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Mr. Vince Fregoso August 13, 2020 Page 2 JWA by the ALUC, particularly as it relates to AELUP sections 1.2 and 2.1.4, and the California Public Utilities Code (PUC), section 21674 (a). The Division understands the ALUC's concern and interpretation of their role specifically as it regards the proposed 1,100 residential units within the Approach/Departure of JWA's primary runway. This is in accordance with the AELUP for JWA, section 2.1.3 pages 13-14, which states: A Determination of No Hazard to Air Navigation does not automatically equate to a Consistency determination by the ALUC. The FAA may also conclude in their aeronautical study that a project is an Obstruction but not a Hazard to Air Navigation. The Commission may find a project Inconsistent based on an Obstruction determination. The commission may utilize criteria for protecting aircraft traffic patterns at individual airports which may differ from those contained in FAR Part 77, should evidence of health, welfare, or air safety surface sufficient to justify such an action. Although the proposed Project will meet the requirements of PUC, section 21670(a) (1) and (2), another issue Caltrans is concerned about is environmental justice for this proposed residential site. If the City overrules the ALUC to change the established Light Industrial zone to Specific Development No. 96 (SD-96), it Will place the new community's residents under a commercial airline approach path, which may place an undue burden on sensitive community segments Within the newly established community. In 2016, the Legislature passed Senate Bill 1000, which requires environmental justice to be addressed in local government General Plan documents, so that planners engage with environmental justice communities and air quality analyses are completed. The Division understands the determination of inconsistency by the ALUC to be following the intent of the AELUP for JWA and its role to concurrently protect public safety and airport viability in concert with local development, as directed by PUC 21674 (a). The Division also acknowledges the concerns noted by the Orange County ALUC and JWA regarding the aircraft noise impact on all residents who will occupy the site for the foreseeable future. Additionally, the ALUC cited statistical data indicating that the proposed site will experience a substantial frequency of commercial overflights to JWA. Therefore, the Division also has concerns that the proposed Project could limit JWA's future operational capacity and thereby diminish the airport's ability to meet the region's growing air service demand. "Provide a safe, sustainable, integrated, and efficient transportation system to enhance California's economy and livability"