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HomeMy WebLinkAboutPlanning Commission 2012-05-29 #2 MemoCommunity Development Department MEMORANDUM DATE: May 17, 2012 TO: Planning Commission Chair Viktoriya Wise, and Planning Commissioners FROM: Kraig Tambornihi, Senior Planner SUBJECT: May 29, 2012 Planning Commission Public Hearing Addendum to March 27, 2012 Staff Report — Response to Caltrans Division of Aeronautics Airport Safety Comments; 397-400 Smith Ranch Road (San Rafael Airport Recreational Facility) Background The above project previously was scheduled for hearing on March 27, 2012. That meeting date was cancelled (after publication of staff's report to the Commission) in order to allow time for staff to evaluate a March 9, 2012 letter received from the State of California Caltrans, Division of Aeronautics. The Caltrans Division's letter points out a recent change to its California Airport Land Use Planning Handbook (Handbook) published for purpose of evaluating development near public use airports for safety and noise compatibility. The Handbook has been relied upon by Mead & Hunt, the airport safety consultant that was hired by the City to evaluate this project. Mead & Hunt was the primary consultant responsible for development of the 2002 Handbook and also served as a consultant for the 2011 Handbook. The Handbook provides general compatibility guidance to local agencies and the public in developing land use plans surrounding public use airports. Development around public use airports is subject to review by Airport Land Use Commissions (ALUC's), which are responsible for developing land use compatibility plans utilizing the Handbook for guidance. Marin County has one public use airport, Gnoss Field, and the County of Marin Planning Commission serves as the ALUC and reviews development projects near that airport. San Rafael Airport is a private airport and, therefore, it is not subject to an ALUC and does not require a land use compatibility plan. The City maintains responsibility for evaluating development on and near the San Rafael airport, for compatibility and compliance with the San Rafael General Plan 2020. Since the San Rafael airport is not subject to an ALUC and related compatibility plan, the Caltrans Division was consulted and provided advisory comments for the City to consider in evaluating the project. To assist with this function City staff decided to utilize the Handbook for guidance, and hired Mead & Hunt as the City's technical expert regarding the Handbook's relevance to the project and to evaluate safety and compatibility issues. The primary intent of this memorandum is to update the Commission on staff's findings and conclusions regarding airport safety in light of the most recent Caltrans Division letter. This additional review evaluates the project in light of the revised guideline criteria, as recommended by Caltrans, but it is not based upon any change in the physical characteristics of the airport or project site or surrounding environment. In response to the Divisions recent letter, Mead & Hunt has recommended additional safety measures; summarized on Page 5 of this memorandum. Additionally, City staff has included a response to comments received from Marin County Public Works regarding levee maintenance obligations, and provides updated project recommendations. The topics covered in this memorandum have been arranged as follows: ➢ Staff Recommendation (Page 2) ➢ Review of Caltrans Division of Aeronautics Airport Safety Comments (Page 3) ➢ Review of General Plan 2020 Policies (Page 6) ➢ Review of Marin County Department of Public Works Levee Maintenance Comments (Page 6) 7�W Community Development Department MEMORANDUM Staff Recommendation The Planning Commission must provide its recommendation on this development project to the City Council, because the project includes a PD rezoning. As a reminder, the policy of the Planning Commission requires that a motion to recommend approval of the PD rezoning must pass with an affirmative vote by four members (i.e., a minimum of four members and not just a majority of those present). The staff report published March 27, 2012 noted that the recreational facility project had been recommended for approval in 2006, before the Project EIR was required and completed. At that time, the project did not include a lighted outdoor field with extended outdoor evening hours, and proposed to be closed between 4pm and 6pm. After the Planning Commission completed its January 24, 2012 review of the Project FEIR (i.e., environmental analysis) no new concerns were uncovered that caused staff to materially alter its previous recommendation for approval, nor recommend a change in scope or design of the project. There have, however, been a number of concerns raised during hearings held on the project and the Project FEIR that are discussed in the March 27, 2012 report. Airport safety in relation to this project is an issue that has received substantial attention and detailed study. Therefore, in light of the March 9, 2012 letter from the Caltrans Division, staff requested that Mead & Hunt prepare an additional evaluation and response to the Division's comments. Mead & Hunt's response has resulted in some additional recommended project mitigations being proposed that respond to the specific concerns of Caltrans. Staff has further augmented its recommendation for this project, in light of this additional airport safety evaluation, and recommends that the Planning Commission consider the following options: Continue the matter with direction from the Commission concerning any additional modifications that the Commission deems necessary to support the project, including consideration of the new airport safety mitigations proposed by Mead & Hunt (staff recommended). 2. Adopt Resolution's recommending that the City Council adopt the following: a. CEQA Findings of Fact and Mitigation Monitoring and Reporting Program for project approval b. PD Rezoning Ordinance, and c. Master Use Permit and Environmental and Design Review Permit, with conditions. 3. Reject the project and direct staff to draft resolutions to deny the PD Rezoning, Master Use Permit and Environmental and Design Review. Following the recent additional airport safety review, staff has concluded that the project appears to remain in conformance with all applicable General Plan 2020 goals and policies, and could be supported with appropriate conditions of approval. It is recommended that the Commission conduct a hearing on project merits in order to consider all additional testimony, including this memorandum and the March 27, 2012 staff report, and continue the project for revision to address the outstanding identified merits issues. This would include but not be limited to; i) incorporation of any additional airport safety requirements that the Commission deems appropriate (including those listed on page 5 of this memorandum), ii) clarification of levee maintenance responsibilities, and iii) confirm and establish the appropriateness of proposed site design, intensity of use, outdoor field lighting, indoor and outdoor hours of operation, other use limitations including proposed alcohol sales, and project climate change strategies. 2 Community Development Department r' MEMORANDUM If the Commission determines site or building design changes should be required in order to support the project (including any additional building design modifications listed in the Mead & Hunt report to further fortify the building structure; e.g., concrete walls, etc.) it may be appropriate or necessary for the project to return to the Design Review Board for its recommendation. If the design implications are substantial, this should occur before staff returns to the Commission with any revised resolutions, findings, and conditions for the project. Review of Caltrans Division of Aeronautics Airport Safety Comments The Caltrans Division of Aeronautics Handbook is used by Airport Land Use Commissions (ALUC's) for developing land use compatibility plans for public use airports; which identify safety and noise compatibility parameters for surrounding development and expansion of an airport facility. The Handbook provides safety zone configurations and associated risk factors that can be used to evaluate and determine land use compatibility within the area around an airport (page 25 of the January 24, 2012 FEIR Staff Report provides detailed discussion of the safety zones). In Marin County, the County Planning Commission serves as the ALUC for Gnoss Field, which is the only public use airport in Marin. Compatibility plans developed for areas around public use airports must be guided by the Handbook. Caltrans also reviews these compatibility plans for the ALUC's, and local jurisdictions consider the ALUC compatibility plans when developing general plan land use designations for incorporated areas that lie within ALUC plan boundaries. Caltrans is responsible for issuing an Airport Permit for the San Rafael Airport facility. It has granted permit Mrn-005 for this facility to operate under the category of "special -use airport" (i.e., an airport not open to the general public, access to which is controlled by the owner in support of commercial activities, public service operations, and/or personal use; California Code of Regulations Title 21 Sections 3525 through 3560). A copy of the Airport Permit is attached. Caltrans regulates the airport facility only, and not the surrounding land uses. The proposed project has not been found to conflict with any of the conditions of the Airport Permit. The airport is privately owned, and pursuant to the existing City Zoning and Use Permit approvals granted for the airport use, only pilots who hangar airplanes at the site are permitted to use the facility; which is limited to 100 -based aircraft. The airport has no control tower thus no commercial flights are allowed and, due to the size of the runway, it is limited to use by small aircraft. The airport permits visual approaches only, with sight of runway required for pilots to land at the airstrip. In inclement weather with low visibility, such as severe fog conditions that impede visibility of the runway from the approach elevation (e.g., 1,000 feet) pilots must land at another airstrip that provides for instrument -based landings. Because this is a private use airport, there is no ALUC authority and no land use compatibility plan required for the site and surrounding land uses. Accordingly, and separate from Caltrans' permitting of the airport facility operations, the City maintains the discretionary land use authority over development on the airport property and on properties within the airport safety zones (that fall within the City's jurisdiction). Therefore, the City hired Mead & Hunt to evaluate and provide guidance on the proposed recreational facility development project given its proposed location adjacent to the active San Rafael Airport runway. Mead & Hunt relied on the 2002 Caltrans Division of Aeronautics handbook in conducting its evaluation of this development project. Building design constraints and intensity of use limitations were examined. Mead & Hunt also reviewed the 2011 Handbook revisions prior to the January 24, 2012 Commission hearing on the FEIR, and had concluded that the text changes did not alter any of its findings regarding airport safety. 3 Community Development Department MEMORANDUM In its March 9, 2012 updated comment letter, Caltrans Division of Aeronautics notes that the project is in safety zone [2] & 5 and that the updated 2011 Handbook recommends prohibiting group recreational uses in the subject safety zones. Caltrans' comment letter specifically recommends: "special considerations should be given to facilities that cater to children such as recreation and sports facilities and Caltrans asks that the City of San Rafael to consider this new information in future decisions regarding this project. " The letter also mentions concerns with the potential for intrusions into the 7:1 transitional surface zones (i.e., building and parking spaces). These previously were identified and discussed during the FEIR review process. The FEIR has recommended installing signage that restricts parking spaces proposed closest to the runway to compact spaces. Parking lot grading could be further adjusted, or parking areas relocated, to avoid potential intrusion of vehicles into the transition zones. Detailed construction drawings, surveys of finish grades and building elevations would be required to confirm that building improvements would not encroach within the transition safety zones. The 2011 Handbook recommending that "group recreation" uses should be prohibited within airport safety zones does not provide any qualifying factors or a definition of the term "group recreation uses." t The term "group recreation" is not contained in the 2002 Handbook either, but "outdoor stadiums" are referenced as an assembly use recommended as prohibited in safety zone 6.$ The term "group recreation" can be viewed to encompass a wide range of low to high intensity uses including outdoor sports fields, indoor gymnasiums, health clubs, assembly uses such as theaters, and sports stadiums. Mead & Hunt does not consider golf courses and public parks to be "group recreation". If this new guideline is applied without qualification, any group recreation use including low intensity recreational uses would be excluded from placement within airport safety zones. Given the recent change to the Handbook there have been no recent ALUC compatibility plans prepared that have been required to apply this new guideline. It appears that the Division's concerns are with facilities that cater to children, facilities with high intensity usage, and facilities creating confined spaces; hence the express inclusion of children's schools, assembly facilities and stadiums -- uses that seem to have fairly uniform and recognizable building and use characteristics, and would likely exceed occupancy intensity standards. Mead & Hunt met with Caltrans Division staff via a conference call in order to gain a better understanding behind its decision to include group recreation as a recommended prohibited use in the Handbook under its basic compatibility polices for the safety zones. As stated in its letter, Caltrans Division explicitly recommends that special considerations should be given to facilities that cater to children, such as recreation and sports facilities. In Mead & Hunt's response, they note that the Division specifically has three concerns with the project: Caltrans acknowledges that their letter incorrectly identified Safety Zone 2 as Safety Zone 3. t http://www.dot.ca.gov/hg/planning/aeronaut/documents/AirportLandUsePlanningHandbook.pdf $ http://www.dot.ca.gov/hq/planninq/aeronaut/documents/ALUPHComplete-7-02rev.pdf - Chapter 9 of the 2002 Handbook recommends "prohibit outdoor stadiums and similar uses with very high intensities in safety zone 6". Further, the 2002 Handbook distinguishes between uses in structures vs. outdoor uses; noting "buildings provide substantial protection from the crash of a small airplane..." and that "people outdoors have more of a chance to see a plane coming as well as more directions in which they can move to vacate the impact area. A greater concentration of people thus is sometimes considered acceptable for such land uses." It is further noted that an exception shall be made with regard to large "open stadiums and other similar uses where a large number of people are confined in a small area with limited exits. Such facilities can represent equal or higher risks than similar uses in buildings." 4 ➢ Project location within Safety Zones ➢ Group Recreation use ➢ Airspace Penetration potential Community Development Department MEMORANDUM Mead & Hunt has summarized the Division's concerns and discussed these relative to the aeronautical and land use compatibility factors pertinent to this site. Principal concerns with group recreation are spectator -oriented facilities that draw large groups of people within confined spaces and the presence of young children who may not respond appropriately to get out of harm's way. The project maintains a low to moderate risk level based on Handbook guidelines (see 2011 Handbook excerpts attached to Mead & Hunt's letter for description of the `Nature of Risk' and 'Basic Compatibility Policies' for the respective safety zones 2 and 5), and there have been no physical changes to the site or the manner in which the airport operates that would materially alter the original airport safety assessment. Thus, based on the characteristics of the project and the airport facility operations, the project would remain conditionally compatible with the airport; i.e., physical and operational constraints associated with the airport result in a low risk level to occupants on the proposed site and to aircraft in flight. Nevertheless, Mead & Hunt has augmented its recommendations to address Caltrans heightened concerns, as follows: Revised Airport Safety Measures 1. Incorporate the two mitigation measures for enhanced exiting and fire sprinkler systems (as currently required in the FEIR). 2. Post maximum occupancy signage for 480 people inside the building (note: this occupancy level accommodates the maximum occupancy level of 345 people anticipated to be inside the recreational building during peak usage§). 3. Post maximum occupancy signage for 336 people for the outdoor soccer field area (note: this occupancy level accommodates the maximum occupancy anticipated for the soccer field and is set at the low end of the 2011 Handbook's acceptable intensity range). 4. Post maximum occupancy signage for 104 people in the outdoor warm-up area (note: this occupancy level exceeds the range anticipated for the warm-up field and is set at the low end of the 2011 Handbook's acceptable intensity range). 5. Post clearly marked exit gates and fencing around the outdoor field areas to further enhance safety in outdoor field areas. 6. Install and maintain fencing (chain link or equivalent) between the recreation and airport facilities to prevent trespass by children onto the airfield and protect site from any potential accident from planes that could veer off the runway; with a barrier that complies with FAA Advisory Circular 150/5370-10B, Standards for Specifying Construction of Airports, Item F-162, Chain Link Fences. 7. Prohibit installation of fixed -seating, including temporary bleachers, around the outdoor field areas; to avoid creating confined spaces and higher than anticipated per -acre intensity occupancy levels. 8. Prohibit conduct of any special events that would draw a large number of people to the site that would exceed the above -noted occupancy limits established for the recreation facility use. § The discussion beginning on Page 27 of the January 24, 2012 Planning Commission Staff Report provided detailed information on the anticipated occupancy calculation. 5 Community Development Department �j MEMORANDUM Based on Mead & Hunt's analysis, the overall risk exposure is deemed minimal for the proposed use given the low activity of the airport, limitations on the airport's use and the location of the project near the middle of the runway rather than close to the runway ends; provided that all recommended airport safety measures are included. Caltrans has further recommended the project verify it would not penetrate protected airspace (the Mead & Hunt report noted that portions of the building and parking spaces near the runway may slightly encroach within the airspace). In order for the project to be supported revisions would need to be incorporated into the project plans and/or a part of project conditions of approval that address the above safety measures and assure that no penetration of protected airspace would occur. Mead & Hunt also has suggested that the Commission could include other building fortifications -- such as increased roof strength, elimination of windows and skylights, and concrete wall construction -- if desired by the Commission to support the proposal. However, the building mitigations recommended in the FEIR (i.e., enhanced exits and fire sprinkler systems) and augmented recommendations listed above address the safety risks for the project. Review of General Plan 2020 Policies The City General Plan 2020 promotes general health & safety and general welfare of the community through implementation of goals, policies and objectives identified as important by the residents of San Rafael. It is expected that implementation of the general plan would promote the values and character of the community. Therefore, in making its land use decisions, the City must consider and weigh all of the policies determined to be applicable to a development project. All pertinent policies have been identified and evaluated in Exhibit 4a of the March 27, 2012 Staff Report. However, deference must be given to safety-related policies. The City General Plan 2020 current Airport/Recreation land use category identifies the site as having valuable recreation and environmental characteristics, with airport, recreational and utility uses being designated as appropriate land uses for the property. The Noise Element does provide airport— related noise contours, for determining noise related compatibility. However, there are no airport land use compatibility policies in the General Plan 2020 Land Use or Safety elements specifically addressing safety. The following general Safety Element Policy is deemed applicable in this case: "S-1. Location of Future Development. Permit development only in those areas where potential danger to the health, safety and welfare of the residents of the community can be adequately mitigated." The Handbook has been relied upon to evaluate the proposed recreational development near the active private San Rafael airport facility (the airport operator also relies upon the Handbook to maintain their facility in compliance with the FAA and Division of Aeronautics standards). The Mead & Hunt airport safety analysis provides the information needed to determine compliance with this policy, and concludes that the development would not create unacceptable safety risks to aircraft or occupants using the facility with the inclusion of measures specified in its report. Review of Marin County Department of Public Works Levee Maintenance Comments The City also has received a recent letter from the County Department of Public Works (March 21, 2012, attached) that clarifies the County's position that it does not have maintenance obligations for portions of the levee surrounding the airport site that fall within County jurisdiction. Thus, the airport property owner maintains the primary incentive and responsibility for assuring the levees are maintained in good repair and condition. As noted in prior staff reports, the County cannot enter into a joint maintenance agreement with the owner for this levee system, which has not been designed to flood standards and is not in the flood control district. However, County DPW would issue grading 9 Community Development Department MEMORANDUM permits for the airport owner to maintain those sections of the levee that are within County jurisdiction. Revisions to the Use Permit draft conditions 8 & 9 are necessary to clarify that the airport property owner has a principal interest in maintenance of this levee system. Staff also notes that the site and building design have been developed to respond the fact that the site is not protected by engineered levees, and, therefore, is more susceptible to potential flooding. impacts. Accordingly, the building must be flood -proofed to preclude penetration by floodwaters, and the driveway has been elevated to permit emergency vehicle access in the event of site flooding. Conclusion The updated airport -safety review completed by Mead & Hunt has considered the private airport's characteristics and the intensity of recreational use being proposed in airport safety zones 2 & 5, and concluded that safety concerns can be mitigated. The project could be approved with conditions that incorporate the safety measures recommended by Mead & Hunt, and conditions recommended by staff to assure the use would remain compatible with the adjacent airport operations and surrounding residential, recreation and open space land uses. If deemed appropriate, the Commission should direct the applicant and staff to make changes to the project as necessary to support an approval for private recreational uses. Staff will forward copies of public comments received after publication of the March 27, 2012 staff report and any additional information received on this project to the Planning Commission prior to or at the May 29, 2012 hearing. Attachments 1. Mead & Hunt's May 16, 2012 response to Caltrans Division's letter, with attachments 2. Caltrans Division of Aeronautics March 9, 2012 letter 3. City of San Rafael April 10, 2012 response to Marin County DPW letter 4. Marin County DPW March 21, 2012 letter 5. San Rafael Airport Caltrans Permit 7 Mead §A lunt May 16, 2012 AIc.Id& fhint. In r. AIN 11 Au ho o I ure, III(. S i Ant W,IF1 M.144-wP11. Rliir '100 5.ifl rd RGIS I, f 111141 i4ld 751111 7117--1+,11010 nwadi imIt.onro Mr. Kraig Tambornini Sent via E-mail Senior Planner City of San Rafael 1400 Fifth Avenue, Room 202 San Rafael, CA 94901 Subject: Caltrans Division of Aeronautics Comment Letter on the San Rafael Airport Recreational Facility — Mead & Hunt Responses Dear Mr. Tambornini: As requested by City Planning staff, this letter provides Mead & Hunt's (M&H) response to the comment letter submitted by Caltrans Division of Aeronautics (Division) on March 9, 2012, regarding the proposed San Rafael Airport Recreational Facility (Project). On March 22, 2012, M&H participated in a conference call with Division staff Terry Barrie, Chief, Office of Aviation Planning, and Ron Bolyard, Associate Environmental Planner, to discuss the contents of the letter. The conclusions of this meeting are summarized below. At the City's discretion, the City may wish to use the information provided in this letter to formally respond to the Division's letter. In October 2011, the Division published a new edition of the California Airport Land Use Planning Handbook (Handbook). Although the Handbook did not change appreciably from the earlier edition in terms of airport land use compatibility guidance, there is one notable change that affects the proposed Project. As indicated in the Division's letter, "group recreational uses" has been added to the list of prohibited uses for the area adjacent to runways (Safety Zone 5). The prior editions of the Handbook did not include this prohibition. The Handbook defines a "prohibited use" as a use that should not be permitted under any circumstances. The Handbook, however, does not provide a definition for a group recreational use or the rationale for this new prohibition. Based upon our discussions with Division staff, they appear to have added group recreation to the list of prohibited uses for two reasons. One is that, as a "group" activity, it was presumed that the use would exceed the usage intensity (people per acre) limits suggested by the Handbook. Second, group recreation was presumed to cater to children and therefore should be restricted -in the same manner as a children's school. Therefore, where the previous Handbook edition recommended prohibition of schools, Division staff added group recreation. It should be recognized that the Handbook provides general compatibility planning guidance to local agencies and the public. The Handbook does not consider the unique operational characteristics of an Mr. Tambornini May 16, 2012 Page 2 airport or specific qualities of a land use proposal. For this reason, the purpose of this letter is to reemphasize the aeronautical and land use compatibility factors that we believe make this Project conditionally compatible with the San Rafael Airport. As noted in our 2008 Technical Report, any project that is located in proximity to an active airport is exposed to some level of risk of an aircraft accident. For San Rafael Airport, the probability of an aircraft accident occurring on the Project site is considered to be remote given the low -activity of the airport and the location of the site near the middle of the runway rather than close to the runway ends. Furthermore, other limitations on the airport's use along with proposed characteristics of the Project itself will also serve to limit the risks to the facility's users. Nonetheless, a community's perception of risk can vary. For this reason, the discussion below provides optional mitigation measures beyond what were provided in our 2008 report for use by the Planning Commission/City Council in addressing the community's concerns. Division Comments The Division's March 9, 2012 comment letter raised the following three concerns: ➢ Project Location within Safety Zones: In its letter, the Division contends that the Project is located in Safety Zones 3 and 5 while M&H's 2008 Technical Report indicates the Project's location in Zones 2 and 5. As can be seen in Attachments A and B, the Project is clearly within Zones 2 and 5 according to the 2011 California Airport Land Use Planning Handbook (Handbook). In our conference call, Division staff indicated that the report graphics were unclear but concurred that the Project is located in Zones 2 and 5. ➢ Group Recreation: As described above fundamentally, the Project is a group recreation use which the 2011 Handbook recommends prohibiting in Safety Zones 2 and 5. Notably, prior editions of the Handbook did not include a similar prohibition. The Division's principal concern is with large spectator -oriented facilities attracting large groups of people to confined spaces. The presence of young children who may not appropriately respond to get out of harm's way is also of concern. The Division's letter requests that special attention be given to the protection of children. This topic is further discussed below as it is the most complex issue raised by the Division. ➢ Airspace Penetration: The Division's letter indicates that obstructions to the airport's airspace surfaces associated with new development could compromise the airport's Operational Permit issued by the Division. The Division will typically accept obstructions on one side of the runway, but not both. The Division noted concern with the row of parking nearest the airfield. Based on comments provided by city planning staff, we informed Division staff that this row of parking would be relocated. Note that although not specifically mentioned in the Division's letter, the building parapet, field lights and proposed landscaping would also penetrate the airport's airspace surfaces. Final grading and design of the site and selection of a shorter variety tree species would likely remove these airspace concerns. Mr. Tambornini May 16, 2012 Page 3 Aeronautical and Land Use Compatibility Factors The discussion below identifies the aeronautical and land use factors which we believe make the Project conditionally acceptable with the San Rafael Airport. Aeronautical Considerations If the San Rafael Airport were a busy public -use facility, the Project would clearly be an incompatible use. Instead, the airport is unique in that it is a private -use facility whose operations are severely constrained by aeronautical factors and the requirements of the Conditional Use Permit issued by the City. These constraints are discussed below. ➢ Physical Constraints: The airport has a very short runway length of 2,140 feet. This length restricts use of the airport to mainly small, light general aviation aircraft. Generally, in the event of an accident, less damage to buildings would be produced by smaller, slower aircraft than by larger, faster ones. The runway is not equipped with a straight -in instrument approach procedure (e.g., GPS). This means that all flights are conducted only under visual and good weather conditions. Based on the accident data provided in the 2011 Handbook, general aviation accidents tend to be fewer and the consequences less severe under visual and good weather conditions. The runway is not served by a parallel taxiway. Without a parallel taxiway, aircraft must taxi on the runway to access the ramp area. For busy airports, a parallel taxiway can enhance safety of the runway system by allowing aircraft to exit the runway environment. Safety at the San Rafael Airport is not significantly compromised without a parallel taxiway for three reasons: 1) activity at the airport is low; 2) pilots are very familiar with the airport's facilities, or lack thereof, because operations are restricted to only those based at the airport; and 3) pilots communicate with each other using a radio frequency specifically established for the airport (Unicom 122.7) and are thus aware of other pilots in the airport's operating environment. ➢ Operational Constraints: The airport's CUP issued by the City in March 2001 establishes several restrictions on the airport that limit activity at the facility. The CUP limits the airport's use to no more than 100 based aircraft. Airport management indicates that the airport has reached its capacity and aircraft operations are expected to remain at about 15,000 annual operations (41 daily operations). The CUP also restricts use of the airport to only based aircraft. Specifically, the CUP prohibits flight training, commercial flight activity, public or semi-public use or activities, helicopters, charter flights, and transient (non -based aircraft) activity. The CUP also prohibits overflights of the Santa Venetia and Contempo Marin neighborhoods. This results in a one-way-in/one-way-out flight route, wind conditions permitting. Essentially, all aircraft approach the airport from the east to land on Runway 22 and depart to the east over the marshlands. A closed-circuit traffic pattern is also prohibited. Therefore, no overflights of the Project site would occur. Mr. Tambornini May 16, 2012 Page 4 ➢ Risk Level: The highest concentration of people on the Project site is expected to be in Safety Zone 5, an area situated adjacent to the center portion of runways. The 2011 Handbook characterizes the risk level in this zone as low to moderate. The types of accidents that commonly occur within Safety Zone 5 are ones involving an aircraft losing directional control and veering off the side of the runway. A pilot with operational control of his/her aircraft would steer away from populated areas. A pilot with an uncontrolled aircraft veering toward the Project site would attempt to decelerate' and spin his airplane away from the site in hopes to avoid striking an object such as a perimeter fence. Assuming a standard chain-link fence such as those found at. FAA -funded airports2, the chain-link mesh would act like a net to ensnare the aircraft and help to immobilize the plane. This snaring effect is accomplished in a manner similar to that used on aircraft carriers for halting incoming planes. An aircraft that is attempting to "spin away" from the fence would likely catch its wing in the chain-link Figure 1: Single-engine piston aircraft that crashed into a chain-link fence at Fullerton Airport, California. mesh. Damage to the aircraft's wing, nose and landing gear caused by striking the fence mesh and posts also would help to further decelerate and arrest the aircraft. Also, the types of airplanes operating out of San Rafael Airport are small light -weight aircraft weighing less than 4,000 pounds when fully loaded 3. For comparison purposes, these aircraft weigh less than a standard sport utility vehicle (SUV)4. Although not impenetrable, a perimeter fence separating the airport and the Project would aid in immobilizing a small aircraft as shown in Figure 1. Given the overall width of an airplane (from wingtip to wingtip), the force of the impact is distributed across a much larger length of the fence thereby enabling immobilization of the aircraft. By comparison, a vehicle being narrower than an airplane may strike only one panel and drive right through the fence. ' An aircraft landing on the runway is typically operating at speeds of about 50 to 75 miles per hour. 2 Federal Aviation Administration Advisory Circular 150/5370-10B, Standards for Specifying Construction of Airports, Item F-162, Chain -Link Fences, provides the following minimum standard specifications: 6 - foot tall fence with 9 -gauge galvanized steel wire in a 2 -inch mesh; 12 -inch high barbed wire section made up of 2 -strands of 12-'/2 gauge zinc -coated barbed wire with 4 -point barbs able to withstand a load of 250 pounds applied vertically; 7 -gauge marcelled steel tension wire; galvanized steel pipe for, posts, rails and braces; posts spaced at not more than 10 -feet apart; concrete footings meeting requirements of Caltrans Section 90-10 Minor Concrete with a minimum 28 -day compressive strength of 2,500 psi. 3 Piper (PAZ8R) 2,150 lbs.; Mooney (M20J) 3,374 lbs.; Cirrus (SR22) 3,400 lbs.; Beech Bonanza (G36) 3,650 lbs. 4 Ford Explorer 4,463 lbs.; Nissan Pathfinder 4,779 lbs.; Chevy Tahoe 5,524 lbs. Mr. Tambornini May 16, 2012 Page 5 Land Use Considerations The Project is fundamentally considered a group recreational use. The 2011 California Airport Land Use Planning Handbook (Handbook) prohibits this use in certain portions of the airport environs. Given the characteristics of the Project, however, we believe that the Project does not exactly fall under the standard definition for the following reasons: ➢ Large Groups: Group recreational uses typically include large groups of people. Exposing large groups of people to high levels of risk would be unacceptable. The 2011 Handbook establishes intensity limits (maximum number of people per acre) for various portions of airport environs. The highest concentration of people on the Project site is expected to be in Safety Zone 5.The 2011 Handbook does not classify Safety Zone 5 as a high-risk zone given its location lateral to the runway and away from the runway ends. Within Zone 5, the Handbook recommends an average intensity limit of 70 to 100 people per acre and a single -acre intensity of 210 to 300 people per single acre during typical busy period usage. Based on M&H's 2008 Technical Report, the Project would not exceed the average or single -acre intensity limits recommended by the state. For example, during the normal peak periods, the Project is anticipated to have an average of about 48 people per acre (475 people =10 acres). Approximately 256 people per single -acre are anticipated in the most intensive portion of the site, which is anticipated to be the recreational building (410 people _ 1.6 -acre building footprint). Optional Mitigation Measures: A major concern with regard to a group recreational uses, with or without children being involved, is that large numbers of people may be confined within a small area where quick egress would not be possible in the event of an impending aircraft accident or its aftermath. The highest risk use would be a large stadium in that such a structure neither allows for quick exiting nor provides the protection from a small aircraft that a building with a roof would afford. Avoiding the use of fixed seating and confining fencing in the outdoor recreation areas would greatly reduce this concern. Another concern is that special events at the Project site may attract significantly more people than under normal peak use. Precautions, such as temporary suspension of airport operations, would be needed to ensure that people are not unduly exposed to risk. Establishing a condition in the Project's Conditional Use Permit (CUP) and requiring signs specifying the maximum number of people permitted in the recreational building and outdoor fields would be desirable. Based on the single -acre intensity limits recommended in the 2011 Handbook, the acceptable intensity range for each component use is: 336 — 480 people in the recreational building (210 — 300 people x 1.6 -acre building footprint) 336 — 480 people in the outdoor soccer field area (210 — 300 people x 1.6 acres) 104 —156 people in the outdoor warm-up area (80 —120 people x 1.3 acres) Mr. Tambornini May 16, 2012 Page 6 These intensity ranges are significantly lower than the occupancy loads permitted by the building code. Under the building code, for example, the maximum occupancy load of the recreational building is 754 peoples while the Handbook would allow a maximum of 480 people. The maximum intensity of the Project should be set at the lower end of the above -noted intensity ranges given the Project's proximity to an active runway and that children will be on the premises. ➢ Vulnerable Occupants: Group recreational uses are among several types of uses of special concern with regard to aircraft accident risks. These uses often include children, elderly or disabled who may have difficulty knowing how to vacate the premises in the event of an aircraft crash or maybe physically unable to do so. As noted in the 2011 Handbook, the public generally affords special attention to the protection of children, including facilities that cater to these groups such as recreation/after-school centers and sports facilities. Buildings can provide substantial protection from the crash of a small airplane, such as those operating at the San Rafael Airport. To enhance the safety of vulnerable occupants, incorporating special risk -reduction features into the building design may be appropriate. There currently is no set standard or set precedence indicating the appropriate risk -reduction features that would mitigate different levels of risk of an aircraft accident. The decision must be based on the type of land use proposed, proximity to the runway ends, and the community's sensitivity to the airport and its associated hazards. Two mitigation measures are currently incorporated into the Project to enhance the safety of the building occupants in the event of an aircraft accident. These measures include an additional emergency exit beyond the building code requirement and an enhanced sprinkler system that would be designed in a manner that the entire system would not be disabled by an accident affecting one area. These building design improvements are considered to be adequate in mitigating the potential risk of an aircraft accident. Optional Mitigation Measures: Below is a list from our 2008 Technical Report identifying additional risk -reduction construction features that could be incorporated into the building design to further enhance safety, if warranted. ■ No skylights ■ Limited number of windows ■ Upgraded roof strength ■ Concrete walls Safety enhancements of the outdoor areas could include: s Source: San Rafael Airport Sports Center Aeronautical Safety Review Technical Report prepared by Mead & Hunt in 2008. Mr. Tambornini May 16, 2012 Page 7 ■ A sufficient number of clearly marked exit gates if a fence is used to separate the outdoor fields from the parking lot or other portions of the facility. ■ Fencing separating the Project from the Airport should be sufficient to prevent children from accessing the airfield. Access gates to the Airport should be prohibited. ➢ Confined Spaces: Group recreational uses often include fixed seating (e.g., bleachers) or other physical barriers which can restrict a person's ability to escape the area of impact. No fixed seating is proposed in the recreational building or around the outdoor soccer and warm-up fields. Spectators are anticipated to be in the designated viewing area in the building (which does not have fixed seats), or to stand or use folding chairs to view activities on the indoor and outdoor fields. Optional Mitigation Measures: The CUP for the Project should specify the prohibition of fixed seating around the outdoor fields. Conclusion For the reasons noted above, Mead & Hunt concludes that the overall risk exposure is acceptable despite the Project's proximity to an active airport. However, given the community's perception of risk, the Planning Commission may wish to establish restrictions beyond what Mead & Hunt recommended in its 2008 Technical Report. The mitigation measures provided above are options for further reducing the perceived risk. If you have any questions or require additional information, please contact me or Ken Brody at 707-526-5010. Sincerely, MEAD & HUNT, Inc. r Maranda Thompson Aviation Planner Attachments A and B: Safety Zone Exhibits X:112237-001070011TECHIRepodtCDA comments March 20121SRA_Tambornini.M&H 051612.docx ATTACHMENT A DEVELOPING AIRPORT LAND USE COMPATIBILITY POLICES 4 Nature of Risk ■ Normal Maneuvers • Aircraft overflying at low altitudes on final approach and straight-out departures ■ Altitude • Between 200 and 400 feet above runway y _= ■ Common Accident Types • Arrival: Similar to Zone 1, aircraft under -shooting approaches, forced short landings • Departure: Similar to Zone 1, emergency landing on straight-out departure ■ Risk Level ; • High • Percentage of near -runway accidents in this zone: 8% - 22% FINALAPPROACH Basic Compatibility Policies ■ Normally Allow • Agriculture; non -group recreational uses 4 • Low -hazard materials storage, warehouses • Low -intensity light industrial uses; auto, aircraft, marine repair services ■ Limit • Single -story office buildings 8 • Nonresidential uses to activities that attract few people 3 3 ■ Avoid 1 • All residential uses except as infill in developed areas s s • Multi -story uses; uses with high density or intensity • Shopping centers, most eating establishments ■ Prohibit • Theaters, meeting halls and other assembly uses 5 5 • Office buildings greater than 3 stories • Labor-intensive industrial uses • Children's schools, large daycare centers, hospitals, nursing homes Refer to Chapter 3 for dimensions. • Stadiums, group recreational uses • Hazardous uses (e.g. aboveground bulk fuel storage) Maximum Residential Densities Maximum Nonresidential Maximum Single Acre Intensities Average number of dwelling units Average number of people 2x the Average number of people per gross acre per gross acre per gross acre Rural See Note A 10-40 50-80 Suburban 1 per 10 - 20 ac. 40-60 80-120 Urban 0 60-80 120-160 Dense Urban 0 See Note B See Note B Note A: Maintain current zoning if less than density criteria for suburban setting. Note B: Allow infill at up to average intensity of comparable surrounding uses. FIGURE 4C Safety Zone 2 — Inner Approach/Departure Zone California Airport Land Use Planning Handbook 4-21 4 DEVELOPING AIRPORT LAND USE COMPATIBILITY POLICIES Nature of Risk ■ Normal Maneuvers • Aircraft—especially smaller, piston -powered aircraft— turning base to final on landing approach or initiating turn to en route direction w" on departure ■ Altitude'~ • Less than 500 feet above runway, particularly on landing ■ Common Accident Types ASS • Arrival: Pilot overshoots turn to final and inappropriately cross controls the airplane rudder and ailerons while attempting to return to the runway alignment causing stall, spin, and uncontrolled crash • Departure: Mechanical failure on takeoff; low altitude gives pilot few options on emergency landing site; or, pilot attempts to return to airport and loses control during tight turn TURNING TO FINAL ■ Risk Level • Moderate to high • Percentage of near -runway accidents in this zone: 4% - 8% Basic Compatibility Policies ■ Normally Allow • Uses allowed in Zone 2 • Greenhouses, low -hazard materials storage, mini -storage, warehouses • Light industrial, vehicle repair services ■ Limit • Residential uses to very low densities • Office and other commercial uses to low intensities Jhe ■ Avoid • Commercial and other nonresidential uses having higher 6usage intensities • Building with more than 3 aboveground habitable floors • Hazardous uses (e.g., aboveground bulk fuel storage) ■ Prohibit • Major shopping centers, theaters, meeting halls and other assembly facilities • Children's schools, large daycare centers, hospitals, Refer to Chapter 3 for dimensions. nursing homes • Stadiums, group recreational uses Maximum Residential Densities Maximum Nonresidential Maximum Single Acre Intensities Average number of dwelling units Average number of people 3x the Average number of people per gross acre per gross acre per gross acre Rural See Note A 50-70 150-210 Suburban 1 per 2 - 5 ac. 70-100 210-300 Urban See Note B 100-150 300-450 Dense Urban See Note B See Note B See Note B Note A: Maintain current zoning if less than density criteria for suburban setting. Note B: Allow infill at up the average of surrounding residential area. FIGURE 4D Safety Zone 3 -- Inner Turning Zone 4-22 California Airport Land Use Planning Handbook 0 M o o 0 n�� .y a I,QLFU + F�Il. r LOS Q J� 0 r ° w w x in O Q n v 0 aD j 1 e I ' I T tlr ol.� �,. Ud m ,n o d Z , ^ d D _ D V / ? f O D -41 rt In d 3 N° N o O x S CD U) D ol.� �,. Ud STATE OF CALIFORNIA—BUSINESS TRANSPORTATION AND HOUS❑ DEPARTMENT OF TRANSPORTATION DIVISION OF AERONAUTICS - M.S.#40 1120 N STREET P, 0, BOX 942874 SACRAMENTO, CA 94274-0001 PHONE (916) 654-4959 FAX (916) 653-9531 TTY 711 March 9, 2012 hm l 1 1 l Mr. Kraig TamboriniC)�'t!4ry. r }�'` City of San Rafael C': r, Y. r lirf'.0 r, Planning Division i YY P.O. Box 151560 San Rafael, CA 94915-1560 Dear Mr. Tamborini: The San Rafael Airport Recreational Facility EDMUND G. BROWN JR., Govemor A e Fleas your power! Be enerop efficient! The California Department of Transportation (Department), Division of Aeronautics (Division), reviewed the above referenced project's Draft Environmental Document and sent comments in a letter dated May 1, 2009 and also the Negative Declaration in a letter Dated February 24, 2006. Since those reviews, the Division updated the California Airport Land Use Planning Handbook (Handbook) in 2011. State law requires airport land use commissions to guide land use decisions near public use airports. Because the San Rafael Airport is not a public use airport, it lacks this benefit. Please see the following for new Division guidance regarding this project. The proposal is for the construction of a recreational facility adjacent to the San Rafael Airport. The facility will consist of a 38 -foot tall recreational building housing indoor fields and courts with spectator seating, offices, food and beverage service, arcade and meeting rooms, two outdoor fields with exterior lighting, landscaping, parking and fencing improvements. The project is located in Safety Zones 3 & 5 according to the updated Handbook. In these safety zones, the Handbook recommends prohibiting group recreational uses. In general, society gives special attention to protection of children. Special consideration should be given to facilities that cater to children such as recreation and sports facilities. We ask the City of San Rafael consider this new information in future decisions regarding this project. The proposed parking area south of the recreational facility adjacent to the San Rafael Airports' runway violates Federal Aviation Regulation (FAR) Part 77.17 obstruction standards. Vehicles using this parking area may penetrate the 7:1 transitional surface and would be defined as obstructions to air navigation. According to FAR Part 77.17, an existing object, including a mobile object, is, and a future object would be an obstruction to air navigation if it of greater height than any of the following heights or surfaces: FAR Part 77.17 section (a)(5) The surface of a takeoff and landing area of an airport or any imaginary surface established under FAR Parts 77.19, 77.21, or 77.23, and section (b)(3) 10 feet or the height of the highest mobile object that would normally traverse the road, whichever is greater, for a private road. New construction projects must meet or exceed the minimum design standards for a permitted airport. in "Caltrans improves mobility across California" DOT, Division of Aeronautics Letter Mr. Kraig Tamborini March 9, 2012 Page 2 accordance with the California Code of Regulations, Title 21, Article 3, "Design Standards, Airports Only." Vehicles using the row of parking closest to the runway, taller than 5 feet will be an obstruction to air navigation. Failure to maintain obstruction free airspace may negatively impact the airport's permit and use of the airport. Sincerely, ,��MA4- RON BOLYARD, Aviation Planner Office of Aviation Planning c; Marin County ALUC, San Rafael Aiiport "Caltrans improves mobility across California" April 10, 2012 Eric Steger, Assistant Director Marin County Department of Public Works PO Box 4186 San Rafael, CA 94913-4189 Re: San Rafael Airport Property Levee System Mr. Steger: \4AY OR GARY O. PHILLIPS MBER DAMON CONNOLLY EMBER BARBARA HELLER ,ILMEMBER MARC LEVINE CUYUGAN MCCULLOUGH COMMUNITY DEVELOPMENT DEPARTMENT PHONE: 415-485-3085 FAX: 415-485-3184 Thank you for contacting me to clarify Marin County Public Works concerns and position regarding the levee system that surrounds the San Rafael Airport site. Based on your letter of March 21, 2012, and subsequent phone conversations with you and Tracy Clay, it is understood that the County does not have an obligation to maintain any portion of the levee system surrounding the airport site, including those portions that were placed on state and county lands. Marin County Public Works has performed work on this levee system, in order to minimize - potential for loss of life or property damage, on the following occasions: • Mid -1990's — Material from a Marin County Flood Control District dredging project was stockpiled within the County jurisdiction for use for future levee repairs. • 2005 —Emergency repair was completed to levee sections in the County jurisdiction. ® 2009 — Excavation material from offsite projects was placed on levee sections within the County jurisdiction. It has been further clarified that the airport property owner can request grading permits from the County in order to maintain portions of the levee that fall within County jurisdiction, in order to protect life and property at the site. In fact, a grading permit was issued to the airport owner to perform levee maintenance on sections of the levee within County jurisdiction in 2001 through 2003 (grading permit GP00-11 was issued on 2/16/01, and three extensions were granted between 8/17/01 and 2/25/03). City staff shall review the draft project conditions of approval and ensure that there is no reference made to joint monitoring and maintenance of the entire levee 1400 FIFTH AvENUE - PO Box 151560 • SAN RAFAEL, CA 94915-1560 W W W.CITYOFSANRAFAEL.ORG system. It will remain incumbent upon the applicant to maintain the levee system consistent with the City of San Rafael General Plan 2020 Policy S-20. Thanks again for your assistance. Sincerely, _ o aig ambornini Senior Planner Cc: Paul Jensen, Community Development Director R Herbst, San Rafael Airport File i 0 :�® �..+•' ......:......................®E..PRTM ETOF..........................BLIC WORKS .... . COUNTY OF MARINPeo le serving people. Robert Beaumont DIRECTOR March 21, 2012 Mr. Kraig Tambornini, Senior Planner Administration City of San,Rafael Community Development _ PO Box 4186 San Rafael, CA 94913-4186 1400 Fifth Avenue, Third Floor 415 473 6528 T San Rafael, CA 94901 415 473 3799 F 415 473 3232 TTY RE: San Rafael Airport Recreational Facility CRS Dial 711 397-400 Smith Ranch Road www.marincounty.org/pw Comrnertis on Report to Planning Ianling !('J. onimissio fo March 27, 201 h Accounting Dear Mr. Tambornini: Airport The Marin County Public Works Department has reviewed the subject report and recommended conditions of approval for the San Rafael Airport Recreational Building Maintenance Facility project and has a few comments. Capital Projects Maintenance of the site perimeter levee system is discussed in the staff report and there are a few related proposed levee maintenance conditions of approval. Certified Unified Program Public Works would life to clarify that neither the County of Marin nor the Marin Agency (CUPA) County Flood Control and Water Conservation District are responsible for levee maintenance around the San Rafael Airport site, including portions of the levee Communications on State tidelands where the County of Marin is a public trust lands administrator. Maintenance County Garage Disability Access Engineering & Survey Flood Control & Water Resources Land Development Purchasing Real Estate Reprographic Services Road Maintenance Stormwater Program Transportation & Traffic Operations Waste Management Reference to the county's responsibility to maintain the levees to 9' MSL. is not accurate. The county is not responsible for maintaining any part of the subject levee system; please remove the reference in the proposed conditions of approval of "joint monitoring and maintenance of the entire levee system." We do, however, concur with the basic condition that the developer is responsible to maintain the levee system consistent with the City's General Plan 2020, Policy S- ��'. Hiij� v't7i'k t✓i I the t�virc iJCil�it7e i�r tt ti Cit O Sari Rafael's jur isdic ion nay, depending on the scope and quantity of material involved, require a grading permit from County Public Works. Should you have any questions or would like to discuss further, please contact me at (415) 473-2754. Thank you for your consideration. Very tri yours,' Lam-, Eric Stege Assistant Director C: Bob Beaumont, Director f:\admin\2012\directors\steger\sa.n rafael airport 3-21-12lettendocx y1AR 2 2012 PLANNING STA7� OF CALIFORNIA—BUSINESS, TRANSPI TION AND HOUSING AGENCY r! GRAY DAVIS, Govemor DEPARTMENT OF TRANSPURTATION a AERONAUTICS PROGRAM M.S. ##40 1120 N STREET - ROOM 3300 P.O. BOX 942873 Marin Ranch Airport SACRAMENTO, CA 94273-0001 (916) 654-4959 San Rafael Airport TDD (916) 654-4014 Marin County FAX (916) 653-9531 March 25, 1999 Mr. Joe Shekou 2173-D Francisco Boulevard San Rafael, CA 94901 Dear Mr. Shekou: We are pleased to enclose the corrected Airport Permit No. Mrn-005 for the San Rafael Airport in Marin County. This corrected permit reflects a change in name and ownership for the airport. We have shown the physical status and the operating conditions for the airport on the permit. Prior to making any physical change to the airport, the airport's owner must notify the California Department of Transportation, Aeronautics Program, to ensure that the proposed change does not affect the status of the airport's permit. Also enclosed is a display certificate for the airport that you can post near the airport. If you have any questions, or if we can be of assistance in the future, please do not hesitate to contact us. Sincerely, Original Signed by DANIEL R. GARGAS Aviation Consultant Enclosures be: DReynolds - District 04 BSpano Permit File DRG.jef DAS-OSS-125 u:\\z\permits\ca3 S-SnRafaelltr.doc INITIALS/[TATE tV617t s I AIRPORT PERMIT FOR A SPECIAL -USE AIRPORT Pursuant to California Public Utilities Code Section 21662, the California Department of Transportation, Aeronautics Program, hereby issues this corrected Airport Permit No. Mrn-005 for the: SAN RAFAEL AIRPORT 397 Smith Ranch Road San Rafael, California Latitude: 380 00' 55 " N. Longitude: 1220 31' 20 " W. Owned by: San Rafael Airport, LLC c/o Joe and Haidy Shekou 2173-D Francisco Boulevard San Rafael, California 94901 This corrected permit reflects a change in name and ownership of the airport and supersedes the permit dated November 5, 1990. This permit is subject to the following conditions: 1. The airport is to be maintained in accordance with California Code of Regulations, Title 21, Sections 3525 through 3560. 2. The designated traffic pattern is as follows: Right traffic for Runway 22. Left traffic for Runway 04. 1000 feet AGL. 3. The airport is approved for day and night use. 4. A variance is granted to the width of primary surface due to a drainage ditch. Page 2 5. A variance is granted to the 7:1 transitional surface which is penetrated by the dike to the north. 6. A variance is granted for a reduced runway length of 2140 feet. 7. A variance is granted to the 20:1 approach surface for Runway 04 for a hill that is 4,500 feet to the southwest. 8. White "Rs" are to be displayed on each end of the runway to denote the airport is privately owned and is not open to the general public. The physical status of this special -use facility is described below: Runway 4/22 Physical length of the runway is 2140 feet. U Runway is lighted. This permit shall remain in effect so long as the airport meets the conditions under which the permit was issued or until action is taken by the Department to suspend, revoke, correct, or amend the permit pursuant to the California Public Utilities Code or the California Code of Regulations. The airport's owner shall apply to the Department for an Amended/Corrected Airport Permit prior to any physical or operational changes at the airport which affect the conditions or physical status above or for a change in airport ownership. Failure to maintain the airport in accordance with the conditions of this permit is a violation of Public Utilities Code Section 21666 and is punishable as a misdemeanor. A4 C"-, ryL L MARLIN BECKWITH, Program Manager Aeronautics Program Department of Transportation State of California March 25, 1999 Date •L 0 T� m U � (V (D ® ro � � b p8 U tj � U C o � LO � Lr. C cc L coE ca qj0- O r� � O o� cS �• O p ,.a