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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             Mr. Kraig Tamborini             City of San Rafael Planning Division              P.O. Box 151560              San Rafael, CA 94915-1560  Dear Mr. Tamborini:  The San Rafael Airport Recreational Facility

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 accordance with the California Code of Regulations, Title 21, Article 3, "Design Standards, Airp01is 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, 

Original signed by

 RON BOLYARD, Aviation Planner

Office of Aviation Planning

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Zone 3 – Inner Turning 4-22   See how the required ten foot fence would also be an obstruction to air navigation.

Zone 5 – Sideline Zone 4-24