County of Sacramento California*

Sacramento International's Master Plan was approved by the Board of Supervisors in late 2007. It was drafted as a 20-year plan. However, as a result of the complex environmental reviews now required which take up to a cumulative eight years before completion, International's Master Plan is now a 12-year plan. Even though updates are planned every 5 years, it remains a short term airport plan. Response to Finding #1: Do Not Concur The inordinate amount of time it takes to complete a comprehensive airport master plan is not a recent phenomenon. Long range plans require an analytical and collaborative process involving numerous local, state and federal agencies and interest groups. By its very nature this takes time and resources to ensure adequate stakeholder input and compliance with the many federal, state and local rules and regulations. Per Federal Aviation Administration Advisory Circular 150/5070-6B, the Sacramento International Master Plan considered existing conditions (1999-2000) and future planning horizons (2005 short-term, 2010 medium-term, and 2020 long-term) using 1999 as its base year. While it is regrettably not uncommon for significant time to lapse between the initiation of a Master Plan and the ultimate approval of the plan's environmental documentation, such a lapse does not change the long term perspective of the plan itself or its compliance with the mandated FAA planning horizon for Sacramento International Airport.

New residential development within the 60 CNEL noise exposure curve for Sacramento International, Mather, or McClellan Airports is prohibited by CLUCPs. Response to Finding #2A: Do not concur The Sacramento Area Council of Governments (SACOG) serves as the airport land use commission (ALUC) for the counties that comprise SACOG including Sacramento County. Under the California Public Utilities Code Section 21670 et seq., ALUCs are responsible for developing an Airport Land Use Compatibility Plan (ALUCP) for most public use airports, including all airports operated by the Sacramento County Airport System (SCAS). While the current ALUCP for International and Franklin Field designate new residential development inside the 60 CNEL to be incompatible land uses, the PUC also allows local governments to override ALUC determinations that a proposed land use is inconsistent with an ALUCP. Thus, to say such development is prohibited by the ALUCPs, while technically accurate, is somewhat misleading as there are provisions whereby local jurisdictions can override the ALUC. Additionally, new residential development inside the 60 CNEL noise contour around Mather Airport is prohibited by Sacramento County Ordinance, keeping in mind that this prohibition applies only to unincorporated areas of Sacramento County. The County ordinance does not prohibit cities that have lands within the 60 CNEL at Mather from approving such residential development. Response to the 2007-2008 Grand Jury Final Report The current Mather, McClellan and Executive ALUCPs designate 65 CNEL as the threshold for incompatibility for residential land uses. An update to the McClellan ALUCP is currently underway and it will consider new residential land uses inside the 60 CNEL to be incompatible as well. We plan to propose that future updates to the ALUCPs at Sacramento Executive and Mather also change this threshold to the 60 CNEL.

New developments within the Airport Planning Policy Areas should have Avigation and Noise Easements recorded on each residential parcel in favor of Sacramento County. However, Avigation and Noise Easements will not prevent law suits in the case of an aircraft accident. In addition, culpability would almost certainly be magnified if the accident involved developments approved below known flight paths/patterns. Response to Finding #2B: Concur with first part of Finding. This is already policy for areas of the unincorporated Sacramento County that lie within the Airport Planning Policy Area boundary because avigation easements have proven to be an effective tool to convey constructive notice to prospective home buyers they are buying in an area subject to the impacts of aircraft operations. Experience has shown that very few aircraft noise complaints come from residents of homes conditioned by avigation easements. However, Sacramento County cannot require other neighboring jurisdictions to require granting avigation easements because it is the responsibility of the ALUC to establish ALUCPs and it is through SACOG's update of individual ALUCPs where conditions requiring avigation easements are coordinated with local governments having jurisdiction. We do not concur with the opinion expressed by the Grand Jury that the County is culpable for aircraft accidents under known flight paths/patterns. The County has a consistent record of not approving residential development that has been determined to be inconsistent with current land use policies.

Mather's future as an important cargo hub has been jeopardized by developments impacting options required for a major extension of its secondary runway. Unless steps are taken to protect Sacramento International Airport, it too may lose future regional expansion options. Response to Finding #2C: Do not concur Mather's future as a regional air cargo airport has not been jeopardized by encroaching development and the extension of runway 22R is included in the Draft Master Plan. The recommended extension to 8,500 feet was not chosen because a 7,200 feet extension is what is necessary for the runway to provide adequate redundant capacity for forecast air Response to the 2007-2008 Grand Jury Final Report cargo operations should Mather's primary 11,200 foot runway be temporarily out of service. At Sacramento International Airport the County is in the process of identifying the lands necessary for construction of the third parallel runway (included in the Final Master Plan approved by the Board of Supervisors) and already have sufficient property for both an extension of runway 34L/16R and for the buffer lands necessary to provide protection for required runway safety areas and instrument approach paths. Other lands adjacent to the airport are either slated for airport compatible development or are outside the current County urban services boundary. The Sacramento County Airport System (SCAS) is vigilant to ensure any proposed development near SCAS facilities are compatible with current and future airport operations and are consistent with federal, state, and local regulations concerning compatible land uses around airports.

County Airport staff has not provided a sufficient response to development proposals necessary to balance political and economic pressures from population growth which may hinder future airport expansion plans. Response to Finding #3A: Do not concur The Sacramento County Airport System (SCAS) staff has been a strong advocate for preserving the long-term viability of the SCAS. We believe the most viable means by Response to the 2007-2008 Grand Jury Final Report which to do so is through the comprehensive airport master planning process. We have successfully completed a master plan for Sacramento International Airport; a draft master plan for Mather Airport has been approved by the Sacramento County Board of Supervisors and it is now going through the environmental review processes; and master plans are in development for Sacramento Executive (a City of Sacramento owned airport) and Franklin Field with a draft plan expected to be completed in the second quarter of 2009.

The long range protection of Sacramento's airport assets, critical for regional economic and transportation viability, demand an informed aviation advocate. At times County Airport Staff has been silent responding to developments presented to the Board of Supervisors, and oftentimes became an agency of compromise. Response to Finding #3B: Do not concur Without examples of critical incidents where Sacramento County Airport System (SCAS) staff has been "silent responding to developments presented to the Board of Supervisors, and oftentimes became an agency of compromise" it is difficult to respond. As for being an advocate for airports, the SCAS has a record of success demonstrated by its ability to accomplish objectives by working collaboratively with regional stakeholders and within established rules and regulations that govern airports at the federal, state and local level. This typically involves reviewing and commenting on project proposals within 5 miles of any SCAS facility or that otherwise might have potential to restrict future airport operations and/or needed expansion activities. The end result, in most cases, projects are modified by the sponsor to be compatible with airports in a manner that meets the approval of the community, local governments, the airport system, and federal and state agencies such as the FAA, U.S. Fish and Wildlife, U.S. Army Corps of Engineers, California Departments of Environmental Protection, Transportation, and Fish and Game, among others. Again, we believe the best strategy for preserving the long-term viability of airports is through the comprehensive master planning process and the SCAS has proven its ability to get such plans in place, keeping in mind there were no current master plans prior to 2000 when we began the master plan for Sacramento International.

Executive Airport's 5,500 foot runway is totally encroached by development. Response to Finding #4: Do not concur Sacramento Executive Airport has been in continuous operation since its inception in the 1930's. Its three operating runways were shortened to include displaced thresholds; otherwise very few physical changes have occurred since scheduled passenger operations were transferred to then Sacramento Metropolitan Airport in 1967, over 40 years ago. Sacramento Executive Airport is a good neighbor airport with strong community support and airport operations are fully compliant with all federal, state and local rules and regulations.