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Ms. Melanie McCann December 6, 2021 Page 2 fielded by JWA may increase as operations return to pre-pandemic levels. The Project's land use changes could exasperate this noise issue, particularly within the three Focus Areaswithin the AELUC forJWA airport planning area (AIA). As a result, JWA's future operational viability could be diminished. The JWA Economic Impact Study (2014) illuminates the valueof this extraordinary economic engine and why it should be preserved, since it supports 22,000 jobswith $2.8 billion in economic output, including$230.8 million in tax revenues. Ranked as the sixth busiest commercial airport in California, it is important to note that JWA is a self- supporting enterprise that receives no general fund tax revenue,while serving as many as ten million passengers annually between 2015-2019. (https://www.ocair.com/about/news-info/statistics/). As a part of the JWA's good neighbor policies, this airport is one of a few airports that restricts hours of commercial airline's aircraft operations to those between 1 1 :00 p. m. and 7:00 a. m. The noise program was a result of collaboration with neighboring communities, and the Division encourages this type of partnership in the planning process. The Division is concerned by the City's Project and this proposed resolution to overrule the ALUC regarding its inconsistency determination,which includes revisions to the existing elements, the addition of new elements, and five new focus areas for future development. The Division is most concerned with the cumulative effect of the proposed zoning changes related to the three focus areaswithin the ALUC's Airport Planning Area (AIA). These focus areas are expected to add nearly 18,000 new residents to the population impacted by JWA traffic patterns and approach/departure overflights. Minimizing the public's exposure to aircraft noise and the increased risk from even a single aircraft accident with mixed-use housing and structural heights of these buildings is the overall intent of the AELUP forJWA. The focus areas' land use designation changes are within the Approach-Departure path of the primary runway end 20R. The Division agrees with the ALUC that the City's proposed Project will subject future residents to a very high frequency of commercial passenger aircraft overflights. Furthermore, this action by the City may be in violation of the provisions of the SAA, as well as Senate Bill (SB) 1000, for safety and environmenta I justice and other CEQA provisions for protections from aircraft noise. The City's proposed action to overrule and allow increased housing densities than those currently allowed within the AIA AELUC for JWA could be in direct violation of section 21676(b), SB 244, Local government: land use: general plan:disadvantaged unincorporated communities, and SB 1000, Land use: general plans: safety and environmental justice. Additionally, California Health and Safety Code section 17922.6 regulates noise for multi-family dwellings. These laws have the goal of protecting people from airport "Provide a safe,sustainable,integrated,and efficient transportations ystern to enhance California's economyand livability"