The San Diego County Regional Airport Authority released the Draft Environmental Impact Report related to the creation of the Naval Air Station North Island Draft Airport Land Use Compatibility Plan.
This proposed Airport Land Use Compatibility Plan will have implications on more than 1,000 existing residential units and commercial properties in Coronado that will restrict how they can be developed in the future. If adopted, the Compatibility Plan 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 Draft Environmental Impact Report for the Compatibility Plan was released during the holidays, the City requested an extension to the comment period. The Airport Authority extended the comment period by 10 days and is accepting comments through Feb. 18. At the direction of the City Council, the City will submit its formal comment letter before the end of the extended comment period. A copy of the letter will be available as part of the Feb. 18, 2020, City Council agenda.
Key points on the Airport Land Use Compatibility Plan and its impacts on Coronado are provided below.
- The Airport Land Use Compatibility Plan exceeds the San Diego Regional Airport Authority’s jurisdiction.
The guidelines that the Airport Authority must follow in preparing the Airport Land Use Compatibility Plan require that the plan only apply to undeveloped land that is currently not in conflict with the airport. The Airport Authority’s plan is based on the premise that Coronado is encroaching into Naval Air Station North Island. However, Coronado is built out and was incorporated prior to the establishment of North Island. 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.The Airport Authority’s limited scope to plan for undeveloped areas with incompatible uses for an airport zone does not apply to Coronado. - The Airport Land Use Compatibility Plan would place severe limits on further investment and development.
The Airport Land Use Compatibility Plan Draft Environmental Impact Report 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 failed to evaluate the resulting substantial loss in property value over the next 50 years for owners in the areas constrained by the Airport Land Use Compatibility Plan compared to those in Coronado that are not within the area. Consequently, the areas impacted by the draft Compatibility Plan represents 26.5% of the City’s General Fund revenues.
The Airport Land Use Compatibility Plan Draft Environmental Impact Report does not include an analysis of the urban decay impacts caused by development restrictions and reduced investment in the area. Permitting for certain activities, for example, 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 Draft Environmental Impact Report does not discuss the indirect impacts of displaced development on important concerns such as traffic, noise and air quality. - The Airport Land Use Compatibility Plan Draft Environmental Impact Report incorrectly relies on an outdated, advisory document – the Air Installations Compatible Use Zones.
The Airport Land Use Compatibility Plan is neither warranted nor required at this time as the Air Installations Compatibility Use Zones, which was used to develop the Airport Land Use Compatibility Plan, reached its expiration as of 2020.Included in the Air Installations Compatible Use Zones document is a 2020 “future” scenario, developed 10 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, which excludes Osprey aircrafts, and underestimated evening and night flights.The mandate to prepare an Airport Land Use Compatibility Plan for North Island was suspended in 2010. - The alternatives analysis for the Airport Land Use Compatibility Plan Draft Environmental Impact Report is flawed. None of the related mitigation measures or feasible alternatives in the Air Installations Compatible Use Zones is included.
The Airport Land Use Compatibility Plan Draft Environmental Impact Report 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. - The San Diego County Regional Airport Authority has prematurely approved the proposed Airport Land Use Compatibility Plan prior to completing the California Environmental Quality Act review.
The Airport Land Use Compatibility Plan 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 Airport Land Use Compatibility is a mandatory document, subject to the California Environmental Quality Act and therefore requires public review and comment.The San Diego County Regional Airport Authority insists that the 2011 advisory Airport Land Use Compatibility Plan must form the basis of the Airport Land Use Compatibility Plan. Thus, the alternatives analysis provided in the Airport Land Use Compatibility Plan Draft Environmental Impact Report is inadequate for California Environmental Quality Act purposes because the 2011 Air Installations Compatible Use Zones is no longer relevant. For example, the contours in the Airport Land Use Compatibility Plan Draft Environmental Impact Report showing noise and safety impacts are based on the outdated Air Installations Compatible Use Zones document that had a horizon year of 2020 and does not account for changes in aircraft fleet mix and flight path.The Air Installations Compatible Use Zones did not require public review or comment but is the foundation of the Airport Land Use Compatibility Plan. If the outcome of the Airport Land Use Compatibility Plan has 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 Airport Land Use Compatibility Plan.
Terms:
- Airport Land Use Compatibility Plan – The state of California mandated that each county create an Airport Land Use Commission with the authority to adopt Airport Land Use Compatibility Plans in 1970. The Airport Land Use Compatibility Plan is a guidance document to manage land uses in the vicinity of airports to promote compatibility with operations. By state law, once an Airport Land Use Compatibility Plan is adopted, affected local agencies must modify, as applicable, their general/master plan and zoning code to be consistent with the Airport Land Use Compatibility Plan. However, the state mandate to prepare an Airport Land Use Compatibility Plan for North Island was suspended in 2010.
- Air Installations Compatibility Use Zones – 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 Air Installations Compatibility Use Zones document for Naval Air Station North Island was completed in 2011 and can be found here.
- San Diego County Regional Airport Authority – Created on January 1, 2003, the San Diego Regional Airport Authority is an independent agency charged with managing the day to day operations of San Diego International Airport and addressing regional air transportation issues. The San Diego Regional Airport Authority 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.
