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ALUC Bowery Overrule Response July 29, 2020 Page 2 of the airport. Specifically, the plan seeks to protect the public from the adverse effects of aircraft noise to ensure that people and facilities are not concentrated in areas susceptible to aircraft accidents, and to ensure that no structures or activities adversely affect navigable airspace. Additionally, Section 2.1.4 of the AELUP for JWA and PUC Section 21674 charge the commission to coordinate planning to protect the public health, safety and welfare. Therefore, because the proposed zone change, General Plan amendment and the project's inclusion of residential uses, the proposed project location within the primary approach corridor for JWA and the existing significant aircraft overflight above the proposed project site, the project is inconsistent with the AELUP. The City of Santa Ana Draft Resolution No. 2020-xx ("Draft Resolution") states that the proposed project does not add any new residential or commercial noise impacts to the JWA 65 dBA CNEL noise areas. While the project is located outside of the 60 and 65 dBA noise contours (Attachment 1 hereto), changing the site's General Plan designation from Professional and Administrative Office (PAO) to District Center (DC), and allowing up to 1,100 residential units in the aircraft approach corridor for JWA would subject residents to noise from overflight of commercial and general aviation aircraft (Attachment 2). Exhibits showing flight tracks in relation to the proposed project site were provided at the May 21, 2020 ALUC meeting (Attachment 3 & 4). Attachment 3 shows a day's worth of normal aircraft arrival operations and has a corresponding table listing each flight, the time of day and elevation above the proposed project site. The table shows that the majority of flights over the property are in range of 750 to 800 feet above ground level and arrive in very close intervals. Attachment 4 has also been included for your information and shows a day's worth of reverse flow departure flight tracks. The reverse departure flow occurs approximately 5% of the time, primarily due to weather factors. During reverse flow circumstances, departing aircraft may be higher in altitude, but louder over the project area. Based upon these aircraft arrival, departure and altitude statistics, future residents of the proposed Bowery Project will experience significant aircraft overflight and single event noise. It has been the ALUC's experience that residential uses located under aircraft approach and departure corridors generate a significant number of noise complaints from the affected residents. The city should give consideration as to how these noise complaints will be addressed should the City Council overrule the ALUC and approve the proposed project. These complaints will likely contact the JWA Noise Office and not the city, despite the fact that the city will have overruled ALUC's valid concerns for the welfare of its future residents. The complainants will then be directed to the city, as the approving authority, and thus, noise concerns should be addressed by the city's regulations or by including noise attenuation conditions of approval. These are not conditions that ALUC can place on the project, but that the city should consider for the protection of their own residents. Finding "F" on page four of Draft Resolution states that the ALUC staff report for the subject item found that "with regard to AELUP issues of aircraft noise, building heights, safety zones and heliports that the proposed project, zone change, and General Plan Amendment are each 75C-994