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Ms. Kylee Otto, Deputy City Attorney August 6, 2004 Page 4 The specific purposes of the ALUC and the powers and duties of the ALUC, fls well as the specific AELUP land use compatibility policies with respect to each land use compatibility concern, should be accurately set forth in the City's General Plan Amendment consistent with statements made in the negative declaration. Page 1 of the Airport Environs Element should also be revised ;to accurately indicate that these policies are not just "ALUC goals," but have been incorporated into the General Plan Amendment as City goals. The proposed first paragraph in the Land Use Element states that these are General Plan goals, but the Airport Environs Element does not. The goals and policies stated in the Airport Environs Element should be internally consistent with the Land Use Element, and consistent with the AELUP for JW A. This could be accomplished, for example, by stating within the Airport Environs Element itself that these are the goals of the General Plan, placing them in the list of policies and repeating them in each relevant section. Essentially, it is important that the land use, housing, transportation, noise, safety and open space elements of the General Plan, as well as the land use maps, being among the likely candidates, be internally and externally consistent with the AELUP policies. 2. In regard to question VII. D. on page 11 of the negative declaration, more facts should be developed and a less conclusory discussion maintained. For example, the ALUC has raised the concern that tall buildings in the MacArthur Place/ Hutton Center area are under relatively low general aviation flight patterns and that approximately 22,000 fixed-wing aircraft typically fly over the proposed location of these residential high-rises on an annual basis. The negative declaration should be revised to reflect this concern, or should set forth evidence as to why this is not of concern to the City and does not pose a "safety hazard to people residing or working in the City." State and federal airport land use compatibility guidelines also recommend that a strict height limitation be imposed that is supported by substantial evidence to show that buildings beyond a certain height would be an obstruction to navigation of aircraft around JW A. As you are aware, long-term members of the ALUC recall the Federal Aviation Administration ("FAA") clearing a building at Hutton Center that ultimately interfered with the VHF Omni Range (VOR) navigational aid at JW A. It is critical that this type of unintended result be avoided in the future, based upon appropriate land use compatibility planning. Further, it appears that stronger language concerning the heights of buildings in the Land Use Element is being replaced with weaker, more subjective criteria. The previous language acknowledged that tall structures within 3 miles of an airport that are 200 feet or higher above ground level or runway level may have the potential to obstruct air navigation. It is important that the Land Use Element continue to contain direct and objective criteria regarding height limitations consistent with the JWA AELUP. The Noise Element of the General Plan should 75C-193