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B. The ALUC also adopted a separate Airport Environs Land Use Plan for Heliports <br />(Heliports AELUP) on June 19, 2008. <br />C. The ALUC is required to use the California Airport Land Use Planning Handbook <br />("Handbook") that was updated by the California Department of Transportation, <br />Division of Aeronautics (Caltrans) in 2011. Neither the JWA AELUP nor the <br />Heliports AELUP have been updated to incorporate the Handbook's guidance. <br />Likewise, the JWA AELUP has not been updated with information about the <br />operation and environmental effects of JWA as reflected in its most recent Final <br />Environmental Impact Report (EIR), certified by the Orange County Board of <br />Supervisors on June 25, 2019 for the General Aviation Improvement Program <br />(GAI P). <br />D. The City of Santa Ana is required to provide findings supporting the overrule of the <br />Orange County ALUC determination as required in PUC Section 21676(b). Based <br />on the following Findings of Fact and the associated substantial evidence in the <br />public record, the proposed action by the City on the Project at 1561 W. Sunflower <br />Avenue and related zoning change (amendment application) are consistent with <br />the purposes of the State Aeronautics Act as stated in PUC Section 21670. <br />E. The proposed Project provides for the orderly development of JWA, and its <br />surrounding area and promotes the overall goals and objectives of the State noise <br />standards by avoiding new noise and safety problems, and protecting the public <br />health, safety and welfare through the adoption of land use measures that <br />minimize the public's exposure to excessive noise and safety hazards to the extent <br />that this area is not already devoted to incompatible uses. This Project would not <br />add any new residential or commercial noise impacts to the JWA 65 dBA <br />Community Noise Equivalent Level (CNEL) noise area. <br />F. As the Project proposes a zone change and adoption of a Specific Plan, and <br />pursuant to PUC Section 21676, the City of Santa Ana referred the proposed <br />Project to the ALUC for review. <br />G. The ALUC has adopted FAR Part 77 as the criteria for determining height <br />restrictions in Orange County. FAR Part 77 requires notification to FAA for any <br />project that would be more than 200 feet in height above ground level or within the <br />imaginary surface of a 100:1 slope extending outward for 20,000 feet from the <br />nearest runway. Here, the Project site is located within the 206-foot-high imaginary <br />surface area for JWA, and the proposed mixed -use buildings that are a part of the <br />Project would be a maximum of 25 stories high, with the tallest point on the <br />buildings being 315 feet above the existing ground level. Thus, FAA notification is <br />required. <br />H. On June 19, 2025, the City of Santa Ana presented the Project to the ALUC for a <br />determination of consistency with the JWA AELUP. <br />The ALUC staff report for that hearing recommended that the ALUC find the <br />proposed Project consistent with AELUP issues of aircraft noise, flight tracks and <br />safety, and heliports. The staff report noted that with regard to AELUP issues of <br />Resolution No. 2025-XXX <br />Page 7 of 20 <br />