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This letter is in response to Acting Chief of the Department of Transportation's Division of Aeronautics, Mr. R. Carson Wiswell who said his department's evaluation of the proposed Pajaro Valley Unified School District high school site, located less than one mile from the take-off runway of the Watsonville Municipal Airport had assumed there were no alternative sites. He added that language relating to 'safety concerns' and suggestions that the 'district explore alternative sites,' omitted from the 'do not object' opinion issued for the site located within an airport's Traffic Pattern Zone was an 'administrative oversight' |
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Peter Nichols
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May 2, 2001 |
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Re: Aeronautics evaluation for proposed site of New Millennium High School in the Pajaro Valley Unified School District Dear Mr. Dominguez, In a conversation with Mr. Austin Wiswell of the Division of Aeronautics, Department of Transportation, I learned of an irregularity in his department's notice to yours regarding their "do not object" opinion resulting from their recent evaluation of the New Millennium High School site in Watsonville. That evaluation was required as part of the city's Local Coastal Plan Amendment approved by the California Coastal Commission. I inquired regarding his department's policies resulting in "do not object" opinions for sites located within an airport's Traffic Pattern Zone, as described in the Department's Airport Land Use Planning Handbook. The subject site is located within such a zone. (see graphics) I reminded him that the Department's Jan. 21, 1992 letter to the Department of Education identified several sites (including the subject) indicating that DOT "did not object" and read: "We have some reservations. . . because of some safety and noise concerns. We recommend that the school district explore all alternative sites before selecting any of these sites." (see text of letter) I asked Mr. Wiswell why similar language was not attached to the most recent letter in which the same "do not object" opinion was issued. He said, "We assumed there were no feasible alternatives," and added that the absence of such a recommendation was "an administrative oversight" on the part of the Department. This appears to be a very serious oversight since the Airport Land Use Planning Hand Book reads: "Schools, hospitals and nursing homes should be avoided in traffic pattern zones unless no other feasible alternatives are available." (see text) The school was originally planned for a site of approximately 55 acres, and now is planned on approximately 30 acres. A 45 percent reduction in acreage requirement would likely increase the number of feasible alternatives available to the school district. And, it would certainly be prudent ". . .that the school district explore all alternative sites. . ." as the DOT guidelines recommend, before selecting a site located within an airport Traffic Pattern Zone. I feel compelled to add that the work of the Departments of Education and Transportation and the Division of Aeronautics, especially as it relates to approving school sites, is far too important to rely on "assumptions." I also inquired as to Mr. Wiswell's knowledge of any other "do not object" opinions issued since the publication of the Airport Land Use Planning Handbook in 1993 for school sites that have a boundary coinciding with that of an airport's Inner Turning Zone. The northern boundary of the district's "Alternative Site B" coincides with the Watsonville Airport's ITZ boundary, and "Alternative Site A," to which the DOT "would not object" if a proposed runway extension were realized, would share an even larger boundary with the ITZ. (see graphics), He indicated that they "probably" had given such an approval and suggested I make a formal Records Disclosure Request to review those approvals. I have made that request and I trust there will be no undue delay in his department providing those records. I further asked if his department issues "do not object" opinions for sites located within the Inner Turning Zone, and he assured me that it did not, that that zone was off limits to school sites. (see text) Thank you for your attention to this matter. Yours very truly, //Signed// Peter Nichols
cc: Mr. R. Austin Wiswell, Department of Transportation
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