HomeMy WebLinkAbout10/17/2000, 8 - PROPOSED AMENDMENT OF THE COUNTY AIRPORT LAND USE PLAN council Oct.17,00
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CITY OF SAN LUIS O B I S P O
FROM: John Mandeville, Long-range Planning Manager
Prepared By: Glen Matteson, Associate Planner 0"
SUBJECT: PROPOSED AMENDMENT OF THE COUNTY AIRPORT LAND USE PLAN
CAO RECOMMENDATION
Authorize the Mayor to send a letter to the Airport Land Use Commission:
Noting the need for environmental review;
Pointing out that the draft plan needs to have maps illustrating the proposed policies;
Noting that more time will be needed for review once the maps are available;
Recommending that noise standards for airport compatibility not be more restrictive than
standards for other noise sources
DISCUSSION
Situation
Under California law an independent, county-level Airport Land Use Commission (ALUC) is
responsible for preparing and maintaining land use plans for county airports. The ALUC is also
charged with determining whether city and county general plans, general plan amendments,
specific plans, and rezonings are consistent with affected airport land use plans. The City must
refer those types of planning proposals to the ALUC before acting on them. The Airport Land
Use Plan (ALUP) aims for compatibility with noise and safety factors in the vicinity of the
airport. To override a determination of inconsistency, the City Council would need to have a
4/5ths vote and to make certain findings that would be particularly difficult with our General
Plan, which calls for consistency with the ALUP. The San Luis Obispo Airport Land Use Plan
was adopted in 1973, and had some minor amendments in the late 1970's. It does not contain
several of the items that State guidelines say it should.
Several years ago, the ALUC began the process of updating its plan. As provided in State law,
County staff provided technical help. The City's General Plan Land Use Element update, adopted
in 1994, was consistent with the draft ALUP in progress at that time. That draft ALUP update
was basically the same as the draft referred to in the Environmental Impact Report for the Airport
Master Plan (a facilities plan) in 1998, and the draft ALUP released to the public in 1999. That
draft ALUP would have accommodated the draft Margarita Area Specific Plan, endorsed by the
City Council in 1998. (The adopted ALUP would require some changes.)
The Airport Land Use Commission has rejected the draft Airport Land Use Plan prepared by
County staff and has released for comment a new draft (preliminary version is available in
Council Reading File). The new draft differs from the adopted plan mainly by further restricting
residential development in the southern part of the urban reserve. If adopted, the new draft
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Council Agenda Report—Airport Land Use Plan amendment
Page 2
apparently would eliminate urban residential use in the Margarita Area and the residentially
designated part of the Dalidio property. The ALUC may schedule a hearing as early as November
8 or November 15 to consider adopting the new plan. The ALUC sees the new plan as a short-
term amendment to correct deficiencies, with a comprehensive revision to be prepared with
consultant help over the next 12 to 18 months.
Evaluation
The draft Airport Land Use Plan, as expected under State law, has been prepared only with the
aim of airport compatibility. It does not consider other community goals, or consistency with
previously adopted City or County land use plans. The City's General Plan is meant to
encompass airport compatibility and other goals, such as balancing increases in jobs and housing
and protecting open space for reasons other than aircraft overflight. Nearly all San Luis Obispo's
new housing is planned to be in the southern part of the city, which is also the area most
influenced by the airport.
The 1973 ALUP established six compatibility zones and a matrix indicating whether certain
types of uses would be compatible, conditionally compatible, or prohibited within each zone. The
zone boundaries were based on noise and overflight conditions. The currently proposed
amendments would not change the zone boundaries or the matrix. However, the amendments
include new policies that would allow, or require, the ALUC to find incompatible some uses that
would be considered compatible under the adopted plan. These new policies come in two forms,
measurable standards and bases for judgment:
Measurable standards
These would classify as incompatible, for example, residential development under certain
flight paths or where noise exposure is projected to exceed 55 decibels. The proposed
ALUP's residential noise-exposure standard of 55 decibels is not consistent with the City's
General Plan Noise Element, which allows residential outdoor noise exposure up to 60
decibels. While the descriptions of the areas subject to certain levels of overflight are quite
complex, they can be translated into specific areas on a map. Other standards are difficult to
map because they involve the passage of time, possibly allowing an early development
proposal to proceed while requiring nearby property to be kept open as an emergency
landing site if it were proposed for development later. City staff has tried to map the main
effects of the new policies that take the form of measurable standards (Attachment 2), with
the help of the Airport Land Use Commissioner who advocated them.
As the Attachment illustrates, the ALUP amendments propose that residential development
in the Margarita and Dalidio areas be substantially reduced or eliminated. This could
eliminate up to half of the new dwelling units planned for in the City General Plan. This in
turn has substantial implications for the City's jobs/housing balance and on where or how
the City would then provide for 1% average annual population growth. Secondary impacts
involve air quality, traffic, and possible conversion of nearby rural lands to residential uses.
A key concern is that this mapping may not be accurate or complete. Without complete
mapping, the implications of the new policies cannot be completely assessed. Providing
accurate maps should be the responsibility of the ALUC.
8-2
i
Council Agenda Report—Airport Land Use Plan amendment
Page 3
Bases for judgment
Regardless of the matrix or measurable standards, these policies would allow the ALUC to
determine that, for example, a residential use is not compatible because it is located
similarly to an area from which noise or overflight complaints have been received. These
areas cannot be mapped in advance of the ALUC exercising its judgment. However, City
staff will continue to work with Airport staff to prepare a map showing complaints received
by the Airport, as an indication of how this policy might be applied.
When this report was prepared, an initial study for the ALUC's environmental determination had
not been prepared. However, potentially significant impacts may result from changes to land use
policies that would conform to the new ALUP. At the Council meeting, City staff will provide an
update concerning environmental information, policy mapping, and the ALUC's intended
schedule for adopting the new ALUP. A request for the ALUC to postpone acting on the
proposed amendment is warranted by the lack of a draft plan reflecting the ALUC's September
20 direction, an environmental study, and accurate policy mapping (draft letter, Attachment#1).
ALTERNATIVES
The Council may transmit whatever comments it deems appropriate.
The Council may take no action. This would signal the Airport Land Use Commission that the
City has no concerns with potential inconsistencies between the proposed Airport Land Use Plan
and the City's General Plan.
Attachments
#1 —Draft letter to Airport Land Use Commission
#2—Map "Consequences of Proposed Airport Land Use Plan" (preliminary)
In Council Reading File:
"Proposed Amendment to the Airport Land Use Plan for the San Luis Obispo County Regional
Airport," September 1, 2000." (When this report was prepared, copies of the draft endorsed by
the ALUC were not available, so City staff provided for the reading file the draft presented to the
ALUC, with notes on their actions.)
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8-3
Attachment #1
Draft
Letter to Airport Land Use Commission
San Luis Obispo County Airport Land Use Commission
County Government Center
San Luis Obispo, California
Honorable Commissioners:
The City supports land-use planning for compatibility with Airport noise and safety conditions.
The City also has other goals that cannot be ignored in our efforts to assure the continued safe
operation of the Airport. Chief among these other goals are balancing additional employment and
housing opportunities in the San Luis Obispo area, and protecting open space for reasons other
than overflight safety. The San Luis Obispo City Council has followed with interest your efforts
to update and amend the Airport Land Use Plan. While we agree that an update is overdue, the
process for considering an amendment must allow enough time to meet legal requirements and
enable public review and comment. November 15 is too soon to consider adoption.
Following are our specific concerns, as identified by Council members at our meeting of October
17.
1. Draft Plan Not Available. A draft document reflecting your Commission's direction was
not available in time for distribution with our usual meeting agenda materials. Our review
and comments therefore had to be based on a previous, committee-prepared draft and our
understanding of your action as reflected in staff notes.
2. Environmental Study Absent.Amending a land use plan is a project as defined by the
California Environmental Quality Act and its implementing Guidelines. You need to make an
environmental determination before acting on the proposed amendment. An initial study,
which could be the basis for approving a negative declaration or setting the scope of an
environmental impact report, was not available when our agenda materials were prepared.
Our understanding is that even if an environmental impact report is not done, a proposed
negative declaration must be available for public comment at least 20 days before action on a
project.
3. Policies Not Illustrated.The draft plan contains several policies for land-use compatibility
that are expressed in terms of aircraft flight paths and altitudes. While these policies could be
translated into specific mapped areas, they have not been. Other policies will be more
difficult to map because they are not expressed in quantified terms. Clearly describing areas
subject to the policies will be an important part of the "project description" for environmental
review. The City and the County governments and the public will need time to review these
descriptions (maps) once they are available.
8-4
Airport Land Use Commissic.. -airport Land Use Plan Amendment Attachment #1
Page 2
4. Noise Standards Not Consistent,and Drastically Reduced Housing Supply.Using 55
decibels Community Noise Equivalent Level (CNEL) as the criterion for compatibility would
not be consistent with the City's General Plan Noise Element, which uses 60 decibels. It
would make sense to use 60 decibels for land inside the current urban reserve line, and 55
decibels for rural land outside the urban reserve.
At this time, the implication of the City implementing the proposed noise compatibility
standard appears to be a severe decrease in the City's ability to accommodate residential
growth in the areas shown in the City's General Plan. The State obligates the City to
accommodate projected residential growth. It is the City's policy to accommodate 1%
average annual population growth. The areas planned for residential expansion in the City's
General Plan have been evaluated for the City's ability to provide urban services and for
environmental impacts as a part of the general plan preparation process. These areas are the
most logical areas for residential use, representing contiguous development and the location
of housing near jobs.
Not implementing the City's General Plan, as suggested by the proposed amendments, would
eliminate up to half of the new dwelling units planned for in the City General Plan. This in
turn has substantial implications for the City's jobs/housing balance and on where or how the
City would then provide for 1% average annual population growth. Secondary impacts
involve increased traffic and vehicle emissions from more commuting, and possible
conversion of nearby rural lands to residential uses as the City seeks to implement its adopted
housing policies in other areas.
Until the effects of the proposed amendments are completely mapped, the implications of the
new policies cannot be completely assessed. Providing accurate maps is the responsibility of
the ALUC, which is the lead agency in this matter.
Thank you for considering our comments. We anticipate your Commission making available the
time and information that will allow a complete evaluation of the proposed amendment.
Respectfully,
Allen K. Settle
Mayor
8-5
-MEETING ' -` AGENDA
,ATE 1°'=ITEM #
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October 17, 2000
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FROM: John Dunn, City Administrative O ❑PW DIR f
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SUBJECT: Item 8: County Airport Lan se Plan °t>ra DIR
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Two Council members have called expressing concern about the extent of action recommended
relative to this item. This concern was discussed in depth at our agenda review meeting this
morning and the following suggestion and alternative are offered.
1. We strongly recommend that Council at least hear the staff presentation this evening. It is
important that we get up-to-speed on this matter since action by the Airport Land Use
Commission (ALUC) may be imminent, and at a minimum, the issue will be the subject of
some public discussion in the coming months.
2. In terms of action, as an alternative we can focus the letter almost entirely on process; that is
that action by the ALUC be deferred until more information is available, and until a
stakeholders are convened to further review proposed plan amendments. This alternative can
be accomplished by dropping #4 of the current letter (relating to noise and housing) and
substituting a new fourth point requesting greater stakeholders involvement. Attached is a
letter which provides this new #4, and also some classifying edits offered by Vice-Mayor
Schwartz at the agenda review meeting.
3. In order to implement the alternative set forth in this memo, the CAO Recommendation
would be amended at as follows:
1. Authorize the Mayor to send a letter to the Airport Land Use Commission:
A. Noting the need for environmental review;
B. Pointing out that the draft plan needs to have maps illustrating the proposed policies;
C. Noting that more time will be needed for review once the maps are available;
D. Requesting that, after sufficient information is available, that the ALUC hold a
stakeholders meeting to include property owners and representatives of the City,
County, School District and others to more fully discuss the issues and options.
2. Designate the Mayor and Vice-Mayor as representatives to the ALUC stakeholders
meeting,when such a meeting is scheduled.
ERECEIVED
ATTACHMENT: Revised Letter
2000
LERK
Attachment#1
Revised Draft
Letter to Airport Land Use Commission
San Luis Obispo County Airport Land Use Commission
County Government Center
San Luis Obispo,California
Honorable Commissioners:
The City has been working for many years to maintain consistent plans with the County and your
Commission. City staff has worked for years with your staff on keeping the Margarita Area Specific Plan
and the proposed ALUP updates consistent. Your Commission's recent decision to start over with the
ALUP updates is at odds with land use plans in the City that have been evolving for over 20 years. The
effect of such a significant change so late in this process may be far reaching,with effects on housing
supply and affordable housing, air quality,protecting open space lands,and property owners'
development rights.
The City supports land-use planning for compatibility with Airport noise and safety conditions.The City
also has other goals that cannot be ignored in our efforts to assure the continued safe operation of the
Airport. Chief among these other goals are balancing additional employment and housing opportunities in
the San Luis Obispo area, and protecting open space for reasons other than overflight safety.The San
Luis Obispo City Council has followed with interest your efforts to update and amend the Airport Land
Use Plan. While we agree that an update is overdue,the process for considering an amendment must
allow enough time to meet legal requirements and enable public review and comment.November 15 is
too soon to consider adoption.
Following are the City's reasons for requesting that your consideration be continued,as identified by the
Council at its meeting of October 17.
1. Draft Plan Not Available.A draft document reflecting your Commission's direction was not
available in time for distribution with our meeting agenda materials. Staff and Council review and
comments therefore had to be based on a previous ALUC technical advisory committee-prepared
draft and the Council's understanding of the proposal as reflected in staff notes.
2. Environmental Study Absent.Amending a land use plan is a project as defined by the California
Environmental Quality Act and its implementing Guidelines.As lead agency,the ALUC needs to
make an environmental determination before acting on the proposed amendment. An initial study,
which could be the basis for approving a negative declaration or setting the scope of an environmental
impact report,was not available when our agenda materials were prepared. Our understanding is that
even if an environmental impact report is not done,a proposed negative declaration must be available
for public comment at least 20 days before action on a project.
3. Policies Not Illustrated.The draft plan contains several policies for land-use compatibility that are
expressed in terms of aircraft flight paths and altitudes.These policies need to be translated into
specific mapped areas.Other policies will be more difficult to map because they are not expressed in
quantified terms.Clearly describing areas subject to the policies will be an important part of the
"project description"for environmental review.The City and the County governments and the public
are entitled time to review these descriptions(maps)once they are available.
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4. All The Stakeholders Must Be Involved. The variety of stakeholders potentially affected by the
proposed amendment is broad,including city and county property owners,businesses,city and county
residents,city and county governments,the school district,and other agencies with responsibility for
issues related to the amendment,such as the Air Pollution Control District. The short path being
taken from drafting the amendments to considering them for adoption is likely to leave many of these
stakeholders without opportunity to review the amendments and provide your Commission with
comments prior to your action.
It would be facilitative of your Commission to hold public forums for the participation of these
stakeholders. The Council is interested in knowing more about the proposed amendment,and
considering the input from affected stakeholders before taking any further action. The City could do
what it can to help your Commission hold such meetings.
The City Council trusts that your Commission will make the time and information available to allow a
complete evaluation of the proposed amendments by all the affected individuals and agencies.Thank you
for considering our comments.
Respectfully,
Allen K. Settle
Mayor
alup mayor letter.doc
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Dear Commission Members: J
I am writing in response to the recent articles in the Tribune regarding The Airport
Land Use Commissions, (ALUC) position on development within the airport area.
I will start by giving you the benefit of the doubt and say, you can't always believe
what you read in the papers. With that said, I would like to express my views on
the subject of limiting growth of the airport area based on the commissions
concerns.
I was born in San Luis Obispo and have lived here my entire life. In 19971 was
asked to participate as a member of the San Luis Obispo County Airport Master
Plan Study as a representative of the airport area property owners. As you know
that study was to determine a long range plan for the expansion of the County
Airport. One of the subjects of study was on airport land use planning. The
study addressed two primary considerations for airport area land use. They
were; First , to secure those areas essential to the safe operation of the airport;
and, second, to determine compatible land uses for the balance of the property
which would be most advantageous to the airport and community. The study
was prepared by a firm specializing in airport master planning. A limit to
development outside of the immediate runway protection zone as a means to
protect the operation of the airport was never discussed.
On a more personal note one of our projects was before this commission on
August 16 of this year. We were requesting a zoning change for two parcels one
R-2 and the second C-S, to one parcel zoned M-U. Our request was approved,
however, not before much discussion and several conditions. I did not have an
issue with the comments, suggestions and conditions with the exception of one.
We were asked to design our project with a maximum decibel rating of 40 in
sleeping quarters. The city of San Luis Obispo's current noise element for the
same condition is set at 45 decibels. I have to believe the city studied the noise
issue to a fault and the ALUC would be safe in accepting an established proven
criteria.
RECEIVED
OCT 1 3 2000
SLO CITY CLERK
815 6 Fiero Lane, San Luis Obispo, CA 93401 Phone: 805/543-0560 Fax: 805/543-0679
Page two
•
In general I believe I understand the concerns of the ALUC and for the record
agree that most are legitimate. However, my disagreement with the ALUC is not
with their concerns but rather their approach to mitigating the same. I disagree
with the "No Development" concept as a method of mitigating airport operation
concerns. If the ALUC established a set of guidelines that outlined the issues
with suggested mitigation measures I can assure you it would take the mystery
out of the process and save time, confusion and expense for all involved.
In addition I must believe the current legal process by which developers grant an
avigation easement to the County of San Luis Obispo covers the bulk of the
concerns in a legal document recorded on properties for perpetuity. If the ALUC
feels the current Avigation easement is inadequate then it should be amended to
fully address all of their concerns.
urge the commission to consider the following;
1. Review and rewrite (if necessary) the counties avigation easement and
address every concern of the ALUC, this document would become a recorded
instrument on each property within the airport area.
2. Establish a set of guidelines for developers to follow that addresses the ALUC
concerns with appropriate mitigation measures to deal with airport area
development issues. These mitigation measures should be reasonable and
follow established criteria.
3. Consider establishing a legal process to disclose potential airport operation
issues to the purchaser of all properties within the airport area.
In summary, I am confident the ALUC can work with applicants to ensure the
protection of airport operations and still maintain the long range plan of
developing the airport area. If you have any questions please do not hesitate to
contact me.
Respectfully,
Matt Quaglino
Cc San Luis Obispo City Council
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FROM: John Mandeville,AICP,Long-Range Planning ManagelN ✓Ci MOA W-50✓1
SUBJECT: Wednesday's Tribune Article About The Airport Land Use Plan And
Restrictions On The City's Housing Plans
Wednesday morning's Tribune carried a front-page article regarding issues surrounding the
Airport Land Use Commission's consideration of changes to the Airport Land Use Plan and how
these changes could affect the City's housing plans. The article contained an error and lacked
critical contextual information for several assertions presented as facts.
First of all,the City does not propose removing the school site from the Margarita Area. The
reporter looked at several draft maps made in the attempt to illustrate the changes being proposed
by the Airport Land Use Commission. Because the Commission's proposed changes restrict
school siting, the illustration viewed by the reporter did not show the school. As the Council
agenda report explains,the Airport Land Use Commission(ALUC)has not illustrated how their
proposed changes will affect land use around the airport. Lacking their providing this
information, City staff has been working with an ALUC member to prepare an illustration that
will make the proposed Airport Land Use Plan (ALUP) changes more understandable. The
reporter mistook this for a city plan.
Secondly, Commissioner Oxborrow indicated that the City's planning for an 1,100 dwelling unit
neighborhood is catching the Commission by surprise. City staff has worked closely with ALUC
staff in the drafting of the Airport Area and Margarita Area specific plans. County planning staff
provide staff support for the ALUC. County staff, acting as ALUC staff, initiated two updates to
the Commission's 1977 ALUP, once in the late 1980's and most recently in 1998. City staff
worked closely with the County/ALUC staff to insure consistency between the specific plans and
the draft ALUP updates. The Margarita Area Specific Plan was consistent with the last version
of the ALUP update presented to the City.
While the City's plans may come as a surprise to some ALUC members, City staff have been
engaged in many years of good faith effort with ALUC staff to coordinate our different agency
plans. Membership on the ALUC has changed. The new ALUC decision to abandon the ALUP
updates prepared by their own staff is essentially pulling the rug out from under previous efforts
to prepare consistent plans. The proposed City letter to the ALUC has been revised to inform
ALUC members of the good faith effort the City has been making for consiste
point in time.
OCT 0- 2000
CCLenerWALUC.dmdo1
SLO CITY CLERK
y
Council Memorandum
October 12, 2000
Page 2 .
Finally, the article implied that the City is considering an alternative land use plan for reduced
residential capacity in the Margarita Area. While staff is examining many alternatives, no
revised Margarita Area Specific Plan will be presented in any official capacity until the Council
endorses it. The reduced capacity concept is just a concept identified as all options are
considered. At this point the staff recommends holding to the current Draft Specific Plan, given
out lengthy history of cooperatively developing it with ALUC staff.
Based upon City and State noise standards,the Draft Margarita Area Specific Plan housing
densities are reasonable. The ALUC is proposing more restrictive standards than the City or
State. It is understandable that the ALUC would seek to minimise noise complaints from
residences near the airport. However,the City is already and will make it mandatory for
properties in the Margarita Area to provide the County with avigation easements that restrict a
property owner's ability to take any legal action regarding airport noise. In addition,the Draft
Margarita Area Specific Plan will recommend insulation beyond what is normally required by
code to minimize interior noise. The City is supporting continued viability of the airport. The
ALUC's proposed restrictions go beyond the City's policy basis for restricting land use.
Restricting property owners' development rights to the extent proposed by the ALUC to control
noise may raise a takings issue for the property owners.
For these reasons, staff is continuing to work on the draft of the Margarita Area Specific Plan
previously endorsed by the Council. Staff will be prepared to discuss alternative land use
scenarios as a normal part of the specific plan review process, or in response to a Council
request.
ATTACHMENT: Revised draft letter to ALUC
jm/HOT File.doc
Attachment#1
Revised Draft
Letter to Airport Land Use Commission
San Luis Obispo County Airport Land Use Commission
County Government Center
San Luis Obispo,California
Honorable Commissioners:
The City has been working for many years to maintain consistent plans with the County and your
Commission. City staff has worked-for years with your staff on keeping the Margarita Area Specific Plan
and the proposed ALUP updates consistent. Your Commission's recent decision to start over with the
ALUP updates is at odds with land use plans in the City that have been evolving for over 20 years. The
effect of such a significant change so late in this process may be far reaching,with effects on housing
supply and affordable housing,air quality,protecting open space lands,and property owners'
development rights.
The City supports land-use planning for compatibility with Airport noise and safety conditions.The City
also has other goals that cannot be ignored in our efforts to assure the continued safe operation of the
Airport.Chief among these other goals are balancing additional employment and housing opportunities in
the San Luis Obispo area,and protecting open space for reasons other than overflight safety.The San
Luis Obispo City Council has followed with interest your efforts to update and amend the Airport Land
Use Plan.While we agree that an update is overdue,the process for considering an amendment must
allow enough time to meet legal requirements and enable public review and comment.November 15 is
too soon to consider adoption.
Following are our specific concerns, as identified by Council members at our meeting of October 17.
1. Draft Plan Not Available. A draft document reflecting your Commission's direction was not
available in time for distribution with our usual meeting agenda materials.Our review and comments
therefore had to be based on a previous,committee-prepared draft and our understanding of your
action as reflected in staff notes.
2. Environmental Study Absent.Amending a land use plan is a project as defined by the California
Environmental Quality Act and its implementing Guidelines. You need to make an environmental
determination before acting on the proposed amendment.An initial study,which could be the basis
for approving a negative declaration or setting the scope of an environmental impact report,was not
available when our agenda materials were prepared. Our understanding is that even if an
environmental impact report is not done,a proposed negative declaration must be available for public
comment at least 20 days before action on a project.
3. Policies Not Illustrated.The draft plan contains several policies for land-use compatibility that are
expressed in terms of aircraft flight paths and altitudes. While these policies could be translated into
specific mapped areas,they have not been.Other policies will be more difficult to map because they
are not expressed in quantified terns. Clearly describing areas subject to the policies will be an
important part of the"project description"for environmental review. The City and the County
governments and the public will need time to review these descriptions(maps)once they are
available.
Attachment#1
Airport Land Use Commission sport Land Use Plan Amendment ;
Page 2
4. Noise Standards Not Consistent,and Drastically Reduced Housing Supply.Using 55 decibels
Community Noise Equivalent Level(CNEL)as the criterion for compatibility would not be consistent
with the City's General Plan Noise Element,which uses 60 decibels. It would make sense to use 60
decibels for land inside the current urban reserve line,and 55 decibels for rural land outside the urban
reserve.
At this time,the implication of the City implementing the proposed noise compatibility standard
appears to be a severe decrease in the City's ability to accommodate residential growth in the areas
shown in the City's General Plan. The State obligates the City to accommodate projected residential
growth. It is the City's policy to accommodate 1%average annual population growth. The areas
planned for residential expansion in the City's General Plan have been evaluated for the City's ability
to provide urban services and for environmental impacts as a part of the general plan preparation
process. These areas are the most logical areas for residential use,representing contiguous
development and the location of housing near jobs.
Not implementing the City's General Plan,as suggested by the proposed amendments, would
eliminate up to half of the new dwelling units planned for in the City General Plan.This in tum has
substantial implications for the City's jobs/housing balance and on where or how the City would then
provide for 1%average annual population growth. Secondary impacts involve increased traffic and
vehicle emissions from more commuting,and possible conversion of nearby rural lands to residential
uses as the City seeks to implement its adopted housing policies in other areas.
Until the effects of the proposed amendments are completely mapped,the implications of the new
policies cannot be completely assessed.Providing accurate maps is the responsibility of the ALUC,
which is the lead agency in this matter.
The Margarita Area Specific Plan is a smart growth solution for improving the jobs/housing balance in
the City. Our staffs have worked to minimize the potential for noise to adversely affect new residents in
the Margarita Area and to guarantee avigation easements from all new development in the area. These
efforts should be carefully considered before starting the ALUP update process again from scratch.
Thank you for considering our comments.We anticipate your Commission making available the time and
information that will allow a complete evaluation of the proposed amendment.
Respectfully,
Allen K. Settle
Mayor
alup mayor letter.doc