ALUCP Draft DEIR Key Points

From the City of Coronado:

February 10, 2020

The San Diego County Regional Airport Authority (SDCRAA) released the Draft Environmental Impact Report (DEIR) related to the creation of the Naval Air Station North Island Draft Airport Land Use Compatibility Plan (ALUCP).

This proposed ALUCP will have implications on over 1,000 existing residential units in Coronado that will restrict how properties can be developed in the future. If adopted, the ALUCP would impose new development restrictions on properties located in the Clear Zone, Accident Potential Zone I, and Accident Potential Zone II, including new limits on density, allowable land uses, a prohibition of new subdivisions, and requirements for noise attenuation measures in new construction.

Because the DEIR for the ALUCP was released during the holidays, the City requested an extension to the comment period. SDCRAA extended the comment period by 10 days and is accepting comments on the DEIR through February 18, 2020. At the direction of the City Council, the City will submit a formal comment letter to the SDCRAA before the end of the extended comment period. A copy of the letter will be available as part of the February 18, 2020 City Council Agenda.

Key points on the ALUCP and its impacts on Coronado are provided below.

· The Airport Land Use Compatibility Plan exceeds the SDCRAA’s authority.
The guidelines that the San Diego County Regional Airport Authority (SDCRAA) must follow in preparing the Airport Land Use Compatibility Plan (ALUCP) require that the plan only apply to undeveloped land that is currently not in conflict with the airport. The SDCRAA’s plan is based on the premise that Coronado is encroaching into NASNI. However, Coronado is built out and was incorporated prior to the establishment of NASNI. Coronado has land uses existing decades before North Island was built. Therefore, the premise that Coronado is encroaching into North Island is a misinterpretation by the Airport Authority.

SDCRAA’s limited scope to plan for undeveloped areas with incompatible uses for an airport zone does not apply to Coronado.

· The ALUCP would place severe limits on further investment and development.
The ALUCP DEIR only considers the impacts to hotel/resort uses as significant and the impacts to other land uses, such as residential or commercial, as not significant. The draft environmental impact report (DEIR) failed to evaluate the resulting substantial loss in property value over the next fifty years for owners in the areas constrained by the ALUCP compared to those in Coronado that are not within the area. Consequently, the areas impacted by the draft ALUCP represents 26.5% of the City’s General Fund revenues.

The ALUCP DEIR does not include an analysis of the urban decay impacts caused by development restrictions and reduced investment in the area. Permitting for certain activities, e.g. adding residential square footage, would be negatively impacted and may not allow owners to make desired improvements to their properties.

Further, development restrictions could displace future land uses to other locations within the City, but the DEIR does not discuss the indirect impacts of displaced development on important concerns like traffic, noise, and air quality.

· The ALUCP DEIR incorrectly relies on an outdated, advisory document - the AICUZ.
The ALUCP is neither warranted nor required at this time as the AICUZ used to develop the ALUCP reached its expiration as of 2020.

Included in the AICUZ is a 2020 “future” scenario, developed ten years ago and based on data from 20 years ago. The results are no longer accurate because of outdated noise simulation models, changes in flight paths since 2011, an inaccurate mix of aircraft fleet mix (e.g. Osprey aircrafts are not included) and underestimated evening and night flights, etc.

The mandate to prepare an ALUCP for NASNI was suspended in 2010.

· The ALUCP DEIR alternatives analysis is flawed - none of the related mitigation measures or feasible alternatives in the AICUZ are included.

The ALUCP DEIR alternatives analysis is inadequate because it ignores any of the feasible alternatives available to the Navy that could reduce significant impacts, such as specific modified flight paths or changes in runway use.

· SDCRAA has prematurely approved the proposed ALUCP prior to completing the CEQA review.

The AICUZ document is an advisory document required by the Department of Defense. As an advisory document it does not require public review prior to its issuance. The ALUCP is a mandatory document, subject to the California Environmental Quality Act (CEQA) and therefore requires public review and comment.

SDCRAA insists that the 2011 advisory AICUZ must form the basis of the ALUCP. Thus the alternatives analysis provided in the ALUCP DEIR is inadequate for CEQA purposes because the 2011 AICUZ is no longer relevant. For example, the contours in the ALUCP DEIR showing noise and safety impacts are based on the outdated AICUZ document that had a horizon year of 2020 and does not account for changes in aircraft fleet mix, flight path, etc.

The AICUZ did not require public review or comment but is the foundation of the ALUCP. If the outcome of the ALUCP has already been pre-determined, and everyone’s “hands are tied”, there is a question as to the legitimacy of the public review and comment of the ALUCP.

Terms:

· Airport Land Use Compatibility Plan (ALUCP) – The State of California mandated that each county create an Airport Land Use Commission with the authority to adopt ALUCPs in 1970. The ALUCP is a guidance document to manage land uses in the vicinity of airports to promote compatibility with operations. By State law, once an ALUCP is adopted, affected local agencies must modify, as applicable, their general/master plan and zoning code to be consistent with the ALUCP. However, the State mandate to prepare an ALUCP for NASNI was suspended in 2010.

· Air Installation Compatibility Use Zone (AICUZ) – An advisory program document created by the Department of Defense evaluating land uses around military airfields with the goal of protecting the health, safety and welfare of the public and preserving operational capability. The last AICUZ for Naval Air Station North Island was completed in 2011 and can be found here: https://www.cnic.navy.mil/content/dam/cnic/cnrsw/Naval%20Base%20Coronado/Documents/2011%20NBC%20AICUZ%20Study%20(reduced%20size).pdf

· San Diego County Regional Airport Authority (SDCRAA) – Created on January 1, 2003, SDCRAA is an independent agency charged with managing the day-to-day operations of San Diego International Airport and addressing regional air transportation issues. The SDCRAA is governed by a nine-member board. Board Members are appointed, not elected and there is currently no representative specifically for the City of Coronado on the Board.

For the full list of draft Airport Land Use Compatibility Plan documents, visit: https://www.coronado.ca.us/government/departments_divisions/community_development/planning_and_zoning/current_projects

This press release was produced by the City of Coronado. The views expressed here are the author’s own.