Item 28 - Public Hearing - Amendment Application for the Village Santa Ana Specific Plan

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Village Santa Ana Specific flan August t5, 2025 Page 2 allow buildings up to 25 stories and/or 315 feet which would penetrate the Part 77 Horizontal Obstruction Imaginary Surface for JWA. ALUC has the following additional comments regarding the Draft ALUC Overrule Findings that were attached to the July 16, 2025 letter. Response to Findingand nd Fact in„Support "a" - Regarding Height: The City contends that the ALUC lacks evidence of the project's inconsistency with the AELUP, citing three factors: (1) the proposed zone change would establish a specific plan without defining the exact locations and heights of individual developments; (2) Commissioners and staff relied on outdated information about tall buildings and instrument procedures; and (3) despite the FAA Determinations of No Hazard, the ALUC found the project inconsistent based on an "obstruction" determination. The findings mention an ALUC staff reference to another city during the ALUC meeting, but this inadvertent reference was corrected by staff during the meeting. The proposed specific plan would allow for buildings with residential uses up to 25 stories and 315 feet in height, which would penetrate the 206 feet Horizontal Surface for JWA regardless of where they are located within the specific plan boundaries. Such structures have potential to adversely impact the continued operation of the airport and other aeronautical operations. The applicant, South Coast Plaza, filed FAA Form 7460-1 notices for eight buildings up to 279 feet tall —below the proposed maximum height of 315 feet. While the FAA issued determinations of no hazard for eight buildings proposed up to 279 feet tall, it also found four buildings to be obstructions under Part 77 standards, exceeding Obstruction Imaginary Surfaces by 26 to 107 feet. Although the project site's location was incorrectly referred to in the staff presentation to the Commission, the location was accurately described in the written staff report and was promptly corrected during the proceedings. Response to Fact in Support "b" - Regarding Mitigation Measures: The City states that during the June 19, 2025 meeting, City staff and the project applicant provided additional information indicating that the City will review projects about the nature of a specific plan, how implementing projects will be reviewed, information on existing high- rises in the vicinity, FAA notification requirements for buildings exceeding 200 feet in height, and that the Final Supplemental Environmental Impact Report ("SEIR") for the Project would contain a mitigation measure requiring "Notice of Airport in Vicinity," to be included in all lease/rental agreements and post outdoor signage informing the public of the presence of operating aircraft. The City asserts that these measures would demonstrate further compliance with the AELUP and to minimize potential future noise complaints. The ALUC appreciates the inclusion of these mitigation measures, however the ALUC determination was based on the fact that the proposed specific plan would allow for buildings with residential uses up to 25 stories and above 315 feet in height which would not only be an Obstruction under Part 77 but could pose a public safety issue and impact the operations of the airport and aeronautical operations, by allowing development to enter airspace reserved for air navigation.