Comments for the November 17, 2010 Planning Commission Public Hearing for the Big Wave EIR & Project Date: November 15, 2010 Commenter Agency Date 1 Ed Rosiak Calpilots 10/26/10 2 Anthony Garcia FAA 10/26/10 3 Barbara Kossy -- 10/19/10 4 Barry Liftland -- 10/25/10 10/26/10 5 Bill Kehoe -- 10/26/10 6 Bob Kline -- 10/27/10 7 Bonnie Dunham -- 10/26/10 8 Carolyn Maddux -- 10/13/10 9 Chris Porter -- 10/27/10 10 Christine Hanlon CGF 10/11/10 11 Chuck Duffy GSD 10/25/10 12 Clemens Heldmaier MWSD 10/18/10 10/26/10 10/27/10 11/9/10 13 Dana Kimsey League for Coastside Protection 10/26/10 14 David Schricker MWSD 10/25/10 15 David Skelly -- 10/28/10 16 David Vesprimi -- 10/26/10 17 Denise Aquila -- 10/22/10 18 Donald Freese -- 10/28/10 19 Gary Giovannoni -- 10/25/10 20 Geoffrey Perusse -- 10/27/10 21 Grace Maguire -- 10/19/10 22 Hal Bohner -- 11/9/10 23 Jack and MaryEm Wallace -- 10/27/10 24 Jack Sutton -- 10/26/10 25 James Porter County DPW, Airports Division 11/2/10 26 Jan Gray -- 10/14/10 27 Jennifer Castner -- 10/24/10 28 Jerry West -- 10/25/10 29 Jim Larimer -- 10/13/10 30 John Collins AOPA 10/26/10 31 Karen Hoexter -- 10/27/10 32 Kathryn Salter Carter MWSD 10/26/10 33 Ken King Sierra Club Loma Prieta Chapter Coastal Issues Committee 11/8/10 34 Kerrie DeMartini -- 10/27/10 35 Kevin Cooke -- 10/26/10 36 Kim Gainza -- 10/28/10 37 Kimberly Clark -- 10/27/10 38 Laurie Goldberg -- 10/25/10 39 Len Erickson -- 10/19/10 10/25/10 40 Lennie Roberts -- 10/15/10 11/10/10 41 Leslie OBrien -- 10/25/10 42 Lisa Carboni Caltrans 10/20/10 43 Lisa Ketcham Pillar Ridge Home Owners Association 10/11/10 10/19/10 10/26/10 44 Madeline Cavalieri CA Coastal Commission 10/26/10 45 Mark Woyshner MWSD 11/10/10 46 Marshall Ketchum -- 10/24/10 47 Mary Larenas -- 10/21/10 48 Mary Lou Williams -- 10/19/10 49 Matthew Clark -- 10/26/10 50 Merrill Bobele Sierra Club Coastal Issues Committee Loma Prieta Chapter 10/26/10 51 Mike Ferreira Sierra Club Loma Prieta Chapter's Conservation Committee 10/26/10 52 Mike Hagmaier -- 10/19/10 53 Nancy Horner GGNRA 11/10/10 11/11/10 54 Neil Merrilees MCC 9/29/10 10/26/10 55 Patty Lauritzen -- 10/24/10 56 Paul Perkovic MWSD 11/12/10 57 Peter Grenell San Mateo County Harbor District 11/8/10 58 Petra Syme -- 10/26/10 59 Robert L. Pilgrim -- 10/25/10 60 Rosabelle and Michael "Arvin" Lynes -- 10/23/10 61 Sandy Gainza -- 10/25/10 62 Sandy Hesnard Caltrans Aeronautics 10/25/10 63 Sara DeSoto -- 10/25/10 64 Sarah Damron Surfrider Foundation 10/19/10 65 Terry Gossett Californians for Property Rights 10/25/10 66 Vanessa Richter -- 10/25/10 67 Winter King, Shute Mihaly & Weinberger -- 11/9/10 PO Box 6868, San Carlos, CA 94070-6868October 26, 2010County of San Mateo, Planning and Building DepartmentAttn: Camille Leung455 County Center, 2nd FloorRedwood County CA 94063Subject: Final Environmental Impact Report (FEIR) for the Big Wave Wellness Center and Office Park Dear Ms. Leung, The California Pilots Associations mission is to promote and preserve the States airports. As a statewide volunteer organization, we work to maintain the States airports in the best possible condition. Previously, we provided comments to the Notice of Preparation for the Environmental Impact Report and the Draft Environmental Impact Report. We do not believe that any of the following concerns have been adequately addressed in the Final Environmental Impact Report. It should be noted CalPilots concurs with the letter from the FAA dated 7-8-2010. We also agree with the Letters from CalTrans Div of Aeronautics dated Nov 17 2008 and Dec 21 2009 as well as comments from AOPA. All express similar very serious concerns about the placement of housing of any kind this close to Half Moon Bay AirportThe California Pilots Association commends the County of San Mateo for this 1)worthwhile project. However, we are opposed to the project at its current location. It does a disservice to the low income, developmentally disabled (DD) children and adults the Big Wave Wellness Center hopes to serve, to be located approximately 300-(even if moved to 800-1000 feet) from Half Moon Bay Airport. This site will subject more than 70 people to the impacts attendant to a location so close to an airport such as safety and noise, etc. There is not a final depiction of the site plan available.The FEIR does not address the safety or other impacts of placing this project so 2)near the Half Moon Bay Airport. The site is inconsistent with the 2002 California Airport Land Use Handbook airport planning guidelines. These guidelines are a minimum. It is inconsistent as well with the Deeds and Restrictions that came with the Federal Governments allowance of County of San Mateo to operate and protect the airport from encroachment. It is not advisable to allow housing, or a medical facility at this location. Land Use Sensitivity Concerns related to Safety and Noise.1 a) Highly Risk-Sensitive Uses.Pg 2 CalPilots FEIR CommentsThe California Airport Land Use Planning Handbook, (the CalTrans Handbook) which is required to be referenced during CEQA analysis for projects within 2-miles of Public Use Airports, states the following:Certain critical types of land usesparticularly schools, hospitals, and other uses in which the mobility of occupants is effectively limitedshould be avoided near the ends of runways regardless of the number of people involved. b) Sensitive Uses. The CalTrans Handbook further states: This category includes land uses which, because of their special sensitivity, should be excluded from certain locations near airports even if they meet other quantitative criteria. Childrens schools, day care centers, hospitals, nursing homes, and other highly risk-sensitive uses are primary examples. No matter what you call this project (Sanitarium) it contains a vulnerable population who should not be placed near the Airport. Sanitarium is an inappropriate designation. c) School Site Reviews. Though not specifically a School Site, Two sections of the Education Code (17215 and 81033) solicit input from the Airport Land Use Commission (ALUC) for use by the California Department of Transportation (CalTrans) when evaluating such Sensitive Land Uses for schools that would be within two miles of an airport runway or potential runway included in an airport master plan. d) Wellness Center Location. The proposed Wellness Center certainly represents the criteria indicated above and should not be located at the proposed site, or within 2-miles of the airport.CalTrans Land Use Safety Zones Around Airports. a) State Law requires that the CalTrans Airport Land Use Planning Handbook (the Handbook) be used as a guide to protect the Public from new incompatible Safety and Noise Land Uses within 2-miles of Public Use Airports b) Beyond the FAAs Runway Protection Zones illustrated by the Planning Department, the Handbook also includes Six additional Safety Zones. The following ones appear to also apply to the proposed development. i) Inner Turning Zone (3) , which would be further offset 17 Degrees than illustrated in the Handbook over the proposed site location(s) to reflect the existing RNAV (GPS) Y RWY 30 instrument approach to the airport. The following limitations are applicable in this area: * Limit residential uses to very low densities (if not deemed unacceptable because of 2noise) * Avoid nonresidential uses having moderate or higher usage intensities (e.g., major Pg 3 CalPilots FEIR Commentsshopping centers, fast food restaurants, theaters, meeting halls, buildings with more than three aboveground habitable floors are generally unacceptable) * Prohibit childrens schools, large day care centers, hospitals, nursing homes * Avoid hazardous uses (e.g. aboveground bulk fuel storage) * The new SFO CLUP Zone 3 Maximum Density Criteria is 80 to 100 people per acre. ii) Sideline Zone (5), which parallels the runway: * Avoid residential uses unless airport related (noise usually also a factor) * Allow all common aviation-related activities provided that height-limit criteria are met * Limit other nonresidential uses similarly to Zone 3, but with slightly higher usage intensities * Prohibit childrens schools, large day care centers, hospitals, nursing homes * The new SFO CLUP Zone 5 Density criteria is 100 to 150 people per acre. c) The proposed Business Park and the Wellness Center both appear to encroach on these Safety Areas, and should be limited by the above criteria. d) The appropriate body to make determinations on the above concerns is the Airport Land Use Commission (ALUC). As stated in former CalTrans correspondence on these projects, the proposed action should be referred to the ALUC for further review and aDetermination.The Half Moon Bay Airport is a vital link in the National Transportation System. It is eligible for and has accepted Grants from the Federal Aviation Administration. When the County of San Mateo last accepted a FAA Grant, the County signed Grant Assurances as part of the contract with the FAA. The County thereby agreed to an obligation to maintain compatible land use zoning. This is Grant Assurance number 21.http://www.faa.gov/airports_airtraffic/airports/aip/grant_assurances/media/airport_sponsor_assurances.pdf321. Compatible Land Use. It (the County, acting as the sponsor) will take 3)appropriate action, to the extent reasonable, including the adoption of zoning laws, to restrict the use of land adjacent to or in the immediate vicinity of the airport to activities and purposes compatible with normal airport operations, including landing Pg 4 CalPilots FEIR Commentsand takeoff of aircraft. In addition, if the project is for noise compatibility program implementation, it will not cause or permit any change in land use, within its jurisdiction, that will reduce its compatibility with respect to the airport, of the noise compatibility program measures upon which federal funds have been expended.As we have seen above, in the FAA Grant Assurance, it is incumbent upon the County of San Mateo to protect the airport with zoning which would prevent the development of a project which is clearly incompatible to safe operation for Pilots at Half Moon Bay Airport as well as the residents, particularly low income, developmentally disabled (DD) children and adults on the ground.Failure to comply with these Grant Assurances could likely result in the loss of millions of dollars in future Federal Grants to the County.NOISE:Incorrect Noise Measurement Techniques Used by the County Planning Consultant: When addressing noise concerns in relation to airports and aviation, the appropriate modeling methodology to be used is the Integrated Noise Model (INM) as addressed in the Federal Aviation Regulations (FAR) Part 150 Airport Noise Compatibility Planning Program documents and procedures. An appropriate output would be Airport Noise Exposure Maps (NEMs) representing the yearly Day-Night-average-sound-Level (DNL) contours and also Single Event analysis. The procedure used by the County Planning Consultant did not appear to produce the appropriate Noise Planning information for a project that would be cited near an airport. No further action should be taken until this required INM information is provided and discussed in a public Workshop Format at the Airport Land Use Commission (ALUC). An example of inadequacy of the FEIR is Section V. General Impact Categories, Page V6 5. NOISE The proposed project is not located near a private Airfield therefore Thank you for this opportunity to comment on this important item.From the DEIR pg IV.G-25: Full compliance with all applicable Federal, State, Regional and Local regulations, Programs and Plans related to land uses in proximity to a public airport would be required was stated. However, the project has not followed FAA or State regulations, Programs and Plans related to land uses in proximity to a public airport and thus results in a very significant impact associated with airport safety hazards to people residing 4or working in the area of a public airport contrary to the stated intent.Respectfully submitted,s/sEd RosiakPresident California Pilots Association800 319 5286 erosiak@comcast.net5U.S. Department of Transportation Western-Pacific Region Airports Division P. O. Box 92007 Los Angeles, CA 90009-2007 Federal Aviation Administration Son Mateo County Afrport$ July 8,2010 Mark Larson Airport Manager Half Moon Bay Airport 620 Airport Drive San Carlos, CA 94070 Dear Mr. Larson: Half Moon Bay Airport Planned Wellness Center JUL 1 2 2010 RECEIVED We are providing comments regarding the proposal to construct a Big Wave Wellness Center (Center) next to Half Moon Bay Airport (HAF). Based on the information available to us, the Center will be built approximately 500 feet west of runway 30. The presence of a center for the developmentally disabled that is so close to the runway represents a use that is not compatible with normal airport operations. Therefore, it is our determination that the selected site is not appropriate. An alternative site outside HAF's influence area should be used for the Center. San Mateo County is reminded of the requirements of Assurance 21, Compatible Land Use. Airport sponsors are required to take appropriate action to restrict the use of land adjacent to the airport to activities that are compatible with normal airport operations. Clearly, a clinical residential center serving disabled patients would not be considered a compatible use so close to the airport and its runway. Even if the center is not inside the noise contours of HAF, aircraft operations will have some disturbing impact on the Center. Its occupants will surely be aware of normal airport operations because aircraft over-flight noise will occur. The duration and intensity of the noise, even if it is intermittent, will likely be deemed to be an undesirable nuisance by occupants and residents of the center. From a practical perspective, the consequences of incompatible land uses should not be taken lightly. The airport's neighbors will surely complain about airport noise. Incompatible land uses such as the Center will eventually provoke persistent criticism related to noise, safety, and emissions. Once incompatible land uses are established, it is the airport that is expected to undertake remedial action to mitigate the offending irritants. For example, the San Mateo County General Plan was formulated to "promote and protect the public health, safety, peace, morals, comfort, convenience and general welfare." Additionally, the "Airport Land Use Plan includes policies, standards, and criteria to address each of these issues to assist local agencies to achieve land use compatibility with existing and future airport development and operations." .J 2 Yet, because of incompatible land uses in the vicinity ofHAF, "the County has implemented noise abatement procedures at HAF to further reduce aircraft noise impacts in the surrounding noise sensitive areas." The above example discloses the land-use incompatibility shortcoming related to the proposed location of the Wellness Center. The planning and environmental documents proffer that there will not be any negative environmental impacts related to the proximity of the Center to the airport. However, experience actually reveals that the opposite is true. Inevitably, the Center's users will complain about the airport. The unfortunate public policy reaction to the complaints will inevitably be proposals to impose additional restrictions on normal airport operations. Historically, case after case shows that incompatible land use becomes a quality of life issue for the airport's neighbors and, thereafter, a losing proposition for the airport. For these reasons, we must express our objection to the proposed site of the Wellness Center. If you have any questions, please call me at 310-725-3634. on 'a Airports Compliance Program Manager! Safety-Certification Inspector Western-Pacific Region P. O. Box 92007Airports Division Los Angeles, CA 90009-2007October 26, 2010Mark LarsonAirport ManagerHalf Moon Bay Airport620 Airport DriveSan Carlos, CA 94070Dear Mr. Larson:Half Moon Bay AirportPlanned Wellness Center Follow-Up CommentsIt is our understanding that San Mateo County (County) may remain in favor of the Wellness Center being built next to Half Moon Bay Airport although it represents an incompatible land use. We wish to remind the County that protecting people on the ground from aircraft noise, emissions, and the potential consequences of near-airport aircraft accidents are fundamental reasons for establishing good compatible land use practices. People react differently to noise and the threat of exhaust emissions, but inevitably some will react negatively and actively seek to extinguish the noise irritant or pollutant. If Center residents do not speak out, family or advocates may lead the protests. They will incessantly complain to government officials and demand limitations be placed on the airport and aircraft operations. The airport will be perceived as the cause of the problem when, in reality, the real cause is incompatible land use.As a substitute for good compatible land use planning, sound insulation and buyer notification become the typical, less-effective noise mitigation measures to reduce the negative consequences of incompatible land use development. However, these measures do not change exterior aircraft noise levels and have no appreciable effect on individual responses to noise. Furthermore, they become less effective if noise occurrences increase as a result of increased aircraft operations or the types of aircraft operations. Therefore, noise mitigation measures are not a substitute for good land use compatibility planning The protection of airports from incompatible land use encroachment is vital to Californias economic future and the financial well being of the airport itself. Airports serve the local and national interest. They facilitate transportation and commerce. They provide for the national defense and serve the public good in times of calamity and emergency. Airports are invaluable because they are irreplaceable. By way of comparison, one can replace a house almost anywhere, but an airport could never be replaced in any of the developed areas of California. Therefore, airports, such as Half Moon Bay, must be preserved and protected.Compatible land use is an obligation that the County pledged to uphold when it made legal commitments to the federal government in exchange for financial assistance. Ordinarily, grant funding is the incentive motivating airport sponsors to comply with the Grant Assurances. The County may not be concerned with future entitlement to FAA grant funding, but the County should be concerned with the health, welfare, personal rights, and the quality of life of the residents who might have to live and work next to an active airport. The County will be responsible for the reduction in any of these measures of well-being. The Airport Improvement Program cannot compensate impacted residents for any diminution of their quality of life. If residents complain about the airport, it will be the Countys responsibility to compensate them for their perceived harm or loss. In the future, the airport should not be blamed for the irritation caused by noise and emissions or the loss caused by an aircraft accident. Furthermore, the airport should not be penalized in any way or made to suffer a reduction in its utility to serve civil aviation or the rights of aviators who want to use the airport. The liability for incompatible land use will lie at the door of the County and not the airport if the County makes a decision to allow incompatible land use next to Half Moon Bay Airport. Sincerely,Or i gi nal Si gned byTony Gar c i aTony GarciaAirports Compliance Program Manager2U.S. Department of Transportation Federal Aviation Administration October 26, 2010 Mark Larson Airport Manager HalfMoon Bay Airport 620 Airport Drive San Carlos, CA 94070 Dear Mr. Larson: Western-Pacific Region Airports Division Half Moon Bay Airport Planned Wellness Center Follow-Up Comments P. O. Box 92007 Los Angeles, CA 90009-2007 Son Mateo County Airports OCT 29 2010 RECEIVED It is our understanding that San Mateo County (County) may remain in favor of the Wellness Center being built next to HalfMoon Bay Airport although it represents an incompatible land use. We wish to remind the County that protecting people on the ground from aircraft noise, emissions, and the potential consequences of near-airport aircraft accidents are fundamental reasons for establishing good compatible land use practices. People react differently to noise and the threat of exhaust emissions, but inevitably some will react negatively and actively seek to extinguish the noise irritant or pollutant. If Center residents do not speak out, family or advocates may lead the protests. They will incessantly complain to government officials and demand limitations be placed on the airport and aircraft operations. The airport will be perceived as the cause ofthe problem when, in reality, the real cause is incompatible land use. As a substitute for good compatible land use planning, sound insulation and buyer notification become the typical, less-effective noise mitigation measures to reduce the negative consequences of incompatible land use development. However, these measures do not change exterior aircraft noise levels and have no appreciable effect on individual responses to noise. Furthermore, they become less effective if noise occurrences increase as a result of increased aircraft operations or the types of aircraft operations. Therefore, noise mitigation measures are not a substitute for good land use compatibility planning The protection of airports from incompatible land use encroachment is vital to California's economic future and the financial well being of the airport itself. Airports serve the local and national interest. They facilitate transportation and commerce. They provide for the national defense and serve the public good in times of calamity and emergency. Airports are invaluable because they are irreplaceable. By way of comparison, one can replace a house almost anywhere, but an airport could never be replaced in any of the developed areas of California. Therefore, airports, such as HalfMoon Bay, must be preserved and protected. Compatible land use is an obligation that the County pledged to uphold when it made legal commitments to the federal government in exchange for financial assistance. Ordinarily, grant funding is the incentive motivating airport sponsors to comply with the Grant Assurances. The County may not be concerned with future entitlement to FAA grant funding, but the County should be concerned with the health, welfare, personal rights, and the quality oflife of the residents who might have to live and work next to an active airport. The County will be responsible for the reduction in any of these measures of well-being. The Airport Improvement Program cannot compensate impacted residents for any diminution of their quality of life. If residents complain about the airport, it will be the County's responsibility to compensate them for their perceived harm or loss. 2 In the future, the airport should not be blamed for the irritation caused by noise and emissions or the loss caused by an aircraft accident. Furthermore, the airport should not be penalized in any way or made to suffer a reduction in its utility to serve civil aviation or the rights of aviators who want to use the airport. The liability for incompatible land use will lie at the door of the County and not the airport if the County makes a decision to allow incompatible land use next to Half Moon Bay Airport. From: "Barbara Kossy" To: , CC: "sabrina brennan" , "Lisa Ketcham" ;2 j \A'c lhl' to on ihc i-ina{ Fnvirufinh.:ntaj Rej")J.lj"l (FEH