to convert the old aid van into a "place of refuge" –a place away from reporters, cameras and gawking onlookers. Up until now, the chaplain could only offer the back seat of a patrol car to shelter the "other victims." Once again, Gaydos' ideas blos- somed into reality with the overwhelm- ing support of the surrounding com- munities. The old aid van was pur- chased by the local Kiwanis Club and donated to the International Chap- lain's Ministry. The interior of the van was gutted and converted into a peaceful, mobile living room. Full mobile telephone service was donated and installed. A small kitchen facility was con- structed towards the rear of the van. Volunteers spent hours preparing the body for a new coat of paint. In all, over 40 agencies and individuals con- tributed to the Support 7 project. Support 7 was placed in service on The van is furnished as u comfort- able retreat. January 1, 1986. The van responds to approximately two calls a week, serv- icing the cities of Edmonds, Lynn- wood, Mountlake Ten-ace, Woodway, Brier and also Snohomish County t=ire District #1 and King County Fire District #4. Upon special request the van will respond to farther points in the Puget Sound area. The van is automatically dispatched through the 911 emergency dispatch center for specific types of calls, i.e., vehicle accidents, residential and com- mercial fires, and natural disasters. It will also be dispatched to any other emergency at the request of the on- scene commander. By now, some of you may be think- ing that the Support 7 group is ac- tually duplicating the work of such organizations as the Red Cross and the Salvation Army, but, as Gaydos explains, "We work hand in hand with these organizations. The Red Cross and Salvation Army provide the resources to handle mass- casualty incidents, while Support 7 exists pri- marily for the single family. If our local resources are used up we can generally rely on the larger support group to help out." For more inf ornwtion regarding the International Chaplain's Ministry or Support 7. comae: Ken Gaydos, P.O. Box 476, Edmonds, WA 98020. (20) 774 -9541. CREATIVE . . • Continued from page 47 MINI) JOGGERS TO INCREASE FIRE SERVICE CREATIVITY Problems: • Fears? • Bottlenecks? • Anxieties? • Performance? • Happiness ?? • Safety? • Waste'' • Attitudes? • Goals? • Values', • Needs? _._. •' 'Stress points? • Complexities? • Mistakes? • Hopes and desires? • Routine? • Improvements? • Complications? • Inefficiencies' • Misunderstandings? Solutions ?: • • • • • • • • • • • • • • • • • • • IDEA ACCEPTANCE CHECKLIST Acceptance: In what way might l gain acceptance fur my idea? Anticipation: How might I overcome anticipated objections? Assistance: In what ways Wright other firefighters or professional groups assist me? Locations: What places or locutions might be advantageous? Timing: In what ways Wright I use special times, dates, etc.? Precautions: Whit measures might lest my best idea? Would my idea still sound good if it came from some - one else? PROBLEMS /NEEDS LIST • What is the problem? • Why is it a problem? • What is the real problem? • What are the needs of everyone involved? • What is the -main need that, if not properly satisfied, makes ful- filling all the other needs pointless? • Which of the needs are vital? • Which of the needs are very im- portant? • Which of the needs are important? • Which of the needs are merely desirable? • Which of the needs are unimpor- tant? • if the problem is solved — then what? IDEA- FINDING CHECKLIST Adapt – New ways to use present sit- uation? Other uses if modified? Modify –New changes or modifica- tions'? Magnify – What to add? How to make stronger? Minimize – Subtract? Lighten'? Substitute –Who else instead? What else instead? Rearrange – Interchange compo- nents? Other sequence? Reverse – Transpose positive and negative? Combine –A blend? Combine ideas? Continued on page 52 • Public Utilities Tom STATE OF C A L I F O R N COMMISSIONER November 1, 1989 Craig McCaw Chairman McCaw Cellular Communications, Inc. P.O. Box 97060 Kirkland, WA 98083 -9760 Dear Craig: I.am writing on behalf of my colleagues to congratulate and commend McCaw Cellular Communications and Bay Area Cellular Telephone Company (BACTC) for your immediate and effective assistance throughout the affected area during the recent earthquake disaster. Two aspects of McCaw's response stand out for special commendation. First, you took all steps necessary to keep service up despite the loss of power in the region and the damage suffered by some of BACTC's facilities. As a result, vital mobile communications were handled at volumes that reached twice normal. Second, McCaw and BACTC immediately began distributing telephones to emergency personnel and arranging with manufacturers to supply, ultimately, over 2000 cellular phones in less than 48 hours. These telephones proved essential in coordinating emergency relief efforts throughout the region. I know that these efforts started at the top with your personal involvement along with other McCaw executives, staff and technicians. Within hours of the earthquake, private and chartered planes began arriving at Oakland Airport carrying cellular phones, emergency equipment and the people needed to make it work. This past Monday John McCaw reported personally to me about your efforts and McCaw's contining commitment to California. I must say that McCaw's emergency response was a convincing reaffirmation of that commitment. Ir. Craig McCaw ' Page 2 November 1, 1989 Again, on behalf of the Commission please accept congratulations and thanks for a job well done. extend the Commission's heartfelt condolences to the BACTC employee whose life was tragically cut disaster. cc: John McCaw Commissioners Cordially, my Please also the family of short in this G. Mitchell Wilk President Photographs of Allentown Cell Site 12560 51st Place S Allentown, Washington c Proposed site - 12560 51st Place S 6:Z=1 • ,;••.••••1 , ,,of• ••• 77%4 • • 7-4 • Proposed site - 12560 51st Place S Proposed Site - 12560 51st Place S Single Family Residence North of Site • Single Family Residence South of Site Single Family Residence West of Site Picture of Proposed Site and Single Family Houses to North, South and West as Seen from Embankment to East of Site Proposed Site and Residence to North of Site Commercial Uses to East and North of Site Northern Pacific Railroad Trucking Company East of Site Northern Pacific Railroad Trucking Company East of Site Northern Pacific Railroad Trucking Company East of Site City Junk Located on S 124th Street Between 50th & 51st Place S ti-kjesiputAtigitatt Riverton Construction Company North of Site Riverton Construction Company North of Site SE 10 -23- s ,.77512 4. 01 a = 01 0 y — N) W; H I-t9,20 3 7200 EAST RIVERTON GARDE TRACTS 2ND AD V0.. IY /75 #(fl /su 1500.00 09TH AVE -3.. -% E II-23-4