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San Joaquin Council of Governments <br /> 555 Fast Weber Avenue • Stockton,CA 95202 • (209)2360600 • FAX(209)235-0496 <br /> San Joaquin County Airport Land Use Commission <br /> ALUC RESPONSE TO LOCAL JURISDICTION <br /> T.,: Kevin Swanacn,San Joaquin County CC,-,T;:r`7 D .nt C_;,3rtment <br /> From: Laura Brunn,Associate Regional Planner, San Joaquin Council of Governments <br /> Date: March 28,2011 <br /> Local Jurisdiction Project Title: PA-0800005 Tracy Material Recovery Site Expansion <br /> Area of Influence,Airport:Tracy Municipal Airport <br /> Safety Criteria Matrix Zone: Traffic Pattern Zone Assessor Parcel Number(s): 253-130-19,26 <br /> (Zone 7)and AIA (Zone 8) Status: Consistent Land Use with Conditions <br /> Dear Mr. Swanson: <br /> The San Joaquin Council of Governments (SJCOG), acting as the ALUC, has reviewed the Draft Initial <br /> Study (IS)and Mitigated Negative Declaration (MND). The IS and MND include the City's responses to <br /> SJCOG comments with respect to impacts to land uses surrounding Tracy Municipal Airport (TMA) and <br /> potential hazards to flight. The responses within the Draft IS are deficient in showing compliance with <br /> both CEQA Guidelines and the ALUC's statutory mandates. <br /> INITIAL STUDY COMMENTS <br /> For this project and the direct relation to ALUC authority, there are two relevant significance thresholds <br /> within the 2010 CEQA Guidelines, Appendix G: <br /> I. VIII. Hazards (e). <br /> For a project located within an airport land use plan or, where such a plan has not been adopted, <br /> within two miles of a public airport or public use airport, would the project result in a safety hazard for <br /> people residing or working in the project area? <br /> 2. X. Land Use Planning(a). <br /> Would the project conflict with any applicable land use plan, policy or regulation of an agency with <br /> jurisdiction over the project adopted for the purpose of avoiding or mitigating an environmental effect? <br /> The Initial Study has not provided enough information that it will not create a safety hazard or is not in <br /> conflict with the 2009 Airport Land Use Compatibility Plan (ALUCP) for Tracy Municipal Airport. <br /> Under "Land Use and Planning" and "Hazards and Hazardous Materials", the preparer identified that the <br /> project would have a "Less Than Significant Impact" for subareas "e" and "e", respectfully. Yet the <br /> explanatory text offers no information to validate this finding. The comments written for Hazards focus <br /> solely on hazardous waste impacts with no mention of airspace hazards and the comments written under <br /> Land Use and Planning do not mention that the project is within the boundaries areas of the Tracy <br />