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

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Village Santa Ana Specific Plan August 0, 2025 Page 3 Response to Fact in Support "c" - RegardingNoise: The City states that because the project is located outside of the 60 and 65 dBA CNEL noise contours, and because mitigation measures will be required that the project is consistent with the AELUP. While the ALUC appreciates that the project will not place residents within. the 60 and 65 dBA noise contours, noise was not a factor in ALUC's determination of inconsistency. Res onse to Fact in Su ort "d" - Regarding Safety. The City states that because the project is outside of the Safety Zones and runway protection zone for JWA, and because the City will require FAA Determinations of No Hazard to Air Navigation that the project is consistent with the AELUP. The applicant, South Coast Plaza, filed Notices of Proposed Construction or Alteration (FAA Form 7460-1) for eight buildings in the project area with heights up to 279 feet above ground level, which is less than the proposed maximum height of 315 feet. On September 6, 2004, the FAA issued Determinations of No Hazard to Air Navigation for all thirty-seven 7460-1's submitted for the project. However, FAA determined that four of the buildings would be Obstructions under Part 77 standards and would exceed the Obstruction Surfaces by 26 to 107 feet. In addition, the FAA conditioned that the buildings be marred and/or lighted in accordance with FAA Advisory Circular 70/7460-1 M, Obstruction Marking and Lighting. Section 3.2.1 of the AELUP states, "within the boundaries of the AELUP, any land use may be found to be inconsistent with the AELUP which ... permits structures of excessive height in areas which would affect adversely the continued operation of the airport; or permits activities or facilities that would affect adversely aeronautical operations." Moreover, a finding of No Hazard to Air Navigation from the FAA does not equate to a consistency determination by the ALUC. The ALUC may find a project inconsistent based on other determinations. The ALUC may also utilize criteria for protecting aircraft traffic patterns at airports which may differ from those contained in Part 77, if evidence of health, welfare, or air safety justify such an action. Response to Fact in Support "e" - Regarding Height: The proposed project area is located within the FAA Part 77 Horizontal Obstruction Imaginary Surface for JWA which would be penetrated at 206' above mean sea level (AMSL). The airspace above 206' AMSL. is reserved for air navigation. The Specific Plan would allow buildings up to 25 stories and/or 315 feet in height and therefore would penetrate the Horizontal Surface and enter airspace reserved for air navigation. In Section 2.1.3 of the AELUP for JWA, the Commission has incorporated the standards for height limits for determining obstructions and has incorporated the definitions of "imaginary surfaces" for airports as defined in the FAA Part 77. The "imaginary surfaces" are defined by means of elevations heights and slopes in relation to individual airports, the spaces above which are reserved for air navigation. To ensure the safe operation of aircraft activity at JWA, structures anywhere in the JWA airport planning area should not exceed the applicable elevations defined in Part 77 (Objects Affecting Navigable Air Space).