Coastal Commission letter to Department of Transportation

The letter from the Coastal Commission District Office requesting information on two Department of Transportation aeronautics evaluations of the Harkins Slough Rd. site was the beginning of the controversy surrounding the now conditional approval.

CALIFORNIA COASTAL COMMISSION
CENTRAL COAST DISTRICT OFFICE
725 FRONT STREET, SUITE 300
SANTA CRUZ, CA 95060
PHONE: (831) 427-4863

January 24, 2000

Marlin Beckwith, Program Manager
California Department of Transportation
Aeronautics Program
P. O. Box 942874
Sacramento, CA 94274-0001

Subject: Proposed High School at Harkins Slough and Lee Roads in the City of Watsonville, Santa Cruz County (Pajaro Valley Unified School District)

Dear Mr. Beckwith,
Our agency is considering a local coastal program amendment request from the City of Watsonville to facilitate a new public school on Harkins Slough Road. The proposed high school site is located near the Watsonville Airport on the southern half of Area C (see enclosed map). In the coastal zone, local governments must issue coastal permits for schools in accordance with the plan and ordinance provisions of their local coastal programs. We are reviewing the City's proposed local coastal program changes for consistency with the Coastal Act, but it is also important that any such provisions not directly conflict with any other applicable State requirements. In particular; we are currently exploring potential siting options for such a school on Area C, and want to be sure that we understand the parameters for public school development nearby airports so that we do not inadvertently recommend a use of the site that may directly conflict with your applicable siting requirements.

From the administrative record that we nave examined, it appears that your office has provided input for a number of years regarding the suitability of proposed high school sites near the Watsonville Airport. However, two letters from your office have come to different conclusions for the proposed Harkins Slough Road site. The December 23, 1987 letter from your office determined that the Harkins Slough Road site "would not be compatible with school development" and concluded that "the Department does object to purchase of the Harkins Slough Road site for school purposes." Subsequently, a January 21, 1992 letter indicates that the your office has "some reservations regarding the Harkins Slough Road site] because of some safety and noise concerns," and indicates that "we recommend that the school district explore all alternative sites before selecting the Harkins Slough Road site]." The January 21, 1992 letter concludes, however, that the Harkins Slough Road site is "considered to provide the level of safety suitable for a school." In light of these letters, we would appreciate your responses to the following questions:

1. Is Area C (see map enclosed), or any portion of it, a suitable location for a public school under the applicable law?
Page 2

2. What accounts for the change in determination on the Harkins Slough Road site change from 'incompatible with school development' in 1987 to 'suitable for a school' in 1992 What were the "safety and noise concerns" observed by your office regarding the Harkins Slough Road site in 1992?

3. The January 21, 1992 letter said your office's determination that the Harkins Slough Road site was suitable for a school would expire January 31, 1997. Has a new determination or an extension of this determination been granted? If so, can you please provide us with a copy? If not, will one be necessary?
4. Did (or will) your site suitability analysis focus on existing flight patterns and numbers of flights at the Watsonville Airport, or is it based upon expected future flight patterns and numbers of flights (for example, flight patterns and numbers of flights that may be expected under the airport master plan)? Has there been a change in flight patterns and or number of flights since I 992 such that your office's determination of suitability for the Harkins Slough Road site would likewise change?
5. It is our understanding that the applicable state requirements for public school siting near airports were revised in 1993; please confirm whether this is or is not the case. What is the currently applicable law governing siting of public schools near airports?
Thank you in advance for your assistance in this matter. Since we have tentatively scheduled this matter for a public hearing in March 2000, we would like to have your response as soon as possible. It would greatly help in framing the issues for the Coastal Commission if we could receive your response at least by February 4, 2000. Please let us know if this time frame will not work for you. If you should have any questions, please do not hesitate to contact me or Dan Carl of my staff at (831) 427-4863.
Sincerely,
Original signed by
Charles Lester
District Manager
Central Coast District Office
Enclosure: Map of Area C of City of Watsonville Coastal Zone
cc: Duwayne Brooks, Director, California. Department of Education School Facilities Planning Division
Luisa M. Park, Executive Officer, California Department of General Services Office of Public School Construction
Daniel Gargas, Aviation Consultant, Caltrans Aeronautics Program

Enclosed Map

Marlin Beckwith, Program Manager California Department of Transportation Aeronautics Program P. O. Box 942874 Sacramento, CA 94274-0001
Subject:	Proposed High School at Harkins Slough and Lee Roads in the City of Watsonville, Santa Cruz County (Pajaro Valley Unified School District)
Dear Mr. Beckwith, Our agency is considering a local coastal program amendment request from the City of Watsonville to facilitate a new public school on Harkins Slough Road. The proposed high school site is located near the Watsonville Airport on the southern half of Area C (see enclosed map). In the coastal zone, local governments must issue coastal permits for schools in accordance with the plan and ordinance provisions of their local coastal programs. We are reviewing the City's proposed local coastal program changes for consistency with the Coastal Act, but it is also important that any such provisions not directly conflict with any other applicable State requirements. In particular; we are currently exploring potential siting options for such a school on Area C, and want to be sure that we understand the parameters for public school development nearby airports so that we do not inadvertently recommend a use of the site that may directly conflict with your applicable siting requirements.
From the administrative record that we nave examined, it appears that your office has provided input for a number of years regarding the suitability of proposed high school sites near the Watsonville Airport. However, two letters from your office have come to different conclusions for the proposed Harkins Slough Road site. The December 23, 1987 letter from your office determined that the Harkins Slough Road site "would not be compatible with school development" and concluded that "the Department does object to purchase of the Harkins Slough Road site for school purposes." Subsequently, a January 21, 1992 letter indicates that the your office has "some reservations regarding the Harkins Slough Road site] because of some safety and noise concerns," and indicates that "we recommend that the school district explore all alternative sites before selecting the Harkins Slough Road site]." The January 21, 1992 letter concludes, however, that the Harkins Slough Road site is "considered to provide the level of safety suitable for a school." In light of these letters, we would appreciate your responses to the following questions:
1. Is Area C (see map enclosed), or any portion of it, a suitable location for a public school under the applicable law? Page 2
2. What accounts for the change in determination on the Harkins Slough Road site change from 'incompatible with school development' in 1987 to 'suitable for a school' in 1992 What were the "safety and noise concerns" observed by your office regarding the Harkins Slough Road site in 1992?
3. The January 21, 1992 letter said your office's determination that the Harkins Slough Road site was suitable for a school would expire January 31, 1997. Has a new determination or an extension of this determination been granted? If so, can you please provide us with a copy? If not, will one be necessary? 4. Did (or will) your site suitability analysis focus on existing flight patterns and numbers of flights at the Watsonville Airport, or is it based upon expected future flight patterns and numbers of flights (for example, flight patterns and numbers of flights that may be expected under the airport master plan)? Has there been a change in flight patterns and or number of flights since I 992 such that your office's determination of suitability for the Harkins Slough Road site would likewise change? 5. It is our understanding that the applicable state requirements for public school siting near airports were revised in 1993; please confirm whether this is or is not the case. What is the currently applicable law governing siting of public schools near airports? Thank you in advance for your assistance in this matter. Since we have tentatively scheduled this matter for a public hearing in March 2000, we would like to have your response as soon as possible. It would greatly help in framing the issues for the Coastal Commission if we could receive your response at least by February 4, 2000. Please let us know if this time frame will not work for you. If you should have any questions, please do not hesitate to contact me or Dan Carl of my staff at (831) 427-4863. Sincerely, Original signed by Charles Lester District Manager Central Coast District Office Enclosure: Map of Area C of City of Watsonville Coastal Zone cc: Duwayne Brooks, Director, California. Department of Education School Facilities Planning Division Luisa M. Park, Executive Officer, California Department of General Services Office of Public School Construction Daniel Gargas, Aviation Consultant, Caltrans Aeronautics Program