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DEPARTMENT OF THE AIR FORCE AIR EDUCATION AND TRAINING COMMAND 9 July 2021 Mr. Christopher P. Toale Director, Community Initiatives Team 56th Fighter Wing 14185 West Falcon Street Luke AFB AZ 85309-1629 Mr. Cody White City of Glendale, Development Services Department 5850 W. Glendale Ave. Glendale, AZ 85301 Re: SR21-0079; Crow 303 Pre-Application (APNs 501-60-008, 501-60-010E, 501-60-006B, 501-60- 006C and 501-60-006D) Dear Mr. White Thank you for the opportunity to provide comments on the Pre-Application for the Crow 303 Development. This project will consist of annexation, zoning and design review for several new spec warehouse buildings, totaling approximately 1.25 million square feet in size. At this time, a proposed building height and an intended use have not been presented. This information is especially important given the existence of easements that run with the land for the benefit of Luke AFB*. The 146-acre site is located south of Glendale Avenue, between Alsup Avenue and Reems Road in Glendale, AZ and is inside the Luke AFB 1988 JLUS 70, 75 and 80 Ldn “high noise or accident potential zone” as identified by A.R.S. §28-8461 and is within the “territory in the vicinity of a military airport” also defined by A.R.S. §28-8461. We recognize this is only a pre-application, which presents an early opportunity for Luke AFB to express concerns it has based on the location of the development. While we recognize that Arizona law may not have restrictions in line with our concerns in this particular area of development, we continually appreciate the opportunity to provide comments, acknowledging that we are not the approval authority. Given the location of this development project, we have identified actual and/or potential mission risks and hazards should development encompass the following: a. Retention ponds or other features that would attract wildlife — Birds pose an aircraft strike hazard and are incompatible with flying operations. b. Light interference — Buildings or structures that would produce light interference at night and or glint/glare during the day that would distract or interfere with pilot vision. c. Physical encroachment on installation boundaries — Unsecured parking areas could potentially increase likelihood of unverified vehicle traffic in close proximity to Luke AFB runways. A minimum aggregate clear zone of 50 feet (15 m), inclusive of the clear zones, outside and inside the installation perimeter should be achieved. d. Spectrum utilization and radio frequency interference — Buildings or structures that would cause a loss of radar coverage such that it interferes with spectrum utilization. Without knowledge of the proposed building height, we cannot state whether the development has potential to affect our radar coverage. Additionally, to avoid radio frequency interference, developers and or end users should not use radio equipment that would interfere with Luke’s frequency or operate on a military frequency. e. Restriction to perimeter fence —- Development that would restrict and or limit Luke AFB’s access to its perimeter fence. The installation perimeter fence is located inside the property/boundary line; this has been purposefully done so that access from the outside is achievable for base perimeter security patrol. Luke AFB must continue to have access to the dirt road on the outside of our installation fence. f. Displaced water resulting in flooding - Development that would displace water or storm runoff in such a manner that it overflows onto the base, particularly areas near our runway. Besides direct effect of flooding, it also creates an opportunity for the pooling of water, which could attract birds near our runway. g. Explosive Ordinance Disposal (EOD) proficiency range — Occupants may likely hear and or feel detonations from the nearby EOD range. h. Physical Encroachment — Personnel standing on the top of the buildings could potentially surveille base activities. Cameras placed on top of building structures present a potential danger to military operations. i. Impairment of pilot’s visibility - Any production that would release substances into the air that would impair visibility or otherwise interfere with operating aircraft such as: steam, dust or smoke. These items create a negative impact and should be eliminated. j. Increased traffic - Glendale Avenue may not currently be developed to a point that would support heavy truck traffic without being restrictive in nature; therefore, an increase of heavy truck activity may pose hazards, especially at the intersection of Bethany Home and Alsup, which is inside our Clear Zone. *NOTE: There are perpetual and assignable easements purchased by the United States for the benefit of Luke AFB (attached) located on APNs 501-60-006B and 501-60-010E that Luke AFB will enforce if necessary. Along with other language, the easement and rights granted consist of prohibiting future construction of buildings, structures or materials that infringe upon, extend into or above the Approach and/or Transitional Surface. The risks and hazards as addressed above should be considered as further maturation of the development occurs and on through project completion. In identifying our concerns, we note that many risks and hazards can be mitigated. Subject to the results of an FAA Obstruction Analysis Evaluation and mitigation efforts to our identified hazards and consideration of the assignable easements; this request, as described in the narrative, should not negatively impact the flying and base operations at Luke AFB; however, we reserve the right to comment as additional development plans are submitted to the City. The submitted FAA Obstruction Analysis Evaluation for any permanent structures, as well as equipment used during construction, will need to be fully evaluated and cleared by all commenting parties to ensure there is no mission impact in addition to the hazards listed above. We also recommend that the developer and or future occupants be made aware that the proposed development is underneath Luke AFB’s flight traffic pattern, specifically low-level flights; therefore, there is an increased risk of accidents in that area as well as fuel dumping or jettison of external aircraft tanks. If this development is approved, we recommend you review the sound attenuation requirements found in A.R.S. § 28-8482. In addition, a strong notification program on the part of the applicant would be essential to inform potential occupants about Luke AFB operations. If you have any questions, please contact my Community Planner, Mr. Mark James at (623) 856-9981. Sincerely Digitally signed by TOALE.CHRISTOP Tonle crristoPHER.P.10306 HER.P.1039696165 e185 Date. 2021.07.09 09:25:40 -07'00' CHRISTOPHER P. TOALE Attachments: 1, Easement Tract-ID G-700-E 2. Easement Tract-ID G-701-E ce: Colonel Luke B. Casper, Vice Commander, 56th Fighter Wing Ms. Cindy L. Allen, GS-13, General and Environmental Law Attorney, 56th Fighter Wing