75A - PH - EIR THE HERITAGE 2001 E DYER

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ALUC Heritage Overrule Response January 15, 2016 Page 2 allowed in an area that has historically been only office and industrial uses. The proposed Heritage project would now be placing residential uses directly under the aircraft approach corridor for JWA, subjecting residents to overflight of both commercial and general aviation aircraft (See Attachment 1). The Findings Section (D) of the City's resolution on page 4 discusses that the proposed Heritage Project is not located within the John Wayne Airport ( "JWA ") 60 or 65 dBA Cumulative (Please note this should be Community not Cumulative) Noise Equivalent Level ( "CNEL ") noise contours indicating areas of significant noise impact as set forth in the JWA Master Plan. The City's resolution Findings Section (E) goes on to state that the proposed Heritage Project is not within the safety zone areas for JWA within which limitations on development and occupancy apply to protect surrounding occupants from adverse airport impacts. Although the proposed project is not within the 60 and 65 CNEL noise contours and is located outside the safety zones for JWA, the proposed Heritage Project is located under the aircraft approach centerline for JWA, and residential uses in this area would not coexist well with constant overflight of aircraft. On October 8, 2015 JWA provided the City of Santa Ana Planning Commission with flight track exhibits showing flight tracks over the proposed project site (see Attachments 2 and 3). ALUC staff also presented the same flight track information at the October 15, 2015 ALUC meeting. Attachment 2 shows a day's worth of normal aircraft arrival operations and has a corresponding table listing each flight, the time of day and elevation above the proposed project site. The table shows that the majority of flights over the property are in range of 500 to 700 feet above ground level and arrive in very close intervals. (This is also graphically depicted in Attachment 4 which is an exhibit from County of Orange /JWA Final EIR 617.) As an example, the table shows aircraft arrivals from 9:00 a.m. to 10:00 a.m. when aircraft flew over the property, on average, every 3.7 minutes with the longest interval being 8 minutes between flights and the shortest being I minute. In the 8:00 p.m. to 10:30 p.m. timeframe on the same day, planes flew over the property, on average, every 5.2 minutes, with the longest interval between flights being 22 minutes and the shortest interval being I minute, Attachment 3 has also been included for your information and shows a day's worth of reverse flow departure flight tracks. The reverse departure flow occurs approximately 5% of the time, primarily due to weather factors. During reverse flow circumstances, departing aircraft may be higher in altitude, but louder over the project area. Based upon these aircraft arrival, departure and altitude statistics, future residents of the proposed Heritage Project arill experience significant aircraft overflight and single event noise. It has been the ALUC's experience that residential uses located under aircraft approach and departure corridors generate a significant number of noise complaints from the affected residents. The City should give consideration as to how these noise complaints will be addressed should the City Council overrule the ALUC and approve the proposed project. Because of the frequency of the overflights, the ALUC does not agree with Finding Section (F) of the City's draft resolution stating that the aircraft overflights will be mitigated by the existing curfew at J WA. 75A -112