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Ms. Melanie McCann <br /> December 6, 2021 <br /> Page 4 <br /> the AELUP planning area (AIA), including the 55 Freeway/Dyer Road Focus Area,the <br /> South Bristol Focus Area, and the South Main Focus Area. <br /> Citing JWA AELUP section 3.2.3 Noise Impact Zone 1 for"Residential use sound <br /> attenuation required to ensure that the interior CNEL does not exceed 45 dB" overlooks <br /> a key provision of the section, "residential uses within the 65-70 dBA CNEL noise contour <br /> must be 'indoor-oriented' to preclude noise impingementon outdoor living areas, as <br /> defined in Section 1 .7." The provision in between states, "All residential units are <br /> inconsistent in this area unless it can be shown conclusively that such units are <br /> sufficiently sound attenuated for present and projected noise exposures, which shall be <br /> the energy sum of all noise impacting the project, so as not to exceed an interior <br /> standard of45 dB CNEL." <br /> The Division supports the determination of inconsistency by the ALUC to be following the <br /> intent of the AELUP forJWA and its role to concurrently protect public safety and airport <br /> viability in concert with local development, as directed by PUC 21674(a). The Division <br /> also acknowledges the concerns noted by the OCALUC and JWA regarding the <br /> aircraft noise impact on all residents who will occupy the site for the foreseeable future. <br /> Therefore, the Division is concerned that the subsequent mixed-use developments will <br /> limit JWA's future operational capacity. Finally, the City of Santa Ana's City Council <br /> Resolution to Overrule the ALUC will remove the ALUC's liability. <br /> Please note: The Division's comments are to be included in the public record of any <br /> decision to overrule the ALUC. <br /> If you have questions orwe maybe of further assistance, please contact me via email <br /> at kevin.ryanC?dot.ca.gov. <br /> Sincerely, <br /> Originally signed by <br /> KEVIN RYAN <br /> Associate Aviation Planner <br /> c: Ms. Lea Choum, Executive Officer, Orange County Airport Land Use <br /> Commission, 3160 Airway Avenue, Costa Mesa, CA 92626-4608; ALUCinfoC?ocair.com <br /> "Provide a safe,sustainable,integrated,and efficient transportations ystern <br /> to enhance California's economyand livability" <br />