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ALUC Response to Not to Ovennale <br />Related Bristol Specific Plan <br />October 24, 2023 <br />Page 3 <br />consistency determination by the ALUC. The ALUC may find a project Inconsistent based on <br />other determinations. The ALUC may also utilize criteria for protecting aircraft traffic patterns at <br />airports which may differ from those contained in FAR Part 77, if evidence of health, welfare, or <br />air safety justify such an action. As described herein, the ALUC found evidence of air safety <br />issues, among other things. <br />Response to Fact in Sunnort "e" Reizardine Heitrht: <br />The proposed project area is located within the FAA FAR Part 77 Horizontal Obstruction <br />Imaginary Surface for JWA which would be penetrated at 206' above mean sea level (AMSL). <br />The airspace above 206' AMSL is reserved for air navigation. The Specific Plan would allow <br />buildings up to 25 stories and/or 285 feet in height and therefore would penetrate the horizontal <br />surface and enter airspace reserved for air navigation. <br />In Section 2.1.3 of the AELUP fur JWA, the Commission has incorporated the standards for <br />height limits for determining obstructions and has incorporated the definitions of "imaginary <br />surfaces" for airports as defined in the FAA FAR Part 77. The "imaginary surfaces" are defined <br />by means of elevations heights and slopes in relation to individual airports, the spaces above <br />which are reserved for air navigation. To ensure the safe operation of aircraft activity at JWA, <br />structures anywhere in the JWA airport planning area should not exceed the applicable <br />elevations defined in FAR Part 77 (Objects Affecting Navigable Air Space). <br />Res onse_to_Fact in Support "f' Regarding Overflight: <br />The July 20, 2023 ALUC staff report included flight tracks over the City of Santa Ana on a <br />typical weekday, on a reverse -flow weekday and on a typical Saturday in January. The ALUC <br />recommends that the maximum structure heights, including all rooftop equipment and/or <br />architectural details, be reduced to below 206 feet AMSL, in order to protect the airspace <br />reserved for air navigation. <br />Res onse to Fact_in Su ort" "Re ardin�; Heliports: <br />As the City states, heliports were not included as part of this project, therefore heliports were not <br />reviewed by ALUC. <br />Res nse to Fact in Su ort "h" Re ardin Zone Chan e: <br />Finding "h" summarizes Findings "a" through "g" and refers to flight tracks. The Inconsistent <br />Finding by ALUC was not based on flight tracks alone but based on the fact that the proposed <br />Related Bristol Specific flan would allow buildings to penetrate the FAR Part 77 Horizontal <br />Obstruction Imaginary Surface for JWA and enter airspace reserved for air navigation. This is <br />problematic for the safe operation of the airport and other aeronautical operations. <br />Exhibit 12 - John Wayne Airport Land Use Commission (ALUC) and California Department of Transportation (Caltrans) Division of Aeronautics <br />Notice of Intent to Overrule and ALUC Response <br />