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Comprehensive Plan January 2021 DRAFT

Prepared for Alamo Area Council of Governments

2700 NE Loop 410, Suite 101 300 South Meridian Street , Texas 78217 Indianapolis, Indiana 4662 VC-2019-2790-JLUS-KELLYFIELD-CHA-R1 www.chacompanies.com

KELLY FIELD (SKF) COMPREHENSIVE PLAN

TABLE OF CONTENTS

Kelly Field Executive Summary: National Airport, National Asset ...... I Introduction ...... 1-1 1.1 Project Description ...... 1-1 1.2 Purpose and Objective ...... 1-2 1.3 Kelly Field Background ...... 1-2 1.3.1 History ...... 1-3 1.3.2 Airport Organization and National Role ...... 1-4 1.3.3 Impact on National Defense ...... 1-6 1.3.4 Annual Aircraft Operations ...... 1-6 1.3.5 Surrounding Aviation Community ...... 1-7 1.3.6 Future Aviation Development...... 1-7 Policy and Stakeholder Involvement ...... 2-1 2.1 Policy and Stakeholder Groups ...... 2-1 2.1.1 ...... 2-1 2.1.2 Port San Antonio ...... 2-3 2.1.3 Alamo Area Council of Governments ...... 2-3 2.1.4 Alamo Area Metropolitan Planning Organization ...... 2-3 2.1.5 City of San Antonio ...... 2-4 2.1.6 Bexar County ...... 2-5 2.1.7 Other Federal, State, and Local Entities ...... 2-5 2.2 Policy and Stakeholder Engagement ...... 2-6 2.2.1 Comprehensive Plan Policy and Stakeholder Meetings ...... 2-6 2.2.2 Technical and Policy Advisory Committees ...... 2-7 Authority and Planning Context ...... 3-1 3.1 U.S. Air Force ...... 3-1 3.1.1 JBSA-Lackland Air Installations Compatible Use Zones Study – October 2019 ...... 3-1 3.1.2 JBSA-Lackland Kelly Field District Area Development Plan – March 2019 ...... 3-5 3.1.3 JBSA-Lackland Port San Antonio Leaseback District Area Development Plan – September 2019 ...... 3-5 3.1.4 JBSA-Lackland Installation Facilities Standards – March 2018 ...... 3-6

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3.1.5 JBSA Installation Complex Encroachment Management Action Plan, Volume I & II – February 2016 ...... 3-6 3.1.6 Air Force Instruction 32-1015 Integrated Installation Planning – July 2019 ...... 3-6 3.1.7 JBSA Bird/Wildlife Aircraft Strike Hazard (BASH) Plan – June 2020 ...... 3-6 3.2 Port San Antonio ...... 3-7 3.2.1 Kelly Field NPIAS Justification Report – September 2013 ...... 3-7 3.2.2 Kelly Field Master Plan and Airport Layout Plan – January 2019 ...... 3-7 3.2.3 Kelly Field Airport GIS Study – September 2018 ...... 3-9 3.2.4 Kelly Field Alternative Landing Surface Analysis, Part I – September 2017 ...... 3-9 3.2.5 Kelly Field Alternative Landing Surface Analysis, Part II – August 2018 ...... 3-10 3.2.6 Kelly Field Air Traffic Control Tower Siting Study – February 2018 ...... 3-11 3.2.7 Coordination of Airport Roles – January 2015 ...... 3-11 3.2.8 Consolidated Facilities – January 2021 ...... 3-12 3.2.9 Port San Antonio Design and Development Standards – October 2016 ...... 3-12 3.3 Joint Land Use Studies ...... 3-13 3.3.1 JBSA-Lackland Joint Land Use Study – November 2011 ...... 3-13 3.4 U.S. Department of Defense ...... 3-15 3.4.1 DOD Unified Facilities Criteria 3-260-01 Airfield and Heliport Planning and Design – February 2019 ...... 3-15 3.4.2 DOD Unified Facilities Criteria 2-100-01 Installation Master Planning – October 2019 3- 16 3.5 Federal Aviation Administration ...... 3-16 3.5.1 Advisory Circular 150/5300-13A Airport Design – February 2014 ...... 3-16 3.6 Code of Federal Regulations ...... 3-16 3.6.1 Code of Federal Regulations Title 14, Part 77 – July 2010 ...... 3-16 3.7 City of San Antonio ...... 3-18 3.7.1 San Antonio Approved Master Development Plan, Port San Antonio – October 2008 3- 18 3.7.2 San Antonio Tomorrow Comprehensive Plan – August 2016 ...... 3-19 3.7.3 San Antonio Tomorrow Multimodal Transportation Plan – August 2016 ...... 3-20 3.7.4 Unified Development Code, Zoning – January 2020 ...... 3-20 3.7.5 Unified Development Code, Development Standards – January 2020 ...... 3-22

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3.7.6 Unified Development Code, Historic Preservation and Urban Design – January 2020 . 3- 22 3.7.7 Major Thoroughfare Plan – September 1978 ...... 3-23 3.7.8 Major Thoroughfare Plan Map – January 2020 ...... 3-23 3.7.9 Transportation and Capital Improvements – Continuously Updated ...... 3-23 3.7.10 Coordination of Airport Roles – January 2015 ...... 3-24 3.8 State of Texas ...... 3-24 3.8.1 Texas Department of Transportation Airport Compatibility Guidelines – January 2003 ...... 3-24 3.8.2 Texas Department of Transportation Texas Airport System Plan – March 2010 ...... 3-25 Kelly Field Existing Conditions ...... 4-1 4.1 Definition ...... 4-1 4.1.1 Exclusive Use Areas ...... 4-1 4.1.2 Jointly Used Flying Facilities ...... 4-1 4.2 Existing Airfield, Facilities, and Land Use ...... 4-3 4.2.1 Port San Antonio Exclusive Use Areas ...... 4-4 4.2.2 U.S. Air Force Exclusive Use Areas ...... 4-6 4.2.3 Jointly Used Flying Facilities ...... 4-6 Economic Impact Analysis ...... 5-1 5.1 Previous Economic Impact Study ...... 5-1 5.2 Economic Impact Analysis Methodology ...... 5-2 5.2.1 IMPLAN Modeling ...... 5-3 5.3 Economic Impact Value of Kelly Field ...... 5-4 5.3.1 Economic Impact Components ...... 5-4 5.4 Application to Kelly field ...... 5-5 5.4.1 State and Local Tax Impacts ...... 5-6 5.4.2 Upstream Economic Connections ...... 5-2 5.4.3 Economic Impact from Runway Closure ...... 5-5 5.5 Economic Impact Analysis Summary and Findings ...... 5-6 Kelly Field Planning and Design ...... 6-1 6.1 Airfield Design Standards ...... 6-1 6.1.1 Airfield Capacity ...... 6-1

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6.1.2 Runway Length ...... 6-1 6.1.3 Runway Width ...... 6-1 6.1.4 Taxiway Design Standards ...... 6-1 6.1.5 NAVAIDs and Approach Category ...... 6-2 6.2 Environmental and Built Considerations ...... 6-2 6.2.1 Floodplains ...... 6-2 6.2.2 Drainage ...... 6-2 6.2.3 Historic Places ...... 6-3 Kelly Field Future Conditions ...... 7-1 7.1 Port San Antonio Exclusive Use Areas ...... 7-1 7.1.1 North Airfield ...... 7-1 7.1.2 North Airfield Flex Development Area ...... 7-3 7.2 U.S. Air Force Exclusive Use Areas ...... 7-4 7.2.1 Kelly Field District ...... 7-4 7.2.2 PSA Leaseback District ...... 7-4 7.3 Jointly Used Flying Facilities ...... 7-5 7.3.1 Air Traffic Control Tower ...... 7-5 7.3.2 Aircraft Rescue and Fire Fighting ...... 7-5 7.3.3 Runway ...... 7-5 7.3.4 Predictable Landing Surface Strategy ...... 7-5 7.3.5 Taxiway System ...... 7-10 7.3.6 Navigational Aids and Instrument Approach Procedures ...... 7-11 7.3.7 Approach and Airfield Lighting ...... 7-11 7.4 Potential Kelly Field Expansion Areas ...... 7-11 7.4.1 PSA ...... 7-12 7.4.2 JBSA ...... 7-12 7.5 Implementation ...... 7-12 Kelly Field Compatibility Analysis ...... 8-1 8.1 Airport Design Criteria for PLSS Development ...... 8-1 8.1.1 UFC 3-260-01 Airfield and Heliport Planning and Design (DOD) ...... 8-1 8.1.2 CFR Title 14, Part 77 (Civil) ...... 8-4

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8.1.3 Advisory Circular 150/5300-13A Airport Design (FAA) ...... 8-7 8.1.4 Airport Design Criteria Compatibility Analysis Summary ...... 8-8 8.2 Noise ...... 8-9 8.3 San Antonio Unified Development Code, Zoning ...... 8-9 8.3.1 Base Zoning ...... 8-9 8.3.2 AHOD ...... 8-10 8.3.3 MAOZ ...... 8-10 8.3.4 MLOD ...... 8-11 8.4 Adopted Plans ...... 8-11 8.4.1 JBSA-Lackland Kelly Field District ADP ...... 8-11 8.4.2 JBSA-Lackland AICUZ Study ...... 8-12 8.4.3 JBSA-Lackland PSA Leaseback District ADP ...... 8-12 8.4.4 JBSA IFS ...... 8-12 8.4.5 JBSA ICEMAP ...... 8-12 8.4.6 JBSA BASH Plan ...... 8-13 8.4.7 Kelly Field Master Plan and ALP ...... 8-13 8.4.8 Kelly Field Alternative Landing Surface Analysis, Part II ...... 8-13 8.4.9 2018 Kelly Field ATCT Siting Study ...... 8-13 8.4.10 Coordination of Airport Roles ...... 8-14 8.4.11 PSA Design and Development Standards ...... 8-14 8.4.12 JBSA-Lackland JLUS ...... 8-14 8.4.13 DOD Unified Facilities Criteria 3-260-01 Airfield and Heliport Planning and Design 8-14 8.4.14 FAA Advisory Circular 150/5300-13A Airport Design ...... 8-14 8.4.15 San Antonio Approved Master Development Plan, PSA ...... 8-14 8.4.16 San Antonio SA Tomorrow ...... 8-14 8.4.17 San Antonio Unified Development Code, Development Standards ...... 8-15 8.4.18 San Antonio Unified Development Code, Historic Preservation and Urban Design . 8-15 8.4.19 San Antonio Thoroughfare Plan Map ...... 8-15 8.4.20 TxDOT Airport Compatibility Guidelines ...... 8-15 Kelly Field Compatibility Resolutions ...... 9-1 9.1 Airport Design Criteria for PLSS Development ...... 9-1

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9.1.1 UFC 3-260-01 Design Criteria (Military) ...... 9-2 9.1.2 CFR 14, Part 77 Design Criteria (Civil) ...... 9-2 9.1.3 Resolutions for Airport Design Criteria ...... 9-2 9.2 Air Traffic Control for a PLSS ...... 9-2 9.3 Liability for a PLSS ...... 9-3

LIST OF FIGURES

Figure 1-1 – Regional Location ...... 1-2 Figure 1-2 – Site Location...... 1-3 Figure 1-3 – Kelly Field ...... 1-5 Figure 3-1 - 2019 AICUZ Noise Contours ...... 3-2 Figure 3-2 – 2019 AICUZ Runway Clear Zones and Accident Potential Zones ...... 3-3 Figure 3-3 – Kelly Field Imaginary Surfaces and Transition Planes for Military Airfields ...... 3-4 Figure 3-4 - Kelly Field Master Plan Recommended Development Plan (PSA) ...... 3-8 Figure 3-5 – Proposed Ultimate Alternate Landing Surface (COA No. 4) ...... 3-10 Figure 3-6 – 3D Diagram of Part 77 Imaginary Surfaces ...... 3-18 Figure 3-7 – Port San Antonio Approved Master Development Plan ...... 3-18 Figure 3-8 – Military Drive Future Option 1 (Curb Running Bus Rapid Transit) ...... 3-20 Figure 4-1 – Jointly Used Flying Facilities, North Airfield ...... 4-1 Figure 4-2 – Jointly Used Flying Facilities, Mid-Airfield ...... 4-2 Figure 4-3 – Jointly Used Flying Facilities, South Airfield ...... 4-2 Figure 4-4 – Components of Kelly Field ...... 4-3 Figure 4-5 – JBSA-Lackland Kelly Field District ...... 4-6 Figure 4-6 – Jointly Used Flying Facilities at Kelly Field ...... 4-7 Figure 6-1 – PSA Property Flooding Conditions ...... 6-3 Figure 6-2 – Kelly Field Historic District at PSA ...... 6-3 Figure 7-1 – Layout of Consolidated Facilities ...... 7-2 Figure 7-2 – Relocated Kelly Field ATCT ...... 7-5 Figure 7-3 – PLSS Alternative 1 ...... 7-8 Figure 7-4 – PLSS Alternative 2 ...... 7-8 Figure 7-5 – PLSS Alternative 3 ...... 7-9

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Figure 7-6 – PLSS Alternative 4 ...... 7-9 Figure 7-7 – Airfield Development Scenario Decision Matrix ...... 7-10 Figure 7-8 – Taxiway System for PLSS Alternatives 1-3 ...... 7-11 Figure 7-9 – Potential Expansion Areas at Kelly Field ...... 7-12 Figure 8-1 – PLSS Alternative 1 Developed to UFC Design Criteria ...... 8-3 Figure 8-2 – PLSS Alternative 2 Developed to UFC Design Criteria ...... 8-3 Figure 8-3 – PLSS Alternative 3 Developed to UFC Design Criteria ...... 8-4 Figure 8-4 – PLSS Alternative 4 Developed to UFC Design Criteria ...... 8-4 Figure 8-5 – PLSS Alternative 1 Developed to Part 77 Design Criteria ...... 8-6 Figure 8-6 – PLSS Alternative 2 Developed to Part 77 Design Criteria ...... 8-6 Figure 8-7 – PLSS Alternative 3 Developed to Part 77 Design Criteria ...... 8-7 Figure 8-8 – PLSS Alternative 4 Developed to Part 77 Design Criteria ...... 8-7

LIST OF TABLES

Table 3-1 - JLUS Main Recommendations by Subarea ...... 3-15 Table 4-1 – PSA Exclusive Use Area Building Inventory in North Airfield ...... 4-4 Table 4-2 – PSA Exclusive Use Area Building Inventory in South Airfield ...... 4-5 Table 4-3 – Existing Instrument Approach Procedures ...... 4-9 Table 5-1 – State of Texas Comptroller’s Report on Direct Jobs at PSA ...... 5-1 Table 5-2 – Kelly Field Economic Impact Components ...... 5-5 Table 5-3 – Direct and Induced Economic Impacts of Kelly Field ...... 5-6 Table 5-4 – State and Local Tax Impacts ...... 5-2 Table 7-1 – PLSS Alternatives ...... 7-7 Table 7-2 – Airfield Development Scenarios...... 7-7 Table 7-3 – Short-Term Development Implementation (Year 0 to 5) ...... 7-13 Table 7-4 – Mid-Term Development Implementation (Year 6 to 10) ...... 7-14 Table 7-5 – Long-Term Development Implementation (Year 11 to 20) ...... 7-14 Table 8-1 – UFC 3-260-01 Airfield Design Criteria (USAF Class B Runways) ...... 8-1 Table 8-2 – CFR Title, 14 Part 77 Design Criteria ...... 8-5 Table 8-3 – Compatibility Analysis Summary of PLSS Alternatives Developed to UFC Design Criteria (Military) ...... 8-8

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Table 8-4 – Compatibility Analysis Summary of PLSS Alternatives Developed to FAA/Part 77 Design Criteria (Civil) ...... 8-8 Table 9-1 – Joint-Use Airports in the FAA NPIAS ...... 9-1

APPENDICES Appendix A: IMPLAN Tables for Kelly Field Economic Impact Analysis

Cover Source: CHA, Google Earth, 2020

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KELLY FIELD EXECUTIVE SUMMARY: NATIONAL AIRPORT, NATIONAL ASSET From its origins in 1917 to over a century later, today Kelly Field is a national asset unlike any other airport in the United States categorized by the Federal Aviation Administration as a General Aviation Regional airport in its National Plan of Integrated Airport Systems. This national airfield plays a critical role in support of our national security and is a vital economic engine for the State of Texas and the Alamo region, including a direct spending and induced benefits total of 11,330 jobs and nearly a $3.2 billion impact on the regional economy. From its beginnings as an Army Air Service training camp during World War I, it played a significant role in nearly every American conflict of the 20th Century. In this 21st Century, Kelly Field continues to support defense missions around the globe. As a publicly-accessible, federally- recognized airport (Federal Aviation Administration designator SKF), Kelly Field also serves the international aviation industry, the national airspace system, the regional airport system, as well as increasing dynamic local industry – any aircraft in the world today can land safely at this airport. By connecting Joint Base San Antonio with Port San Antonio, Kelly Field, as a joint-use facility, converges military and civilian aerospace, national intelligence, cybersecurity, robotics and military medicine, with leading innovation and technology. Military operations at Kelly Field are centered on the 502nd Air Wing Base (502nd AWB), the 433rd Airlift Wing (433rd AW), and the 149th Fighter Wing (149th FW). The 502nd AWB performs the joint base administration mission at all three Joint Base San Antonio installations plus eight other operating locations. Joint Base San Antonio is the largest joint base in the Department of Defense and the 502nd AWB, along with its 49 support functions, service more defense students and more active runways than any other installation. The 433rd AW is an U.S. Air Force Reserve Command unit responsible for training USAF active duty, reservists, and National Guard airmen to operate and maintain the C-5M Super Galaxy. The 149th FW is a Texas Air National Guard unit responsible for training USAF active duty and National Guard airmen to operate and maintain the F-16 Fighting Falcon. Collectively these military components play a critical and unique role in the military’s ability to train, sustain, and optimize airmen for a variety of installation and mission support. Civilian operations at Kelly Field is centered on Port San Antonio, which is a 1,900-acre technology and innovation campus created in 1997 by the City of San Antonio as a separate political subdivision of the State of Texas. The campus includes a mixed-use development center, railport, and industrial aerospace complex adjacent and accessible to Kelly Field. The 400-acre industrial aerospace complex is home to several aerospace customers providing essential maintenance, repair, and overhaul services to military and commercial aircraft, as well as, providing cargo services and advancing aerospace industry innovation in fabrication, avionics, modifications and upgrades, cybersecurity integration, and testing. The industrial aerospace complex provides on- site Federal Inspection Services for the U.S. Customs & Border Protection Agency and serves as a Foreign-Trade Zone (#80-10). The military flying units stationed at Kelly Field and Port San Antonio provide intangible benefits to the local community beyond economics. The 433rd AW works extensively with youth groups,

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senior citizens, handicapped and other civic charitable organizations in the San Antonio region, and set a record for the most blood ever donated on a one-day drive.1 The 149th FW also routinely gives back to the San Antonio community, including conducting F-16 flyovers for memorial, tribute, and other local events. Port San Antonio engages with the local community through a variety of means, such as hosting aerospace expositions for youth, providing storage space for donated holiday gifts before being delivered locally and books for a school district’s reading program, and exhibiting local artist’s artwork in their public offices.

1 USAF/433rd AW, “433rd Airlift Wing”, https://www.433aw.afrc.af.mil/About-Us/Fact- Sheets/Display/Article/680426/433rd-airlift-wing. Published August 15, 2015, current as of April 2017.

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INTRODUCTION

1.1 PROJECT DESCRIPTION Kelly Field is a joint use, civil-military (CIV/MIL) airfield at Joint Base San Antonio-Lackland (JBSA or JBSA-Lackland) located in southwestern San Antonio, Texas. Kelly Field is a longstanding strategic asset for the U.S. Air Force (USAF), San Antonio region, and nation with a long history, far-reaching economic impact, and significant opportunities to grow civilian and military activities. The USAF is the lead agency at JBSA and thus owns, operates and maintains the Kelly Field airfield. USAF operational flying units at Kelly Field include the Texas Air National Guard (TXANG) 149th Fighter Wing (149th FW) and the USAF Reserve Command 433rd Airlift Wing (433rd AW), which are based on the western side of Kelly Field. The 502nd Air Base Wing (ABW) provides installation support to JBSA with its 502nd Operations Support Squadron (OSS) providing air traffic control for Kelly Field. Civil use of Kelly Field is controlled by the Port Authority of San Antonio, or commonly referred to as Port San Antonio (PSA). PSA operates a 1,900-acre campus that comprises an industrial airport, port operations, industrial airpark, and an array of industrial and commercial facilities that house over 80 public and private sector tenant customers on the east side of the runway. PSA customers directly employ over 14,000 people in the community and include major aerospace, cybersecurity, applied technology and additional Department of Defense operations. The Kelly Field Comprehensive Plan ("the Plan") is a collaborative, long-range, broad-based planning effort that blends military installation planning from JBSA with civilian aeronautical planning from PSA. The Plan seeks to develop a single strategy to continue ongoing commercial development and economic growth through the civilian side of Kelly Field while also supporting mission sustainment and potential growth of military operations and activities. The Plan will merge development standards and planning from the Department of Defense (DOD), JBSA, PSA, the City of San Antonio (San Antonio), Bexar County, the State of Texas, and the Federal Aviation Administration (FAA). Easterly View of Kelly Field with JBSA-Lackland in foreground and PSA in background

Source: Google Earth, 2020.

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1.2 PURPOSE AND OBJECTIVE The purpose of the Plan is to define the geographic and economic footprint of Kelly Field, and to provide a single vision for the future development of Kelly Field that align military and civilian ideals over a 20-year planning horizon. The Plan’s purpose will be accomplished through achieving a series of objectives integral to aligning military and civilian interests, including: Promoting community development that is compatible with military training, testing and operational missions. Planning for joint-use airfield recapitalization and long-term development for the benefit of civil and military missions and activities. Identification of current and potential incompatibilities and recommended strategies that will mitigate or prevent such issues from adversely affecting the growth and appropriate development of Kelly Field. Alignment of prior airfield studies and planning. A focus on mission growth. Promotion of a regional approach to compatible land use around JBSA facilities. Guidance and clear definition of compatible land use. Strategies for reducing operational impact on adjacent land. 1.3 KELLY FIELD BACKGROUND Kelly Field is located in western Bexar County in the south central part of Texas (Figure 1-1) within the municipal limits of San Antonio, approximately eight miles southwest of the city’s downtown generally within the bounds of Interstate Loop 410, Interstate 35, and U.S. Highway 90 (Figure 1-2). Military use is primarily accessible from JBSA-Lackland to the west of the airfield while civilian use is exclusively accessed from PSA to the east, as further detailed in Section 4.1. Figure 1-1 – Regional Location

Source: CHA, ESRI, 2020

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Figure 1-2 – Site Location

Source: CHA, ESRI, 2020 1.3.1 History On November 21, 1916, a site was selected five miles southwest of San Antonio for a new aviation airfield. The intent was to replace , which was deemed to have inadequate space for expansion. The site for the new airfield was chosen partly for its access to adjacent railroad facilities, which still play a major role in PSA’s operations today. On April 6, 1917, one day before the U.S. entered World War I, four aircraft landed at the field to begin flying operations. By the end of May, the field’s population had grown to over 4,000 military personnel. The base was named for Second Lieutenant George Edward Maurice Kelly, who was killed in a crash at Fort Sam Houston on May 10, 1911, the first American military aviator to lose his life while piloting a military aircraft. The installation played a significant role in the region’s contribution to Army Air Corps support during World War I. Leading into World War II, new facilities were built to meet the needs of a developing air force in the face of the looming war. By 1943, Kelly Field had become the largest military maintenance and supply facility in the country. The supply depot activities became the primary mission of the base and flight training activities were transferred elsewhere, while the name officially became Kelly Air Force Base (AFB) in 1948.

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Post-war, the base became home to logistics responsibilities for such aircraft as the B-29, B-50, B- The B-29 was one of many aircraft 36, B-47, and B-58 bombers; F-102 and F-106 stored and maintained at Kelly Field fighters; and various cargo aircraft, including the C- 5 transport. Air transport and maintenance remained the primary mission during the Korean War, Vietnam War, Desert Storm, and Desert Shield. Notwithstanding its storied history, Kelly became one of the facilities targeted under the 1995 Base Realignment and Closure (BRAC) Commission in 1995, resulting in 1,876 acres being transferred to PSA, including land, hangars, and industrial facilities. Source: JBSA-Lackland AICUZ Study, 2019 The 1995 BRAC also aligned the Air Force retained Kelly Field facilities to . PSA was initially established as the Greater Kelly Development Corporation (GKDC) in 1995 but was restructured in 1997 as the Greater Kelly Development Authority (GKDA) in order to accept federal property.2 In 2006, GKDA was reorganized as Port San Antonio. The organization is led by a board of directors appointed by the San Antonio City Council, and its strategic plan and day-to- day activities are managed by a President and CEO. In 2005, Kelly Field was incorporated into JBSA as part of the Department of Defense joint basing program as recommended by the 2005 BRAC and implemented by Congress. 1.3.2 Airport Organization and National Role Kelly Field is a joint use, civil-military (CIV/MIL) airfield at Joint Base San Antonio-Lackland (JBSA or JBSA-Lackland). According to the Joint Use Agreement (JUA) between the USAF and PSA signed in 2013 (Section 4.1), USAF controls the “Jointly Used Flying Facilities” consisting of the runway, taxiways, Air Traffic Control Tower (ATCT), Aircraft Rescue and Fire Fighting (ARFF), navigational aids (NAVAIDS), and associated systems through its 502nd OSS. PSA has access to the Jointly Used Flying Facilities from the portion of Kelly Field owned and operated by PSA located east of the runway and consisting of ramps, hangars, and support facilities for PSA customers including a fuel farm; a public-use ramp; and a leaseback area occupied by the USAF. The red and blue outlines in Figure 1-3 illustrate of the boundaries of PSA and JBSA-Lackland (excluding the Chapman Annex), respectively. Collectively, the civilian aviation component of PSA and the JBSA-Lackland Kelly Field District (“the Kelly Field District”) represent Kelly Field – shown in the yellow shading in Figure 1-3. The three-letter airport identifier for Kelly Field is SKF. A JUA was first established in 2001 between the USAF and PSA, which provided for both military and civilian operations at Kelly Field. The JUA was updated and a new JUA was signed in 2013 (Section 4.1) to allow greater access to civil aircraft, and to establish language acceptable to the FAA for inclusion in the National Plan of Integrated Airport Systems (NPIAS). The NPIAS identifies over

2 PSA, “Kelly Field Heritage, BRAC Transition Era at Kelly Field”, http://www.kellyheritage.org/brac-transition- era.asp. Accessed July 10, 2020.

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3,000 existing and proposed airports that are included in the national airport system, the roles they currently serve, and the amounts and types of airport development eligible for Federal funding under the FAA Airport Improvement Program (AIP) over a 5-year time period. Kelly Field’s inclusion in the NPIAS is further discussed in Section 3.2.1. Figure 1-3 – Kelly Field

Source: CHA, Google Earth, 2020 Military use takes precedent at the airfield except for emergency services provided by civilian customers at PSA. The primary role of civilian use is an industrial airport focused on aerospace business and maintenance, repair and overhaul (MRO), with a secondary role as an air cargo and business aviation facility. At the time of its inclusion in the NPIAS in 2014, Kelly Field was categorized as an “unclassified” GA airport. The unclassified NPIAS listing was due to the FAA’s ongoing General Aviation Asset Study, which had unresolved questions as to how GA airports like Kelly Field (i.e. heavy aircraft industrial nature, MRO activities, with an aerospace employment center) would be categorized within the FAA’s emerging classification system. However, on September 30, 2020, the FAA published the 2021-2025 NPIAS update that elevated Kelly Field to a categorized Regional GA airport. The recategorization from “unclassified” to Regional was based on Kelly Field’s number and type of based aircraft and its volume and types of flights. Kelly Field can support these myriads of roles due to its aviation infrastructure that was designed to handle large-scale military/industrial uses, which is an asset to the international aviation industry, the national airspace system, the regional airport system, as well as increasing dynamic local industry. Subsequently, Kelly Field can provide mission support to the C-5M Galaxy, the largest aircraft in the USAF inventory, while simultaneously accommodating civilian GA, air cargo, and aerospace manufacturing traffic and all their related jobs and economic growth opportunities.

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1.3.3 Impact on National Defense Military operations at Kelly Field are centered on the 433rd AW, 149th FW, and aeronautical medical activities, which are all supported through airfield operations by the 502nd ABW. The 502nd ABW is assigned to the Air Education and Training Command (AETC) and performs the joint base administration mission at all three JBSA installations plus eight other operating locations. JBSA is the largest joint base in DOD and the 502nd ABW, along with its 49 support functions, service more defense students and more active runways than any other installation. By providing a myriad of installation mission support, the 502nd ABW plays a crucial role in the training and sustainment of our military forces today and in the future. The 433rd AW is an USAF Reserve Command unit responsible for training USAF active duty, reservists, and National Guard airmen to operate and maintain the C-5M Super Galaxy. The C-5M is a strategic transport aircraft and the largest aircraft in the USAF inventory that serves a primary mission to transport cargo and personnel for the DOD. Upon activation, the 433rd AW is assigned to the Air Mobility Command (AMC) and plays a critical role in transporting cargo and personnel throughout the world for mission support and humanitarian relief operations. The 149th FW is a TXANG unit responsible for training USAF active duty and National Guard airmen to operate and maintain the F-16 Fighting Falcon. The F-16 is a compact, multi-role fighter aircraft that provides high maneuverability in both air-to-air combat and air-to-surface attacks. As a relatively low-cost, high-performance weapon system, the F-16 is a critical component in our national security and defense. The 149th FW certifies over fifty F-16 pilots each year through its training program, which deploy to flying units and missions throughout the world. Collectively these military components play a critical and unique role in the military’s ability to train, sustain, and optimize airmen for a variety of assignments and forward locations. In addition to these permanently assigned units and their based aircraft, transient military aircraft routinely utilize Kelly Field for their respective missions, including the F-15 Eagle, KC-135 Stratotanker, F/A- 18 Super Hornet, C-17 Globemaster III, C-130 Hercules, T-1 Jayhawk, T-6 Texan II, T-38 Talon, MH- 60G/HH-60G Pave Hawk, and C-12 Huron. As such, Kelly Field plays a critical role in supporting the missions of a variety of military units across the United States, including national intelligence, cybersecurity, robotics and military medicine, with leading innovation and technology. 1.3.4 Annual Aircraft Operations Each take-off and landing of an aircraft is counted as a single operation in calculating the annual aircraft operations for an airport. As such, there were 36,568 annual operations at Kelly Field in 2018 as reported in the 2019 JBSA-San Antonio Air Installations Compatible Use Zones (AICUZ) study (Section 3.1.1). This includes based and transient aircraft, either fixed-wing or rotary-wing, for both military and civilian components. According to the 2019 Kelly Field Master Plan and ALP (Section 3.2.2), military operations comprised over 83% of the annual operations at Kelly Field in 2015, which is likely similar to the number of annual operations today. Most civilian operations were transient, related to MRO services provided at PSA. There are no individual or T-hangars, and very few bulk hangars are available or suitable for GA aircraft storage, resulting in 12 based civilian aircraft (10 single-

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engine, 1 multi-engine, and 1 jet) as of January 2021.3 The remaining civilian operations were either air carrier, air taxi, or air cargo. Civilian annual aircraft operations beyond 18,756 per year, as defined in the JUA, require an updated Federal National Environmental Protection Act (NEPA) Environmental Impact Statement (EIS). 1.3.5 Surrounding Aviation Community Kelly Field is one of three NPIAS aviation facilities in Bexar County. San Antonio International Airport (SAT) is the primary commercial service airport for the region, located eight miles from . Stinson Municipal Airport (SSF) is a GA and a reliever airport to SAT and is located six miles from downtown San Antonio. Other nearby NPIAS facilities include two GA airports: Castroville Municipal Airport (CVB) and New Braunfels Regional Airport (BAZ). Six non- NPIAS airports also serve the San Antonio community as well. 1.3.6 Future Aviation Development One of the principle outcomes of this Comprehensive Plan is to reconcile and coordinate future aviation development at Kelly Field. Civilian use development is driven by PSA and its Kelly Field Master Plan and Alternative Landing Surface Analysis. Military use development is driven by JBSA-Lackland by-way-of its Installation Development Plan (IDP), Kelly Field District Area Development Plan (ADP), and PSA Leaseback ADP. These plans are described in Chapter 3 and outline future aviation development over the next 10 to 20 years. However, future development in relation to the Jointly Used Flying Facilities needs to be reconciled between these plans to ensure both JBSA-Lackland and PSA needs are accommodated, which is described in Chapter 4.

3 GRC, “Airport Master Record Form 5010 (SKF)”, https://www.gcr1.com/. Retrieved October 22, 2020.

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POLICY AND STAKEHOLDER INVOLVEMENT

Policy and stakeholder involvement is an integral part of any significant airport planning study, as it encourages information-sharing and collaboration among the community and airport stakeholders that have a collective interest in the outcome of the study. The identified policy and stakeholder groups relevant to this Comprehensive Plan are described in Section 2.1. Through open, two-way communications, the primary objectives of the policy and stakeholder involvement are to (1) educate the various stakeholder groups of the benefits and contributions of the Airport to the region; and (2) to garner insight as to how the USAF and PSA can best support the needs and interests of the local communities. Policy and stakeholder engagement throughout this Comprehensive Plan process are detailed in Section 2.2. 2.1 POLICY AND STAKEHOLDER GROUPS 2.1.1 Joint Base San Antonio JBSA was established following implementation of BRAC in 2005 that consolidated Fort Sam Houston, Lackland Randolph and Lackland Air Force Bases, and Camp Bullis. The USAF is the executive agency for JBSA, which is the largest joint base within the United States Department of Defense (DOD). In addition to the three primary installations, JBSA includes eight other operating locations and hosts 266 mission partners. JBSA-Lackland consists of the Lackland Main Base, Kelly Field, and the Chapman Annex, totaling approximately 8,856 acres. JBSA-Lackland is best known for being the sole location for the USAF enlisted Basic Military Training (BMT) for the Active Duty Air Force, Air Force Reserve Command (USAFRC), and Air National Guard. In addition to BMT, JBSA-Lackland provides technical training for a wide array of USAF support functions, English language training for international military personnel, and specialized maintenance and security training. Further, JBSA-Lackland is home to more than 120 DOD and associate organizations, providing mission-critical facilities, infrastructure, and property to support readiness training exercises and operations as well as its various tenant commands’ mission responsibilities. JBSA-Lackland missions with operations in Kelly Field are described below. 502nd Air Base Wing The 502nd ABW is the host unit at JBSA and provides installation support across all JBSA locations. The 8,000-person 502nd Air Base Wing executes the 49 installation support functions at JBSA and manages and provides oversight for major projects, facilities, and infrastructure. 502nd ABW Groups and Squadrons that have facilities at JBSA-Lackland include the 502nd Installation Support Group (ISG), 502nd Civil Engineer Group (CEG), 502nd Operations Support Squadron (OSS), 502nd Logistics Readiness Squadron (LRS), 502nd Civil Engineer Squadron (CES), 802nd Security Forces Squadron (SFS), and the 802nd Force Support Squadron (FSS).

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433rd Airlift Wing – USAF Reserve Command The 433rd AW, also known as the Alamo Wing, is a USAFRC unit with approximately 2,500 active duty personnel. Headquartered at JBSA- Lackland with 21 subordinate units, the Wing organizes, equips, and trains reservists to achieve combat readiness according to training standards established by the Air Mobility Command and the Air Education and Training Command. Additionally, the 433rd AW operates the only C-5M Formal Training Unit, providing airframe-specific training for all C-5 aircrew members across the USAF. C-5M Super Galaxy

Source: JBSA-Lackland AICUZ Study, 2019

149th Fighter Wing – Texas Air National Guard The 149th FW is a TXANG F-16 Fighting Falcon training unit with approximately 650 active duty personnel. The cornerstone of the 149th's flying mission is the 182d Fighter Squadron, whose role is to take pilots, either experienced aircrew or recent graduates from USAF undergraduate pilot training, and qualify them to fly and deploy the F-16.

F-16 Fighting Falcon

Source: JBSA-Lackland AICUZ Study, 2019

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2.1.2 Port San Antonio PSA is a public, self-sustaining enterprise incorporated in 1997 by San Antonio as a separate political subdivision of the State of Texas under Local Government Code 379B as a Defense Base Development Authority. Originally established in 1995 as the GKRC, it was restructured in 1997 as the GKDA in order to accept federal property. In 2006, GKDA was reorganized as PSA known today to provide an organization led by a board of directors and a President and CEO. It’s 11-member Board of Directors is appointed by the Mayor and City Council. It is an independent, special redevelopment authority resulting from the implementation of BRAC that closed the former Kelly Air Force Base in 1995. PSA was created and designed to repurpose the former military land into a 1,900-acre technology and innovation campus that would provide regional job and economic growth. Located just southwest of downtown San Antonio, PSA has more than 80 public and private sector tenants employing over 14,000 people throughout industries in aerospace, defense, global logistics, manufacturing, cybersecurity, and energy. 4 One of the strongest attractions of PSA is its unique offering of tenant sites and services in proximity of JBSA-Lackland, including the industrial airport at Kelly Field, a 750,000-square foot office complex, a 350-acre rail port, U.S. Customs & Border Protection federal inspection station, and designation as a Foreign-Trade Zone. Further, Kelly Field specifically hosts seven of these PSA customers and over 2,000 workers. 2.1.3 Alamo Area Council of Governments The Alamo Area Council of Governments (AACOG) is a voluntary association of municipal and county governments and special districts located in Bexar County and the surrounding twelve counties. Defined as a political subdivision of the State of Texas, the Alamo Area Council of Governments (AACOG) was established in 1967 under Chapter 391 of the Local Government Code as a voluntary association of local governments and organizations that serves its members through planning, information, and coordination activities. AACOG serves the Alamo Area/State Planning Region 18, which covers 13 counties and 12,582 square miles. Comprising the area planning region are Atascosa, Bandera, Bexar, Comal, Frio, Gillespie, Guadalupe, Karnes, Kendall, Kerr, Medina, McMullen, and Wilson counties. 2.1.4 Alamo Area Metropolitan Planning Organization The Alamo Area Metropolitan Planning Organization (AAMPO) develops transportation plans and programs to address the needs of the greater San Antonio area, and decides how federal and state transportation funds will be allocated for the region. The AAMPO is led by the Transportation Policy Board comprised of 21 voting members representing the cities of Boerne, New Braunfels, San Antonio, and Seguin; counties of Bexar, Comal and Guadalupe; the Advanced Transportation District; the Alamo Regional Mobility Authority; the Greater Bexar

4 State of Texas Comptroller, “Port of Entry: Port San Antonio. Impact to the Texas Economy, 2018”, https://comptroller.texas.gov/economy/economic-data/ports/port-san-antonio.php. Accessed May 2020.

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County Council of Cities; the Northeast Partnership; the Texas Department of Transportation and VIA Metropolitan Transit. 2.1.5 City of San Antonio Aviation Department The Aviation Department of San Antonio is responsible for managing and operating the San Antonio Airport System consisting of San Antonio International Airport (airport code SAT) and Stinson Municipal Airport (airport code SSF). SAT provides primary commercial airline service for the South Texas region in addition to general aviation (GA) and air cargo services. SSF is the second oldest continually operating GA airport in the US and serves as the primary reliever for SAT. City Council The San Antonio City Council acts as the policy-making and legislative body within the city's government. The Council is comprised of ten members elected from single-member districts. Additionally, the Council appoints several city positions including the San Antonio City Manager and members of various boards and commissions. Office of Military and Veteran Affairs The Office of Military and Veteran Affairs (OMVA) is a department within the City of San Antonio that works with military-related organizations and partners with JBSA to engage and sustain JBSA’s mission readiness and ensure the long-term protection of the city’s military bases. OMVA works with all military families, active duty, retirees and approximately 250,000 veterans. Planning Department The Planning Department of San Antonio is responsible for guiding the city’s growth and development through the creation and adoption of long-range plans, community development plans, neighborhood plans, sector plans, corridor plans, and other special studies. Public participation is a major component to most city planning activities that strive to include the public in the decision-making process for their city. Public Works Department The Public Works Department oversees the capital construction and maintenance of San Antonio streets, traffic, and drainage infrastructure – including both 2012 and 2017 Bond Programs and non-bonded projects throughout the city, such as the Henry B. Gonzalez Convention Center Expansion Project. Transportation Department The Transportation Department focuses on improving mobility for all modes of transportation and implementing long-range transportation planning initiatives.

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2.1.6 Bexar County Bexar County encompasses San Antonio and JBSA and is an important partner in ensuring military readiness throughout the region, especially the County Commissioners. Although Bexar County does not have the legal authority to regulate zoning or to adopt comprehensive plans to control land use and development in unincorporated areas, the Texas Airport Zoning Act in 1987 (Texas Code 241) provides limited authority to control development around airports, though this is not applicable to Kelly Field within the municipal limits of San Antonio. 2.1.7 Other Federal, State, and Local Entities JBSA Public/Public/Public/Private Community Partnership Initiative The JBSA Public/Public/Public/Private (P4) Community Partnership Initiative enables the 502nd Air Base Wing and JBSA to enter into partnerships in the community in order to provide, receive or share installation support services for many of its municipal and morale, welfare and recreation functions. Military Transformation Task Force The Military Transformation Task Force (MTTF) is a joint initiative of San Antonio, Bexar County, and the Greater San Antonio Chamber of Commerce that aims to share information and work with the military to enhance mission readiness through a Community-Military Partnership, to advocate for the military at a local, state, and national level, and to address any impacts that the military may have on the local community. MTTF is comprised of a chairperson from each of the three member organizations, as well as members of the community, including the 502nd Air Base Wing, Brooks Development Authority, PSA, OMVA, the Military Affairs Commission of the Greater Chamber of Commerce, AACOG, and CPS Energy. MTTF also manages four committees representing various community and military issues, including infrastructure and transportation, real property and neighborhoods, communication and legislative affairs, and mission readiness and sustainability. Texas Department of Transportation, Aviation Division The Aviation Division of the Texas Department of Transportation (TxDOT) helps cities and counties obtain and disburse federal and state funds for reliever and GA airports included in the 300-airport Texas Airport System Plan (TASP). The division also participates in the FAA State Block Grant Program, through which it implements a federal improvement program for GA airports. Texas Military Preparedness Commission The Texas Military Preparedness Commission (TMPC) was established in 2003 by the 78th Texas Legislature with the goal of preserving, protecting, expanding, and attracting new military missions, assets, and installations to the State of Texas. The commission also works to encourage defense-related businesses to expand or relocate within/to Texas. Additionally, the TMPC administers two important defense community funding programs, including the Defense Economic Adjustment Assistance Grant Program (DEAAG) and the Texas Military Value Revolving Loan Fund (TMVRLF). DEAAG is an infrastructure grant program

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designed to assist defense communities that are responding to or recovering from a reduction or termination of defense contracts, and those that have been positively affected with new or expanded military missions, as well as, qualified job retention. The TMVRLF aims to assist defense communities in enhancing the military value of a military facility in their area, provide financial assistance to defense communities for job-creating economic development projects that minimize the negative effects of BRAC, and provide financial assistance to defense communities for infrastructure projects to accommodate new or expanded military missions resulting from BRAC. U.S. Department of Defense Office of Local Defense Community Cooperation The Office of Local Defense Community Cooperation (OLDCC) is a DOD Field Activity that provides technical and financial assistance to states and communities that are invested in the defense mission. The OLDCC was created from the FY21 National Defense Authorization Act, which changed the Office of Economic Adjustment (OEA) to the OLDCC. Prior to this change in January 2021, the OEA managed over 200 grants exceeding $1.3 billion in 2020. 5 2.2 POLICY AND STAKEHOLDER ENGAGEMENT Policy and stakeholder engagement throughout this study’s planning process included two large open invitation meetings to leadership and staff from the groups described within Section 2.1, and six small focus meetings from a subset of these groups; the Technical Advisory Committee and Policy Advisory Committee, TAC and PAC, respectively. The proceeding sections provide a narrative of the Plan’s policy and stakeholder engagement. 2.2.1 Comprehensive Plan Policy and Stakeholder Meetings Kick-Off Meeting Policy and stakeholder engagement for the Comprehensive Plan began with a kick-off meeting at PSA, organized by AACOG and CHA Consulting, Inc. (CHA) on January 29, 2020. The meeting included a diverse panel of attendees from JBSA, PSA, PSA customers, San Antonio, TxDOT, and the San Antonio Chamber of Commerce. A formal presentation provided an overview of the project, the Comprehensive Plan objective and process, identified policy and stakeholder groups, key elements of Kelly Field, both military and civilian components, planned civilian aviation growth at PSA, and planned military development at Kelly Field. Following the formal presentation, AACOG and CHA facilitated a group discussion with the attendees that ranged in topics from the Comprehensive Plan’s process to planned airfield development from both civilian and military components. Afterwards, AACOG and CHA met with individual policy and stakeholder groups for detailed discussions relative to their expertise and interest. Final Meeting TBD.

5 DOD OEA, “An Introduction to OEA”, https://www.oea.gov/introduction. Accessed July 10, 2020.

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Kick-Off Meeting Presentation Cover Slide

Source: CHA, Google Earth, 2020 2.2.2 Technical and Policy Advisory Committees The Technical Advisory Committee (TAC) was organized as a collection of stakeholders with technical expertise beneficial to the planning process and development of the Plan and included participants from a host of organizations. The Policy Advisory Committee (PAC) was organized as a collection of stakeholders with policy expertise and authority beneficial to the planning process and development of the Plan. PAC participants represented organizations similar to the TAC but was expanded to capture economic development stakeholders. Both TAC and PAC convened separately three times over the course of the Comprehensive Plan as described below. TAC/PAC Meeting #1 The first TAC/PAC meetings were held on Tuesday, June 9, 2020 and Wednesday, June 10, 2020, respectively, at PSA, virtually due to the COVID-19 global outbreak. CHA facilitated the meeting and presented an overview of the Plan’s objectives, regulatory and planning context, planned airfield development, and expectations for the next TAC/PAC meeting. TAC/PAC Meeting #2 The second TAC/PAC meetings were held on Tuesday, September 1, 2020 and Wednesday, September 2, 2020, respectively, at PSA virtually due to the COVID-19 global outbreak. CHA facilitated the meeting and presented a brief overview of Kelly Field and the Plan’s objectives and

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process for new attendees, draft Working Paper #1 regarding Kelly Field’s background and existing conditions, and an overview of planned airfield development, including the JBSA Kelly Field District, the Consolidated Facilities being pursued by PSA, and an alternative landing surface. TAC/PAC Meeting #3 The third TAC/PAC meetings were held on Wednesday, December 16, 2020 and Thursday, December 17, 2020, respectively, virtually due to the COVID-19 global outbreak. CHA facilitated the meeting and presented revisions to planned airfield development based on committee input and findings of the economic impact analysis for Kelly Field (Chapter 5).

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AUTHORITY AND PLANNING CONTEXT

As described in Chapter 1, the USAF and PSA have independently developed plans that, in some cases, are without review and evaluation for compatibility and a single vision for Kelly Field. Planning and development studies, as well as adopted regulations, by the DOD, Federal Government, City of San Antonio, Bexar County, and the State of Texas are often applicable to Kelly Field and to be considered within the Comprehensive Plan. Below is the review and evaluation of these authorities and planning contexts. 3.1 U.S. AIR FORCE 3.1.1 JBSA-Lackland Air Installations Compatible Use Zones Study – October 2019 The goal of the AICUZ program is to protect the health, safety, and welfare of those living and working near air installations while sustaining the USAF’s operational mission. The USAF accomplishes this goal by recommending that noise zones, Clear Zones (CZs), Accident Potential Zones (APZs), and safety of flight concerns associated with military airfield operations be incorporated into local community planning programs in order to maintain the airfield’s operational requirements while minimizing the impact to residents in the surrounding community. Moreover, the AICUZ study for JBSA-Lackland identifies these potential issues and offers mitigating recommendations related to operational noise, community and aircraft safety, and land use compatibility. Operational Noise Aircraft operations are the primary source of noise associated with a military air installation. The level of noise exposure relates to a number of variables, including the aircraft type, engine power setting, altitude flown, direction of the aircraft, flight track, temperature, relative humidity, frequency, and time of operation (day/night). In order to analyze the impact of operational noise on surrounding communities, the AICUZ study develops “noise contours” of perceived decibel levels (dB) using NOISEMAP, the DOD’s standard model for assessing noise exposure from military aircraft operations at air installations. The model is based on projected operations at JBSA-Lackland and incorporates known and anticipated changes in mission and operations through 2021. Figure 3-1 shows the resulting 2019 AICUZ Study noise contours centered on Runway 16-34 with gradient shading to illustrate intensity. These contours can help identify areas of incompatible land use and assist communities in planning for future development around JBSA-Lackland. Moreover, to mitigate impacts on surrounding communities, JBSA-Lackland has established a Noise Abatement program aimed at reducing and controlling the emission of noise and vibrations associated with the use of military aircraft, weapon systems, and munitions while maintaining operational requirements. The program includes: During nighttime hours (10:00 p.m. to 7:00 a.m.), all arrivals are flown to a full-stop landing and no afterburner takeoffs are permitted without prior approval, based on

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aircraft configuration, weight, and temperature. (Note: multiple landings at night are conducted on occasion as directed by the syllabus.) Takeoff patterns are routed to avoid noise-sensitive areas as much as possible. Flight patterns are routed to avoid nearby Nelson W. Wolf Minor League Stadium and Sea World San Antonio as much as possible. The Airfield Operations Board, established to support installation flying missions, monitors airfield activity to ensure there is no unnecessary nighttime aircraft maintenance activity and that noise from aircraft operations is minimized to avoid conflict. Transient aircraft are limited to one approach to a full-stop landing. Adjusting straight-in arrival procedures to reduce the distance the wing flaps are deployed (from 10 miles from the runway threshold to 2 miles) and flying a tighter pattern over the airfield so that more of the arrival operations’ noise is contained closer to the runway. Aircraft maintenance engine run-up locations and MRO operations areas have been designated in such a way to minimize noise for people in the surrounding communities, as well as for those on base. Figure 3-1 - 2019 AICUZ Noise Contours

Source: JBSA-Lackland AICUZ Study, 2019

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Community and Aircraft Safety The USAF through its AICUZ program establishes a flight safety program and designates areas of accident potential around air installations to assist in preserving the health, safety, and welfare of residents living nearby. Subsequently, the AICUZ program defines CZs, APZs, imaginary surfaces, and hazards to aircraft flight zones (HAFZ) to aid surrounding communities in developing land uses compatible with airfield operations. Runway Clear Zones and Accident Potential Zones CZs and APZs are considered areas where aircraft accidents are most likely to occur if an accident were to take place, and therefore density and land use restrictions are recommended. CZs are defined as an area 3,000 feet square centered on the end of the runway and should remain undeveloped. APZ I is a rectangle area beyond the CZ that is 3,000 feet in width and 5,000 feet in length along the extended runway centerline. APZ II is a rectangular area beyond APZ I that is 3,000 feet in width by 7,000 feet in length along the extended runway centerline. A variety of land uses are compatible in both APZs, however higher density uses (e.g., schools, apartments, churches) should be restricted because of the greater safety risk in these areas. Figure 3-2 shows the 2019 AICUZ Study CZs and APZs: red shading are the CZs, orange shading are the APZ Is, and yellow shading are the APZ IIs. Figure 3-2 – 2019 AICUZ Runway Clear Zones and Accident Potential Zones

Source: JBSA-Lackland AICUZ Study, 2019

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Imaginary Surfaces The DOD identifies a complex series of imaginary planes and transition surfaces that together define the airspace needed to remain free of obstructions around an airfield. The imaginary surfaces for military airfields include primary surface, approach-departure clearance surface, inner horizontal surface, conical surface, outer horizontal surface, and transitional surface. In general, the USAF does not permit above-ground structures in the primary surface (located on base), and height restrictions apply to transitional surfaces and approach and departure surfaces. Height restrictions are more stringent for areas closer to the runway and flight paths. Figure 3-3 shows the military airfield imaginary surfaces and transition planes at Kelly Field: orange shading is the approach/departure clearance surface, teal shading is the inner horizontal surface, blue shading is the conical surface, pink shading is the outer horizontal surface, and yellow shading is the transitional surface. Figure 3-3 – Kelly Field Imaginary Surfaces and Transition Planes for Military Airfields

Source: JBSA-Lackland AICUZ Study, 2019 Hazards to Aircraft Flight Zones The USAF further identifies the imagery surfaces, as described above, as HAFZs that surrounding communities should utilize to examine the compatibility of land use and activities in relation to the military airfield. Rather than having defined compatibility guidelines, HAFZs act as

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consultation zones in which the USAF encourages developers and planning bodies to consult with the USAF regarding potential development to ensure compatibility with military operations. Land use and activity compatibility considerations from potential development include height, visual interference, light emissions, bird or wildlife aircraft strike hazards, radio frequency or electromagnetic interference, and drones/unmanned aircraft systems. Land Use Compatibility In an effort to establish long-term compatibility for lands within the vicinity of military air installations, the DOD has created land use compatibility recommendations based on the Federal Highway Administration’s Standard Land Use Coding Manual (SLUCM). Land uses include residential; manufacturing; transportation, communication, and utilities; trade; services; cultural, entertainment, and recreational; and resource protection and extraction. These guidelines are used by DOD personnel for on-installation planning and for engaging with the local community to foster compatible land use development. The guidelines indicate whether land uses are compatible, compatible with exceptions, incompatible, or incompatible with exceptions in relation to the CZs, APZ I and IIs, and noise zones derived from the noise contours. Moreover, the AICUZ study analyzes both existing and future land uses for compatibility in surrounding communities, identifies existing and potential future concerns, and offers recommendations to alleviate those concerns. 3.1.2 JBSA-Lackland Kelly Field District Area Development Plan – March 2019 Area Development Plans (ADPs) are long-range planning documents that provide important programming information to justify capital investment decisions and to secure funding for future projects to facilitate the effective and efficient use of real-property resources and land. ADPs are typically prepared with 20-year planning horizons and focus on one specific area of an installation that are subsequently used to create a comprehensive Installation Development Plan (IDP). The Kelly Field District ADP provides detailed site planning for individual area projects that collectively depict the desirable end state of the Kelly Field District for the next 20 years. The projects strive to optimize mission operations, eliminate current deficiencies, address the physical location of new facilities and functions, and address the integration with other supporting or limiting elements within and outside the Kelly Field District. Due to the Kelly Field ADP being designated as For Official Use Only (FOUO), this Comprehensive Plan will only consider the ADP as an internal reference and will not include specific details herein. 3.1.3 JBSA-Lackland Port San Antonio Leaseback District Area Development Plan – September 2019 The JBSA-Lackland PSA Leaseback District ADP (“the PSA Leaseback District”) focuses on the leased land and buildings located within PSA and the PSA East Annex. It strives to provide a comprehensive vision for the installation missions and mission partners located in the PSA Leaseback District over the next 20 years that align with the IDP. Due to the PSA Leaseback District ADP being designated as FOUO, this Comprehensive Plan will only consider the ADP as an internal reference and will not include specific details herein.

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3.1.4 JBSA-Lackland Installation Facilities Standards – March 2018 Installation Facilities Standards (IFS) is a base-level program of facility standards establishing an acceptable level of quality and performance for facility design, facility operations and ongoing building maintenance. It is a component of the IDP that must be adhered to for all military construction projects and non-appropriated funds facilities, including installation elements (i.e. street envelope standards, open and public spaces, etc.), site development (i.e. site design, stormwater management, lighting, etc.), facility exteriors (i.e. architectural features, structural systems, etc.), and facility interiors (i.e. building configurations, furnishings, etc.). Additional guidance is often provided at the ADP level, superseding IDP level guidance, depending on mission requirements. 3.1.5 JBSA Installation Complex Encroachment Management Action Plan, Volume I & II – February 2016 Installation Complex Encroachment Management Action Plans (ICEMAPs) are designed to assist the Major Commands (MAJCOM) and installation commander and staff in developing a comprehensive plan to manage encroachment challenges and their impacts on the installation’s operations. Volume I, or the “Commander’s Action Plan,” serves as the launching point for the installation’s encroachment management program. Volume II provides the context and rationale for Volume I for members of the Installation Encroachment Management Team (IEMT). Due to the ICEMAP being designated as FOUO, this Comprehensive Plan will only consider the ICEMAP as an internal reference and will not include specific details herein. 3.1.6 Air Force Instruction 32-1015 Integrated Installation Planning – July 2019 Air Force Instruction (AFI) 32-1015 establishes a planning framework to enable installations to be adaptive, resilient, right-sized, and fiscally sustainable. The planning framework includes installation development and facility space planning, management of the AICUZ and noise programs, and integration of the Environmental Impact Analysis Process. Further, it includes three levels of efforts: strategic, enterprise, and installation. Strategic planning is led by the Directorate of Civil Engineers and provides strategic-operational, and functional intent and guidance for an installation. Enterprise planning is led by the AFIMSC, Air Force Reserve, National Guard Bureau and provides analysis of assets and mission-driven infrastructure requirements, which inform both strategic and installation planning. Installation planning is led by installation staff and identifies actions and investments needed to assure current mission accomplishment and future operational needs. 3.1.7 JBSA Bird/Wildlife Aircraft Strike Hazard (BASH) Plan – June 2020 The JBSA Bird/Wildlife Aircraft Strike Hazard (BASH) Plan works to identify and recommend actions to reduce bird/wildlife hazards and mitigate the threats they pose to safe aircraft operations at all JBSA facilities. Additionally, the BASH Plan collects, compiles, and reviews data on bird/wildlife strikes, and recommends necessary operational and procedural changes. The four main pillars of the BASH Plan include wildlife habitat deterrence, operational avoidance of wildlife, wildlife dispersal, and wildlife population management.

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3.2 PORT SAN ANTONIO 3.2.1 Kelly Field NPIAS Justification Report – September 2013 In April 2012, PSA submitted a formal request to the FAA for NPIAS inclusion of Kelly Field. The FAA responded in January 2013, that while it applauded the vision of the Authority in redeveloping land conveyed by the U.S. military for economic purposes, there were four areas of concern that prevented a final decision on inclusion. Subsequently, the Kelly Field NPIAS Justification Report was produced to address those concerns, which included (1) whether Kelly Field meets statutory requirements, (2) whether PSA can comply with FAA sponsor assurances, (3) what is the unmet need (from the perspective of civil aviation) that Kelly Field would resolve, and (4) whether the potential projects identified in Kelly Field’s capital improvement plan are for the benefit of civil aviation and eligible for federal funding through the Airport Improvement Program. The Justification Report was deemed sufficient and PSA was notified on July 17, 2014 that Kelly Field was accepted into the NPIAS by the FAA as a “unclassified” GA airport. 3.2.2 Kelly Field Master Plan and Airport Layout Plan – January 2019 The Kelly Field Master Plan is a planning document that evaluates existing facility and market conditions, identifies anticipated stakeholder needs, and formulates both near- and long-term development strategies. It provides planning and strategic guidance necessary for the Authority to address land development of Kelly Field for the next 20 years and beyond. Coupled with the Airport Layout Plan (ALP), the Master Plan serves as a strategic development and marketing tool for the ongoing improvement of airport facilities. The overarching goal of the Master Plan is to provide a high level of customer service and promote regional economic health, while accommodating the ever-changing business requirements of the aviation industry. In order to provide flexibility of future development, recommendations are categorized by physical location and timeframe for the development of improvements. Consequently, improvements are divided by their physical presence throughout Kelly Field and phased in either the near-term (within five years) or long-term (beyond five years). In addition, the Master Plan recommends that some of the areas beyond those associated with Kelly Field, referred to as the “flex development area,” be considered to accommodate non- aeronautical activities with the option of developing it for aeronautical uses at a later timeframe, should the need arise. Recommended near-term development, as shown in Figure 3-4, focuses on the north airfield development area and includes: Preserve aircraft access (Group VI Taxilane) for future aeronautical use to northern developable parcels. Future bisection of Frank Lue Drive to accommodate planned Group VI Taxilane. Midfield GA Terminal with Security and Operations Center. GA hangar storage in the midfield. Specialized 4-bay MRO facility, which could be an aircraft paint facility. Additional areas preserved for MRO or manufacturing facilities.

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Assumption that Building 1470 (211 N Frank Luke Drive) will ultimately be demolished once federal inspection services are relocated. Long-term development focuses on the undeveloped north airfield development area. In order to maximize flexibility, the Master Plan does not recommend a specific set of developments, rather it provides a basic framework for future development, including: The northern 60-acre portion, east of the USAF CPSD building, should be reserved for non- aeronautical development for as long as possible. The larger 125-acre portion of land to the south (of the above described area) should be reserved for a mix of aeronautical (corporate, GA, MRO, manufacturing) and non- aeronautical uses. Regarding the military use area, the Master Plan recommends that the USAF Leaseback area be preserved to accommodate existing and potential future military demands of Kelly Field, to the highest and best possible density. This recommendation will preserve a clear separation of MRO, GA, and military activities. Figure 3-4 - Kelly Field Master Plan Recommended Development Plan (PSA)

Source: PSA Master Plan, 2019

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3.2.3 Kelly Field Airport GIS Study – September 2018 The FAA’s Airport GIS (AGIS) Program establishes standards and specifications for the collection, processing, and validation of spatial data regarding airports. This data is used for a host of purposes, including, but not limited to, establishing geodetic control for engineering projects, assisting in airport planning and land use studies, developing instrument approach and departure procedures, and planning and siting NAVAIDs. Moreover, an AGIS was completed for Kelly Field that resulted in the collection and validation of the following Airport components: Aerial photography survey Runway critical data inventory and survey NAVAID inventory and survey Obstruction critical data inventory and survey (Airport Airspace Analysis for Runways with Vertical Guidance) 3.2.4 Kelly Field Alternative Landing Surface Analysis, Part I – September 2017 The Kelly Field Alternative Landing Surface Analysis was conducted in partnership between PSA and JBSA to determine a long-term solution to eliminate Runway 16-34 closures affecting both parties. In particular, PSA is concerned about the hardship to its customers should significant runway closures be required, and JBSA is concerned that long runway closure periods would likewise cause hardships to the military by requiring deployment of its commands. The Alternative Landing Surface Analysis is partitioned into two parts. Part I, as described herein, evaluates the existing pavement condition at Kelly Field to determine if it required full reconstruction or if future maintenance and repair (M&R) projects could address the pavement needs, as well as the timing of the reconstruction or M&R. Ultimately, the analysis recommends that the inner 75 feet of Runway 16-34, referred to as the keel section, be fully reconstructed due to its deteriorating pavement condition. This recommendation was based on a 2012 study provided by the Air Force Civil Engineering Center (AFCEC), which revealed the keel section had a pavement condition index (PCI) of 51. As an aviation industry standard, PCI values below 65 for a runway (60 for a taxiway) typically point to an invasive rehabilitation, but often warrants full reconstruction. However, AFCEC uses a 50- value threshold to evaluate reconstruction, whereas values between 50 and 70 warrant major M&R (i.e. isolated panel replacement, joint sealant replacement, spall repair, etc. for concrete pavements). In 2016, JBSA completed a major M&R project that raised the PCI from 51 to 64, on average, across Runway 16-34. However, both PSA and JBSA encountered significant operational impacts that translated into equally significant financial burdens during the M&R project. To further increase the PCI and effective usefulness of Runway 16-34, JBSA has programmed additional major M&R with construction planned for fiscal year 2023, but indicated fast-track construction methods that could mitigate lengthy runway closures will not be utilized. Moreover, Part II of this Alternative Landing Surface Analysis strives to coordinate and alleviate future runway closure concerns.

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3.2.5 Kelly Field Alternative Landing Surface Analysis, Part II – August 2018 Part II of the Alternative Landing Surface Analysis includes coordination of runway closure concerns when considering the future maintenance/rehabilitation needs for Runway 16-34, and development of four Courses of Action (COA) aimed to minimize, or altogether eliminate airport closures due to construction. COA No.’s 1 through 3 describe the ability to fast-track minor and major M&R projects, temporarily relocate runway thresholds to facilitate minor and major M&R/rehabilitation/reconstruction, and utilize an existing taxiway as a temporary runway to promote unrestricted construction on Runway 16‐34, respectively. COA No. 4 was selected as the recommended COA by PSA, however, the USAF did not have an official position at the time. COA No. 4 proposes construction of an 11,550-foot long by 200-foot wide Alternative Landing Surface (ALS) parallel to Runway 16‐34 that would provide an all‐weather back‐up runway of ample length and pavement strength to handle both military and civil operations. COA No. 4 is founded on the basis that AFCEC may consider the possibility of waivers to the DOD Unified Facility Criteria (UFC) 3-260-01 Airfield and Heliport Planning and Design (Section 4.4.1) for runway to parallel runway and/or runway to parallel taxiway separation. COA No. 4 recommends that the ALS, proposed to be marked as Runway 16L-34R, serve as a back-up runway only and not for capacity reasons requiring simultaneous (independent) operation activity. As such, wake turbulence concerns due to the closer separation of runways should not be an issue. Without the need for simultaneous operations, the runways can be treated as a single runway by Air Traffic Control (ATC). However, some non‐simultaneous sequencing of activity on the runways to enhance logistics and safety between military and civil aircraft movements in the Air Operations Area (AOA) is envisioned. COA No. 4 is comparative to other joint‐use airfields across the United States that converted a single runway/parallel taxiway airfield to a dual runway/single parallel taxiway airfield. Moreover, this configuration would permanently address future impacts to aircraft operations while also creating a long‐term layout which utilizes the two runways to separate civilian from military activities while offering operational flexibility and providing a back‐up runway when either runway is closed for repair. Implementation of COA No. 4 would occur in incremental development, including immediate needs (year 0 to 5), short-term goals (year 6 to 10), and long- term goals (year 11 and beyond) resulting in the proposed ultimate airfield configuration with the potential for an 11,550-foot ALS shown in Figure 3-5. Figure 3-5 – Proposed Ultimate Alternate Landing Surface (COA No. 4)

Source: Kelly Field Alternative Landing Surface Analysis, Part II, 2018

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3.2.6 Kelly Field Air Traffic Control Tower Siting Study – February 2018 The existing air traffic control tower (ATCT) at Kelly Field is owned and operated by the USAF and located on the western side of the airfield approximately 2,005 feet from the Runway 16-34 centerline. The tower was commissioned in the mid-1960s, consists of six finished floors and a tower cab, is open 24 hours a day, and handles both USAF missions and civilian operations. Utilized as a training facility as well as an ATCT, the tower is in poor structural condition and does not functionally meet current visibility standards, nor does it provide adequate cab space for controllers, supervisors, and instructors based on current design standards. Consequently, the ATCT Siting Study, a joint effort between PSA and USAF, aimed to identify a site to accommodate the shortest possible ATCT that meets DOD Unified Facilities Criteria (Section 3.4) and FAA criteria (Section 3.5) while providing unobstructed views of all controlled airport surface areas and maximum visibility of airborne traffic. Through collaboration among PSA, USAF, and several stakeholders, 15 possible sites were evaluated as new tower locations; three sites were found as possible preferred locations. Upon further analysis and discussion, Site #5A was chosen as the recommended site, which is approximately 80 feet northwest of the existing tower and provides the same line-of-sight viewing angles as the existing tower. Site 5A proposed a tower with an overview height of 139 feet or 814 feet above mean sea level (AMSL) that provided a cab eye level of 109 feet above ground level (AGL) and 784 feet AMSL. The distance to the farthest point in the airfield’s movement area was 8,549 feet at the southeast corner of the arm/de-arm pad on the southeast side of the airfield. Siting criteria used to evaluate the preferred new tower locations included: Visual performance U.S. Department of Transportation (USDOT) Standards for Terminal Instrument Procedures (TERPS) Code of Federal Regulations, Title 14, Part 77, Safe, Efficient Use, and Preservation of the Navigable Airspace Sunlight/daylight Artificial lighting Atmospheric conditions Industrial municipal discharge Site access Interior physical barriers Security 3.2.7 Coordination of Airport Roles – January 2015 In a joint effort between PSA and the City of San Antonio, strategic planning firm LeighFisher conducted an independent review of the roles of SAT, SSF, and SKF. The review followed Kelly

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Field’s acceptance into the NPIAS, in order to determine how Kelly Field might best meet future facility demands of the aerospace community as PSA fulfills its role of economic development and job creation, without undermining or competing with the established roles played by SAT and SSF. Competition among the airports for federal resources and funds were also cited as potential concerns. While definitive roles for each airport were not established, generalized or primary roles are recommended to articulate each airport’s identity, including: SAT – primary air carrier airport serving the San Antonio region, with secondary roles as an air cargo, business aviation, and MRO facility SSF – GA reliever to SAT, primarily focused on mid-market business aviation, recreational aviation, flight training, and GA MRO Kelly Field – industrial airport, primarily focused on aerospace business and MRO, with secondary roles as an air cargo and business aviation facility The review also recommends joint strategic planning between PSA and the City in order to create a long‐term vision, development priorities, goals and objectives of each airport. Subsequently, an economic development committee was to be established with the expressed aim of promoting and coordinating economic development among the airports, which in turn could be developed into a formal, more closely integrated management structure or migration to management of all airports by a single entity. 3.2.8 Consolidated Facilities – January 2021 The Consolidates Facilities is envisioned to accommodate the FBO, U.S. Customs & Border Control FIS, and PSA Operations within a multi-use facility. The purpose of the Consolidated Facilities is to provide greater flexibility in redeveloping landside and apron space currently fragmented by these three operations located in separate facilities. The Consolidated Facilities will accommodate jet and twin-engine aircraft, provide hangar and tie-down parking space, provide access to U.S. Route 90, and airfield access via a dedicated taxiway. Land needed for development of the Consolidated Facilities include seven residential parcels and three commercial parcels, as well as ingress/egress via U.S. Route 90 right-of-way owned by the State of Texas. The proposed Consolidated Facilities configuration is consistent with the Predictable Landing Surface Strategy (PLSS) Alternative 1 described in Section 7.3.4. 3.2.9 Port San Antonio Design and Development Standards – October 2016 The PSA Design and Development Standards were established to foster the use and development of land in an orderly manner by both private and public interests with special consideration given to the appearance of PSA as a result of such development. The standards define PSA’s land use zones, overlay zones, development procedures, and design and development standards for the purpose of the following: To provide for the orderly and functional arrangement of land uses and buildings. To establish standards for the orderly development or redevelopment within PSA.

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To permit public involvement in the planning of land uses which have the potential for significant impact on the use and enjoyment of the surrounding property. To preserve, protect and encourage the development of buildings, groups of buildings and development sites of distinguished architectural character and appearance. To avoid the deterioration of the health, sanitation, safety, and public welfare brought about by poor planning and by indiscriminate and unregulated construction of inferior and unsuitable buildings. 3.3 JOINT LAND USE STUDIES 3.3.1 JBSA-Lackland Joint Land Use Study – November 2011 Developed as a cooperative land use planning initiative between the USAF, PSA, Bexar County, City of San Antonio, and other regional entities, the JBSA-Lackland Joint Land Use Study (JLUS) serves as an ongoing framework to enhance land use compatibility around JBSA-Lackland and improve quality of life in the surrounding community. The JLUS recommendations address a variety of possible land use and operational issues, including noise, physical adjacency to the airfield, air safety, and light pollution. Noise and vibration from overhead flights emanating from JBSA-Lackland can affect the quality of life in surrounding neighborhoods. This includes the risk of an aircraft accident. Conversely, these military and airport operations are susceptible to hazards created by certain nearby civilian activities. Moreover, the JLUS strives to analyze incompatibility issues and offer strategies to alleviate or mitigate those issues. The majority of compatibility issues at JBSA-Lackland are related to growth and noise. As San Antonio continues to develop and grow, more residents, employers, and employees are potentially placed in closer proximity of the base. Continued growth may increase exposure to the base’s aviation and training activities furthering incompatibility issues, including: Noise sensitive uses, such as housing, schools, medical facilities or places of worship. Uses that tend to concentrate people (certain higher residential densities, schools, churches, hospitals). Uses that can interfere with safe air navigation, such as tall structures, or activities that throw off excessive lighting, smoke or dust and may impair vision, particularly during nighttime training exercises. Uses which attract birds and other wildlife that can interfere with the safety of aviation. To analyze incompatibility issues, the JLUS defines four subareas to reflect operational limits of their respective impacts: Air Safety Military Influence Area (MIA), Noise MIA, Main Base Areas of Concern (AOC), and Lackland Training Annex AOC. The Air Safety MIA is based on the CZs and APZs defined in the JBSA-Lackland AICUZ study (Section 3.1.1); the Noise MIA are areas of higher average aircraft noise exposure based on computer modeling that incorporates the frequency and type of aircraft operations; the Main AOC is a 1,500 to 3,000-foot conceptual buffer around the perimeter of the main base intended to encompass property with direct adjacency and to

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reflect areas of potential security vulnerability; and the Lackland Training Annex MIA is omitted due to non-relevance to this Comprehensive Plan. To combat existing and potential incompatibility issues, the JLUS establishes a set of recommendations and strategies aimed to promote land use compatibility and strengthen coordination between JBSA-Lackland and the surrounding communities, including: Conservation/Land Acquisition or Transfer

City/County/Service Provider Plans o Local Government Plans o Utility and Infrastructure Plans Communication and Coordination o General Outreach Materials o Searchable Database o Real Estate Disclosures o Memorandum of Understandings o Automated Notification Process o Ongoing Implementation Body Legislative Initiatives o Limited County Land Use Authority o Enhanced Extra-Territorial Jurisdictional Authority o Annexation o Joint City-County Airport Zoning Board Transportation Outdoor Lighting Noise/Sound Attenuation o Military Sound Attenuation Overlay Zone o Residential Retrofitting Program o Avigation Easements Bird Aircraft Strike Hazard (BASH) Height/Airspace Restrictions Radio Frequency Interference Drainage A summary of the main recommendations and strategies for each subarea is shown in Table 3-1, which includes communications tools, performance standards, compatible uses, and current policies or any additional local regulatory or state legislative actions that are necessary to protect the safety of affected property.

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Table 3-1 - JLUS Main Recommendations by Subarea CURRENT COMMUNICATION PERFORMANCE COMPATIBLE SUBAREA CONTROLS/ADDITIONAL TOOL STANDARD USE/LIMITATIONS ACTIONS REQUIRED Air Safety MIA • CZ is mostly owned by • No uses permitted • No uses permitted • No uses permitted (CZ) the USAF • MAOZ is in place • Real estate • Height restrictions • No new single-family • MLOD is in place disclosure • No electrical or visual housing • Develop disclosure Air Safety MIA • Joint Consultation interference • Maximum 3,000 methods (APZ I) through an MOU • No BASH hazards square foot building • Develop MOU • Searchable • Shielded outdoor size for industrial and • Rezone for MLOD database lighting commercial uses • Develop BASH standards • MAOZ is in place • One (1) new single- • Real estate • Height restrictions • MLOD is in place family residence per disclosure • No electrical or visual • Develop disclosure acre Air Safety MIA • Joint consultation interference methods • Maximum 250,000 (APZ II) through an MOU • No BASH hazards • Develop MOU square foot building • Searchable • Shielded outdoor • Rezone for MLOD size for industrial and database lighting • Develop BASH commercial uses standards • Non-noise sensitive • MSAO is in place uses (retail, • Develop disclosure • Real estate industrial) are most methods disclosure • Sound attenuation for compatible • Develop MOU • Joint consultation Noise MIA permitted noise • Noise sensitive uses • Rezone for MSAO through an MOU sensitive uses (houses, schools, • Explore easement or • Searchable medical facilities) acquisition options database should be attenuated • Explore attenuation or limited in density retrofitting • No use limitations recommended • Redevelopment • Real estate should increase • MLOD is in place disclosure buffer from base • Develop disclosure Main Base • Joint consultation • Shielded outdoor perimeter where methods AOC through an MOU lighting possible and avoid tall • Develop MOU • Searchable structures or dense • Rezone for MLOD database development to enhance installation security Source: JBSA-Lackland JLUS, 2011 3.4 U.S. DEPARTMENT OF DEFENSE 3.4.1 DOD Unified Facilities Criteria 3-260-01 Airfield and Heliport Planning and Design – February 2019 UFC 3-260-01 provides requirements for evaluating, planning, programming, and designing airfields and heliports at DOD installations. It provides standardized airfield, heliport, and airspace criteria for the geometric layout, design, and construction of runways, helipads,

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taxiways, aprons, landing zones (LZs), short take-off and vertical landing (STOVL) facilities, unmanned aircraft system (UAS) facilities and related permanent facilities to meet sustained operations. Design standards to determine obstructions to the airspace relative to each runway are also defined, which are commonly referred to as “imaginary surfaces” and further discussed in Section 3.6.1. 3.4.2 DOD Unified Facilities Criteria 2-100-01 Installation Master Planning – October 2019 UFC 2-100-01 provides requirements for installation master planning in support of the installation mission. It outlines comprehensive planning strategies through facility and infrastructure development, including planning, programming, engineering and design, construction, reuse, real estate actions, public-private ventures, operations and maintenance, and disposal. Further, it focuses on ten strategies in order to develop a master plan that supports the effective execution of assigned military missions at the installation, including: Sustainable Planning Natural, Historic and Cultural Resource Management Healthy Community Planning Defensible Planning Capacity Planning Area Development Planning Network Planning Form-Based Planning Facility Standardization Plan-Based Programming 3.5 FEDERAL AVIATION ADMINISTRATION 3.5.1 Advisory Circular 150/5300-13A Airport Design – February 2014 Advisory Circular (AC) 150/5300-13A is a multifaceted document that contains the FAA standards and recommendations for the geometric layout and engineering design of runways, taxiways, aprons, and other facilities at civil airports such as NAVAIDs and transportation infrastructure. It also provides guidance on the planning of airports, including determining an airport’s critical aircraft, runway design code, taxiway design group, and runway approaches. Furthermore, it is the primary resource for planning and designing airports under FAA purview. 3.6 CODE OF FEDERAL REGULATIONS 3.6.1 Code of Federal Regulations Title 14, Part 77 – July 2010 Code of Federal Regulations Title 14, Part 77, titled Safe, Efficient Use and Preservation of the Navigable Airspace (Part 77) defines the airspace around civil runways and subsequently provides design standards to determine obstructions to the airspace, including air navigation and communication facilities. These are commonly referred to as “imaginary surfaces” and are

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established with relation to the airport and to each runway. The size of each such imaginary surface is based on the category of each runway according to the type of approach available or planned for that runway. The slope and dimensions of the approach surface applied to each end of a runway are determined by the most precise approach procedure existing or planned for that runway end. The definitions of the Part 77 imaginary surfaces are listed below, and a 3D diagram is shown in Figure 3-6. The DOD has established obstruction criteria that differ from civil airports discussed above. Subsequently, the DOD has requested that the criteria be incorporated into Part 77 for application at military airports, except heliports, controlled by components of the DOD, where the longest runway exceeds 5,000 feet. The DOD advises that these separate criteria are required at military airports because of the operating characteristics of certain military aircraft, the necessity for low-altitude maneuvering and formation takeoffs, the more stringent air crew training, and the armament and ordnance-carrying requirements of the military. Obstruction criteria based on military runway types are detailed in DOD UFC 3-260-01 Airfield and Heliport Planning and Design (Section 3.4.1). Horizontal Surface The horizontal surface is established 150 feet above the airport elevation. The perimeter of the horizontal surface created by swinging arcs of a specified radii from the center of each end of the primary surface of each runway of each airport and connecting the adjacent arcs by lines tangent to those arcs. Conical Surface A surface extending outward and upward from the periphery of the horizontal surface at a slope of 20 to 1 for a horizontal distance of 4,000 feet. Primary Surface A surface longitudinally centered on a runway that extends 200 feet beyond each end of that runway. The elevation of any point on the primary surface is the same as the elevation of the nearest point on the runway centerline. Approach Surface A surface longitudinally centered on the extended runway centerline and extending outward and upward from each end of the primary surface. An approach surface is applied to each end of each runway based upon the type of approach available or planned for that runway end. Transitional Surface The transitional surface extends outward and upward at right angles to the runway centerline and the runway centerline extended at a slope of 7 to 1 from the sides of the primary surface and from the sides of the approach surfaces.

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Figure 3-6 – 3D Diagram of Part 77 Imaginary Surfaces

Source: National Geodetic Survey, National Oceanic and Atmospheric Administration (NOAA), date unknown 3.7 CITY OF SAN ANTONIO 3.7.1 San Antonio Approved Master Development Plan, Port San Antonio – October 2008 San Antonio reviews Master Development Plans (MDP) to ensure proposed projects are in compliance with current regulations and San Antonio’s Master Plan. Upon approval, the project is to comply with the applicable Validity requirements of San Antonio’s Unified Development Code 35-412 concerning MDPs. The MDP is a flexible plan that may be amended by the applicant as needed, of which each amendment undergoes a review process. The MDP for PSA, dated August 4, 2008 and shown in Figure 3-7, was approved by San Antonio Department of Development Services on October 20, 2008. It states that the Kelly Field portion of PSA is 1,403.05 acres and zoned either Mixed Heavy Industrial (MI-2S) or Commercial (C-3), which are referred as the site’s base zoning. For additional zoning information, see Section 3.7.4. Figure 3-7 – Port San Antonio Approved Master Development Plan

Source: City of San Antonio Approved MDP, PSA, 2008

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3.7.2 San Antonio Tomorrow Comprehensive Plan – August 2016 The San Antonio Tomorrow (SA Tomorrow) Comprehensive Plan is San Antonio’s official Comprehensive Plan providing a 25-year framework to guide future growth and development. Further, the Plan addresses land use, urban design, and municipal policy to coordinate City resources and incentive programs to pro-actively accommodate projected growth and provide more choices for current and future residents. The Plan includes nine “plan elements” that detail a host of topics and issues throughout San Antonio, including growth and city form, transportation and connectivity, housing, jobs and economic competitiveness, community health and wellness, public facilities and community safety, natural resources and environmental sustainability, historic preservation and cultural heritage, and the military. The Plan also includes 13 “regional centers” that encompass large employment centers where new development and growth is occurring. Divided into three types (activity centers, logistics/service centers, and special purpose centers), the Plan attempts to guide growth in these regional centers by building on their respective existing pattern of development. Kelly Field is a component of the JBSA-Lackland/PSA Special Purpose Regional Center further described below. Military Plan Element The military plan element identifies four key issues within the city-military dynamic and provides six goals and 39 policies for San Antonio to utilize to address those issues. Goals are the broadest statements of San Antonio’s desired long-term direction and describe the ideal result if the Comprehensive Plan is fully implemented. Policies are statements that identify San Antonio’s preferred actions to achieve those goals through broad themes, including land use, regulations and ordinances, communication and collaboration, infrastructure and investment, education/training and economic development, and quality of life and wellness. The four key issues include land use and military integration, encroachment, economic impact and employment, and care for service members, families, and veterans. Policies are grouped into broad areas, including: Land Use Regulations and Ordinances Communication and Collaboration Infrastructure and Investment Education/Training and Economic Development Quality of Life and Wellness JBSA-Lackland/PSA Special Purpose Regional Center SA Tomorrow includes specific recommendations for three types of regional centers: activity centers, logistics/service centers, and special purpose centers. In relation to this Plan, JBSA- Lackland and PSA are identified as a collective special purpose center and significant economic

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driver for San Antonio. The JBSA-Lackland/PSA special purpose center includes over 8,600 developed acres with over 50,000 employees and nearly 20,000 residents. While the regional center offers strong transportation connectivity by land, air, and rail, SA Tomorrow recommends that expanded housing options would benefit JBSA-Lackland and PSA employees. 3.7.3 San Antonio Tomorrow Multimodal Transportation Plan – August 2016 The SA Tomorrow Multimodal Transportation Plan serves as San Antonio’s long-range blueprint for travel and mobility in San Antonio and Bexar County. Further, the Plan provides policy guidance to achieve the transportation and connectivity goals established in the SA Tomorrow Comprehensive Plan. The Multimodal Transportation Plan covers a myriad of topics ranging from walking, biking, public transportation, and automobiles. It also includes corridor plans that aim to address issues of connectivity, multimodal options, and safety by providing possible short term operational and safety improvements that would generate long-term benefits and serve as an example for improvements elsewhere in San Antonio. One noteworthy corridor plan relative to this Comprehensive Plan is SW/SE Military Drive from Quintana Road to South WW White Road. Military Drive is a major arterial connecting to other high-volume facilities such as IH 37, IH 35 and US Highway 90, and provides important access and connection to economic generators including PSA and Brooks City Base. Moreover, the Plan offers two long-term multimodal options to increase transportation options and improve capacity, including: Future Option 1: provide bus rapid transit (BRT) service within a dedicated curb lane in each direction but place bicycle traffic on adjacent residential streets (Figure 3-8). Future Option 2: provide BRT service within mixed traffic and provide a separated and protected bicycle lane. Figure 3-8 – Military Drive Future Option 1 (Curb Running Bus Rapid Transit)

Source: San Antonio Tomorrow Multimodal Transportation Plan, 2016 3.7.4 Unified Development Code, Zoning – January 2020 San Antonio’s Unified Development Code (UFC) provides comprehensive zoning in accordance with the Texas Local Government Code with intentions to lesson congestion in streets; secure safety from fire, panic, and other dangers; promote health and general welfare; provide adequate light and air; prevent overcrowding of land; avoid undue concentrations of population; or facilitate provision of transportation, water, sewers, schools, parks, and other public requirements. The UDC also incorporates the Texas Airport Zoning Act of 1987 that serves as a local planning tool to regulate the development of land and protect the airspace surrounding an

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airport. Further, the UDC includes base zoning and various zoning overlay districts, adopted as a result of the JBSA JLUS described in Section 3.3.1, that help ensure compatibility between Kelly Field and surrounding development. The zoning overlay districts relative to this Comprehensive Plan, as described below, include the Military Airport Overlay Zoning District, the Airport Hazard Overlay District, and the Military Lighting Overlay District. For information on PSA’s base zoning, see Section 3.7.1 regarding the approved MDP. Base Zoning The base zoning for PSA applicable to Kelly Field is MI-2S, which is Mixed Heavy Industrial with an authorized specific use set forth in Section 35-423 of the Unified Development Code (UDC). As described in the PSA Design and Development Standards (Section 3.2.9), the MI-2S zone allows most light manufacturing such as warehousing and machine shops to more intensive uses that could potentially generate high volumes of truck traffic or could involve major transportation terminals. The special uses requested by PSA and approval by the San Antonio City Council include: Metal Forging or Rolling Mill Airport Non-Governmental Aircraft Maintenance and Repair Jet Engine Maintenance and Repair Rail Car Maintenance and Repair Trans-load Facilities Rail Service Facilities Land uses are restricted to those permissible in the MI-2 zoning district. Additionally, all building and paving setbacks, landscape buffers and buffer yards, and building heights must comply with San Antonio’s UDC, with the exception of the tree canopy coverage requirement. Military Airport Overlay Zoning District The City of San Antonio established the Military Airport Overlay Zoning District (MAOZ) in order to promote the public health, safety, peace, comfort, convenience, and general welfare of the inhabitants of military airport environs and to prevent the impairment of military airfields and the public investment therein. The adopted MAOZ boundaries are the safety zones established in the USAF AICUZ for JBSA-Lackland (Section 3.1.1), including the CZs and APZs. The MAOZ strive to promote safety in the areas relative to military airport runways by limiting the density of development and intensity of uses. Moreover, the MAOZ intend to: Guide, control, and regulate future growth and development. Promote orderly and appropriate use of land. Protect the character and stability of existing land uses. Enhance the quality of living in the areas affected.

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Protect the general economic welfare by restricting incompatible land uses. Prevent the establishment of any land use which would endanger aircraft operations and the continued use of military airports. Airport Hazard Overlay District The City of San Antonio established the Airport Hazard Overlay District (AHOD) in the interest of public health, public safety and general welfare due to hazards associated with the operation of Kelly Field, SAT, and SSF. The AHOD also strives to protect public investment in these airports and their safe, efficient operation by protecting their flight paths and airfield imaginary surfaces defined in Part 77 (Section 3.5.1.). Moreover, the AHOD imposes height restrictions on areas near these airports, sets development standards for land use, analyzes nonconforming land uses, and resolves conflicting regulations. Military Lighting Overlay District San Antonio established the Military Lighting Overlay District (MLOD) to regulate outdoor lighting impacting military operations five (5) miles or less from the perimeter of JBSA-Lackland, Camp Bullis/Camp Stanley, and . The purpose of the MLOD is to: Reduce glare and potential distractions to nighttime training exercises occurring within this area. Balance the needs of the military, the San Antonio community, and property owners regarding responsible development including outdoor lighting within this area. Permit the use of outdoor lighting that does not exceed the minimum level as guided by Illuminating Engineering Society (IES) recommended practices for night-time safety, utility, security, productivity, enjoyment and commerce. Minimize adverse offsite impacts of lighting such as light trespass, and obtrusive light. 3.7.5 Unified Development Code, Development Standards – January 2020 The San Antonio UDC establishes land development standards for any land development application within the San Antonio municipal boundary, except as otherwise noted in the UDC. The UDC development standards include: Infrastructure (traffic and transportation, utilities and parkland dedication) Landscaping and tree preservation Lot layout, height and density/intensity standards Natural resource protection Parking and storage standards 3.7.6 Unified Development Code, Historic Preservation and Urban Design – January 2020 The San Antonio UDC establishes historic preservation and urban design standards for the protection of historic, cultural, archaeological and artistic resources. The City of San Antonio designates a city historic preservation officer that administers these standards through the Office

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of Historic Preservation, which reviews and offers recommendations to the Historic and Design Review Commission for each applicable development application. Historic resources relative to Kelly Field and this Comprehensive Plan are described in Section 6.2.3. 3.7.7 Major Thoroughfare Plan – September 1978 As adopted in 1978, the Major Thoroughfare Plan identifies the location of San Antonio major roadways that were expected to accommodate through traffic to the year 2000 and beyond. The intent of the plan is to support the Land Use Plan, to serve as a guide for determining right-of- way requirements, and to establish policies concerning the construction of major roadways in support of orderly urban development through the land subdivision process. Further, the plan establishes a roadway system to accommodate varying levels of traffic, including: Expressways – controlled access highways to serve the highest travel demands by providing grade separation and ramps to primary and secondary arterials Primary Arterials – streets to serve high travel demand with connections to expressways Secondary Arterials – streets to serve high travel demand with connections to primary arterials and activity centers Collector Streets – streets to serve medium travel demand with connections to secondary arterials Local Access Streets – streets to serve low travel demand with connections to collector streets 3.7.8 Major Thoroughfare Plan Map – January 2020 The Major Thoroughfare Plan Map compliments the 1978 Major Thoroughfare Plan as it is routinely updated to reflect the needs of San Antonio in real time, by identifying the alignment and functional types of roadway facilities for long-term growth. Relative to PSA and JBSA- Lackland, the map includes a proposed secondary arterial that bisects the JBSA-Lackland Kelly Field District by extending South Callaghan Road south to SW Military Drive near the intersection of Old Pearsall Road. The proposed secondary arterial would utilize existing roadways in the Kelly Field District and would create new roadways through a forested area just east of Gateway Hills Golf Course. 3.7.9 Transportation and Capital Improvements – Continuously Updated Bond Program Projects Multiple 2017 Bond Program projects sited in the vicinity of PSA and JBSA-Lackland will impact accessibility and drainage near Kelly Field, as shown on the TCI Bond Program webmap at https://gis.sanantonio.gov/TCI/BondProjects/index.html. Two projects of note to be completed within this Plan’s 20-year planning horizon include: 2017 Bond Project #23-01633 – Expand drainage infrastructure at PSA to provide adequate storm water capacity and reduce on-going flooding risks. This project is located east of Kelly Field, within PSA, and extends from General Hudnell Drive to Berman Road, with an estimated completion date of March 2021.

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2017 Bond Project #23-01579 – Improve Enrique M. Barrera Parkway corridor with street, drainage and sidewalk improvements as appropriate. This project is located north of Kelly Field and extends from SW 34th Street to State Route 151, with an estimated completion date of May 2022. Infrastructure Management Program The Infrastructure Management Program (IMP) is a five-year rolling program that focuses on the maintenance of San Antonio’s infrastructure. Service needs are identified city wide and are scheduled for street maintenance, alley maintenance, drainage maintenance, sidewalks, traffic signals, pavement markings and Advanced Transportation District (ATD) related projects. The majority of planned 2019-2024 IMP projects in the vicinity of PSA and JBSA-Lackland are street pavement preservation or rehabilitation projects, as shown on the TCI IMP webmap at https://gis.sanantonio.gov/TCI/TCI_IMP/default.html. 3.7.10 Coordination of Airport Roles – January 2015 Coordination of Airport Roles is described in Section 3.2.7 under PSA, due to the fact that this was a joint effort between PSA and the City of San Antonio. 3.8 STATE OF TEXAS 3.8.1 Texas Department of Transportation Airport Compatibility Guidelines – January 2003 TxDOT developed the Airport Compatibility Guidelines as a reference source for elected officials, zoning board members, and city and county staff members responsible for assuring compatibility between an airport and the community it serves. However, the guidelines are applicable to PSA and the USAF relative to this Comprehensive Plan. The guidelines describe methods for planning in and around airport environments, such as assessing land use compatibility relative to height restrictions and noise exposure. The guidelines also detail implementation measures intended to reduce noise exposures and actions to forestall incompatible development, including: Facility changes Changes in operational procedures Restrictions on operations Acquisition of property Restrictive covenants Plat review Condemnation Subdivision and zoning regulations Building codes Capital improvements

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3.8.2 Texas Department of Transportation Texas Airport System Plan – March 2010 The Texas Airport System Plan (TASP) identifies airports and heliports that perform an essential role in the economic and social development of Texas. Further, it provides guidelines to help policymakers and aviation planners determine how to maximize the return on investment of public funds and identifies what capital improvements would best serve the state's aviation needs. The focus of the TASP is on the GA airports that provide capacity to the Texas airport system in urban areas served by commercial service airports and on the airports serving the state’s smaller communities from the cognition that an adequate airport is an essential component to attracting business development to expand their local economies. While Kelly Field is not listed in the published March 2010 TASP, it was added in late 2010.

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KELLY FIELD EXISTING CONDITIONS

4.1 DEFINITION The eastern components of Kelly Field are comprised of three distinct areas as defined in the 2013 JUA: the PSA Exclusive Use Area, the USAF Exclusive Use Area, and the Jointly Used Flying Facilities. These areas are shown in Figure 4-1, Figure 4-2, and Figure 4-3, and defined below. 4.1.1 Exclusive Use Areas At the time of execution of the 2013 JUA, the PSA and USAF Exclusive Use Areas were defined as those areas depicted in Figure 4-1, Figure 4-2, and Figure 4-3. However, the PSA Exclusive Use Area in the North Airfield has been modified for this Comprehensive Plan to include additional areas for flexible development supporting aviation and/or non-aviation uses (“the North Airfield Flex Development Area”), as shown in Figure 4-4. The USAF Exclusive Use Area to the east of the Jointly Used Flying Facilities is owned by PSA and currently under a leaseback agreement to the USAF, as defined and described in the PSA Leaseback District ADP (Section 3.1.3). The USAF Exclusive Use Area to the west of the Jointly Used Flying Facilities consists of the Kelly Field District as defined in the JBSA ADP (Section 3.1.2.) and is owned by the USAF. 4.1.2 Jointly Used Flying Facilities The Jointly Used Flying Facilities are defined in the 2013 JUA as “the runways, taxiways, lighting systems, navigational aids, markings, and appurtenances located on [Kelly Field] and associated with the airfield and open to public use” and depicted in Figure 4-1, Figure 4-2, and Figure 4-3. Figure 4-1 – Jointly Used Flying Facilities, North Airfield

Source: JUA, 2013

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Figure 4-2 – Jointly Used Flying Facilities, Mid-Airfield

Source: JUA, 2013 Figure 4-3 – Jointly Used Flying Facilities, South Airfield

Source: JUA, 2013

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4.2 EXISTING AIRFIELD, FACILITIES, AND LAND USE As defined in Section 4.1, Kelly Field consists of the PSA Exclusive Use Area, the USAF Exclusive Use Area, and the Jointly Used Flying Facilities. Figure 4-4 illustrates the boundaries of these areas in red, blue, and purple shading, respectively, with subdivisions labeled and described in the proceeding sections. Figure 4-4 – Components of Kelly Field

Source: CHA, Google Earth, 2020

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4.2.1 Port San Antonio Exclusive Use Areas PSA encompasses the civilian aviation component at Kelly Field and is divided into three areas: the North Airfield, North Airfield Flex Development Area, and the South Airfield, as shown in Figure 4-4 and detailed below. North Airfield The North Airfield consists of ten buildings as detailed in Table 4-1 and described below. Table 4-1 – PSA Exclusive Use Area Building Inventory in North Airfield BUILDING PSA CUSTOMERS NUMBER 607 GDC Technics 1410 Forward Air 1420 GDC Technics 1425 Safran 1426 Bario Aviation 1427 Fixed Base Operator Atlantic Aviation 1428 Boeing San Antonio 1438 Safran 1440 GoAeroMx 1470 Pinnacle Logistics U.S. Customs & Border Protection Federal Inspection Services Multi-Use Air Cargo Facility Source: PSA Kelly Field ALP, 2018, PSA, 2020. Fixed Base Operator Atlantic Aviation is the sole Fixed Base Operator (FBO) at Kelly Field and provides a host of aircraft and passenger services, including: Jet fuel FBO Atlantic Aviation Terminal Building 100LL fuel Hangar space Terminal building with pilot and crew lounge (ALP building #1427) Car rentals Air stairs and ground handling Flight planning Source: www.atlanticaviation.com, accessed 24/7 surveillance and security 1/27/2020 U.S. Customs & Border Protection Federal Inspection Station and Multi-Use Cargo Facility The U.S. Customs & Border Protection Federal Inspection Station (FIS) facility opened in early 2009 and provides inspection services for international cargo and agricultural products. The FIS operates under a user-fee agreement with PSA and is co-located with the multi-use cargo facility for PSA customers requiring cargo services.

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Terminal Apron The terminal apron in the North Airfield is approximately 4.8M SF and is designated for industrial aviation development in the future. Other PSA Customers Six PSA customers are in the North Airfield and provide a host of specialized commercial and military MRO services, as well as air medical transport and cargo services, including:

Bario Aviation – Flight school dedicated to providing flight training for all levels of pilots. The company also offers services such as aircraft rentals, instrument proficiency checks and aircraft maintenance. GDC Technics – Provides innovative aircraft design solutions, along with engineering, installation, and maintenance services for narrow and wide-body aircraft. Additionally, GDC Technics specializes in luxury aircraft interiors for heads-of-state and other VIPs. GoAeroMx – Maintenance services company developed from worldwide operating and management experience in VIP transport category aircraft, including regulatory compliance, program development, auditing, and in-service technical support. Pinnacle Logistics – Established, fully qualified, insured and US Customs bonded motor carrier offering airport transfers, local delivery, line haul and, airport-to-airport and door- to-door service, CFS handling and exclusive use deliveries. Safran – Supplier of systems and equipment in aerospace (propulsion, equipment), defense and security markets. Forward Air – Provider of ground transportation and related logistics for air freight and expedited less-than-load (LTL) freight markets. Currently, Forward Air at Kelly Field only provides LTL freight services and does not rely on the airfield for any operations.

North Airfield Flex Development Area The North Airfield Flex Development Area consists of undeveloped land with limited minor road and infrastructure improvements. South Airfield The South Airfield consists of six buildings as detailed in Table 4-2 and discussed below. Table 4-2 – PSA Exclusive Use Area Building Inventory in South Airfield BUILDING PSA CUSTOMER NUMBER 361 Boeing San Antonio 365 Boeing San Antonio 375 Boeing San Antonio 379 Boeing San Antonio 385 Boeing San Antonio 400 Boeing San Antonio Source: PSA Kelly Field ALP, 2018, PSA, 2020

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Boeing San Antonio Boeing San Antonio has a major presence at PSA, as the sole customer occupying the South Airfield, including approximately 1.6M SF of facility space and 4.9M SF of apron space. Boeing is the world’s leading aerospace firm providing maintenance, repair and overhaul services for military and commercial aircraft. 4.2.2 U.S. Air Force Exclusive Use Areas The USAF encompasses the military aviation component at Kelly Field and is divided into two areas: the Kelly Field District west of the Jointly Used Flying Facilities and the PSA Leaseback District east of the Jointly Used Flying Facilities. The Kelly Field District is located within the fenceline of JBSA-Lackland, with the 433rd AW and 149th FW as the primary military users of Kelly Field, shown in Figure 4-5. The PSA Leaseback District is located on PSA property under a leaseback agreement, as shown in Figure 4-2. Figure 4-5 – JBSA-Lackland Kelly Field District

Source: CHA, Google Earth, 2020 4.2.3 Jointly Used Flying Facilities The Jointly Used Flying Facilities consist of the airfield components related to the operation of Kelly Field, ranging from the runway and taxiways to navigational aids and lighting. Figure 4-6 shows an overview of the principle aviation components at Kelly Field.

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Figure 4-6 – Jointly Used Flying Facilities at Kelly Field

Source: CHA, Google Earth, 2020 Air Traffic Control Tower Air traffic services are provided by the USAF. PSA, as the sponsor for civil aircraft operations at Kelly Field, is required to comply with the requirements of the Record of Decision (ROD) concerning the Joint Use Supplemental Environmental Impact Statement dated August 2000, the JUA, and the Airfield Operations Instruction. Therefore, all ground and air movements of both military and civil aircraft in the controlled movement areas of Kelly Field must be controlled by the Air Traffic Control Tower (ATCT), which is operated by the USAF. The ATCT is located within the Kelly Field District, just north of Taxiway G. A new ATCT has been funded and construction is anticipated to begin in calendar year 2021.. Aircraft Rescue and Fire Fighting The USAF provides fire and crash rescue services to all military and civil aircraft for landing and take-off when under the control of the ATCT. The aircraft rescue and firefighting (ARFF) facility is located within the Kelly Field District just north of Taxiway G (Figure 4-5). Runway and Taxiway System The existing runway at Kelly Field, Runway 16-34 (formerly designated as 15-33), is oriented in a northwest/southeast direction and is 11,550 feet long by 300 feet wide, but striped for 150 feet in width for aircraft usage. There is a 1,000-foot blast pad on the south end and a 150-foot blast pad on the north end; the north end has also a 700-foot unpaved overrun beyond its blast pad. The center portion of the runway (width) and the last 1,000 feet on both ends are constructed of Portland Cement Concrete (PCC). The runway edges and shoulders are constructed of Asphalt Concrete (AC). The load bearing capacity is 81,000 lbs. for single wheel configurations, 122,000 lbs. for dual wheel configurations, 477,000 lbs. for dual tandem wheel configurations, and

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837,000 lbs. for double dual tandem wheel configurations. Additionally, Runway 16-34 is classified as a USAF Class B runway, which are primarily intended for high-performance and large, heavy aircraft like the C-5 and F-16 that both operate at Kelly Field. Runway 16-34 is served by a full-length 75-foot parallel taxiway – Taxiway A. Taxiways A1, B, C, D, E, and F provide runway access to the PSA Exclusive Use Areas and the Mid-Airfield. Taxiways G, H, J, and K provide access to the Kelly Field District. All of the taxiways at Kelly Field are constructed of PCC with AC shoulders. Navigational Aids and Instrument Approach Procedures Instrument approach procedures assist properly trained flight crews and properly equipped aircraft to operate during poor weather conditions. Historically, instrument approach procedures relied on ground based electronic NAVAIDs and were classified as either “precision” or “non- precision.” Non-precision approaches provide only lateral guidance, whereas precision instrument approaches provide both lateral and vertical guidance. At Kelly Field, the only ground- based, non-precision NAVAID is the Tactical Air Navigation (TACAN) system, which is used by the USAF. The TACAN provides the user with a distance and bearing from a ground station and is a more accurate version of the very high frequency (VHF) omnidirectional range/Distance Measuring Equipment (VOR-DME) that provides range and bearing information to civil aircraft. NAVAIDs supporting precision approaches are collectively called an Instrument Landing System (ILS) and include a Localizer (providing lateral guidance), a Glideslope (providing vertical guidance) and an approach lighting system (providing close-in visual guidance). New advances in Global Positioning System (GPS) technology allow “vertically-guided instrument approach procedures” and ILS-like approach capability without the need for all of the traditional ground- based ILS NAVAID components. Based on current FAA classifications in AC 150/5300-13A, the four types of approach categories include: Visual (V): Approaches performed under visual flight rules only, when meteorological conditions include a ceiling height of 1,000 feet or greater and visibility of 3 miles or greater. Non-Precision Approach (NPA): Instrument approach procedures providing only lateral guidance with a ceiling minimum of 400 feet above the threshold. These can include VHF Omnidirectional Range (VOR), non-directional beacon (NDB), area navigation (RNAV), lateral navigation (LNAV), localizer performance (LP), and localizer (LOC) equipment. Approach Procedure with Vertical Guidance (APV): Instrument approach procedures providing vertical guidance to 250 feet above the threshold and visibility minimums as low as ¾ mile. These can include an ILS, LNAV/Visual Navigation Aids (VNAV), Localizer Performance with Vertical Guidance (LPV) or Area Navigation (RNAV) Required Navigation Performance (RNP). Precision Approach (PA): Instrument approach procedures providing vertical guidance to less than 250 feet above the threshold and visibility minimums lower than ¾ mile. These

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can include an ILS, LPV, and Global Navigation Satellite System (GNSS) Landing System (GLS). Each end of Runway 16-34 is equipped with a Category I (CAT-I) ILS which supports precision approach minimums of 200-foot decision height (i.e. cloud ceiling) and ½-mile visibility (the best minimums possible for a CAT-I approach). The category of an ILS refers to the accuracy of the system. Higher categories are more accurate and provide lower approach minimums. For example, Category III systems can provide minimums as low as zero feet ceiling and zero visibility and are typically reserved for only the busiest of commercial airports. GPS approaches are also available to both runway ends. Kelly Field has High Altitude Approach Procedures which are procedures that usually begin at or above 18,000-foot mean seal level (MSL). The beginning altitude may be lower to achieve compatibility with airspace constraints and optimum traffic flows. These approaches are utilized by tactical military jets to minimize the time at low altitudes and save fuel on their final approach. Kelly Field offers HI-ILS and HI-TACAN approaches to both runway ends. The approaches available at Kelly Field and the established weather minimums are summarized in Table 4-3. Kelly Field does not currently have any Standard Instrument Departure (SID) procedures. Table 4-3 – Existing Instrument Approach Procedures RUNWAY END APPROACH TYPE APPROACH METHOD MINIMUMS – CEILING (AGL) / VISIBILITY HI-ILS 200’ / ½ mile PA ISL 200’ / ½ mile 3 APV RNAV (GPS) 600’ / 1 /8 mile Runway 16 HI-TACAN 500’ / ¾ mile NPA TACAN 500’ ¾ mile1 V Visual 1,000’ / 3 miles HI-ILS 200’ / ½ mile PA ILS 200’ / ½ mile 3 APV RNAV (GPS) 600’ / 1 /8 mile Runway 34 HI-TACAN 500’ / 1 mile NPA TACAN 500’ / 1 mile1 V Visual 1,000’ / 3 miles Source: PSA Kelly Field Master Plan, 2019 1 Approach Visibility Minimums are ½ mile for Approach Category A and B aircraft. Approach and Airfield Lighting Existing approach lighting systems at Kelly Field aid in the safety of landing aircraft, which includes Approach Lighting System with Sequenced Flashing Lights configuration 1 (ALSF-1) and Precision Approach Path Indicator (PAPI) Lights. ALSF-1 (an element of the ILS) are located at both runway ends and assist pilots transitioning from the cockpit instrument landing segment to the runway environment. A PAPI is a system of lights located near a runway end, which provides pilots with visual descent guidance during an approach to the runway. Airfield lighting supplements instrument NAVAIDs and approach lighting to aid in the safety of landing, taking off, and taxiing aircraft around the airfield. Existing airfield lighting at Kelly Field includes a rotating beacon, runway threshold lighting on both runway ends, runway edge lighting,

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and taxiway edge lighting. The rotating beacon functions as the universal indicator for locating an airport at night and is generally visible 10 miles from the airport. Threshold identification lights make use of a two-colored lens, red and green; the green half of the lens faces the approaching aircraft and indicates the beginning of the usable runway, while the red half faces the airplane on the rollout or takeoff, indicating the end of the usable runway. Runway edge lighting is used to outline the edges of a runway during periods of darkness or restricted visibility. Taxiway lighting delineates the taxiway’s edge and provides guidance to pilots during periods of low visibility and at night.

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ECONOMIC IMPACT ANALYSIS

One of the objectives of this Comprehensive Plan is to define the economic impact of Kelly Field. While previous economic studies have included Kelly Field within the greater context of PSA and JBSA, such as the State of Texas Comptroller Office (“the Comptroller”) described in Section 5.1, no studies have solely focused on the airfield at Kelly Field to evaluate its unique economic impact to the local and regional economy. To that end, an economic impact analysis of Kelly Field was prepared by Wiedemann & Associates, an independent consultant specializing in aviation-related economic impact analysis, for inclusion in this Comprehensive Plan. The study identities impacts associated with the airfield portion of PSA and JBSA-Lackland; therefore, it focused on those businesses and organizations that are dependent upon the functional operation of the airfield. The importance of the airfield operation is showcased in this analysis, because if it were ever permanently closed, those dependent businesses would be permanently lost. This is not inherently true of the non-aeronautical businesses located at PSA or JBSA-Lackland. 5.1 PREVIOUS ECONOMIC IMPACT STUDY6 The Comptroller is charged with overseeing the state’s finances and routinely conducts economic impact analyses regarding the economic health of Texas. In 2018, the Comptroller prepared an economic report of PSA that assessed its contribution to Texas economy as one of 29 official ports of entry in the state. PSA had more than 100 direct employees managing 1,900-acre campus that supports more than 80 public- and private-sector tenants that employed approximately 13,400 in 2018, as detailed in Table 5-1. This Table includes about 6,100 military personnel, mostly airmen from the USAF, who work for one of the DOD activities located within the PSA campus. Among these is the 16th Air Force, a cybersecurity command within the USAF that employs more than 1,000 uniformed and civilian personnel. Table 5-1 – State of Texas Comptroller’s Report on Direct Jobs at PSA JOB TYPES NUMBER OF JOBS Military 6,100 Aerospace 3,215 Business Services 1,300 Logistics 1,050 Cybersecurity 775 Manufacturing/Applied Tech 530 Other 180 Education 110 Port Authority 104 TOTAL JOBS 13,364 Source: Texas Comptroller Report: “Port San Antonio, Impact to the Texas Economy, 2018”, CHA 2020 From these job numbers and other input, an economic impact modeling system (REMI) was used to determine the total economic impacts of PSA. The Comptroller estimated that PSA

6 Texas Comptroller Report: “Port San Antonio, Impact to the Texas Economy, 2018”

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contributed $5.6 billion ($5,624,922,000) to the Texas economy and supported some 32,000 jobs in 2018. It is against this economic backdrop that the estimate of economic value of Kelly Field was developed. 5.2 ECONOMIC IMPACT ANALYSIS METHODOLOGY Economic impact analysis is the process of quantifying the economic contributions of any specific activity under study. End products of these analyses are described in terms of jobs, income, and total economic output in dollars. The economic impact analysis of Kelly Field provides stakeholders with evidence of the value of the airfield component of PSA and the aeronautical military mission value to the MSA. Several variables help explain the overall economic impact of the study area. For example, regional multipliers quantify how direct expenditures (employee salaries and capital expenses) further impact the local economy. As an example, if a new firm comes into an area and employs 50 people and also purchases some local goods and services, economic studies show that the impacts in the area will be attributable to the company's direct dollar output plus the re-spending of these outputs resulting in ripple effects of the dollar spending and re-distribution. There will be two types of ripple effects: (1) those associated with company-to-company transactions and (2) those derived from the wages and salaries allocated to employees in these companies. The wages and salaries paid to the 50 new employees will be spent and re-spent several times within the community. Retail establishments that no direct association with the nature of the new firm's business will be affected by its presence as the new employees spend their income on clothes, automobiles, restaurant meals and so forth. Thus, for every dollar of new wages and salaries, an additional twenty-five to seventy-five cents of income might be generated elsewhere in the area. As supplier firms providing inputs to the new firm expand their production and thus allocate more resources to wages and salaries, a further consumption- generated ripple effect will be observed. Economic Impact Fundamentals: Direct, Indirect, and Induced Impacts

Source: Caplink.org, 2021

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When all the effects are summed up, a new job can often generate the equivalent of another job (summed up over many partial jobs in different parts of the area's economy) if the region is large and has a sophisticated consumer retail base. For this analysis, the San Antonio-New Braunfels MSA was used as the region in which the multiplier effects were measured. Ripple or multiplier effects work in both a positive (when a new airport enters or an existing airport expands) and in a negative manner (when an enterprise goes out of business or an airport closes). 5.2.1 IMPLAN Modeling IMPLAN Inputs and Outputs Impact Analysis for Planning (“IMPLAN”), developed originally by the U.S. Forest Service, is a comprehensive impact system that is built on the framework of input-output and social accounting methodology. The database is maintained at the county level, affording the analyst an opportunity to create regions for study that are aggregations of counties. The database includes the latest business censuses supplemented by County Business Patterns and other data derived from the U.S. Bureau of Economic Analysis. The input-output and social accounting models are derived from national data with adjustments made to reflect regional specialization, size, and industrial composition. The procedures used to accomplish this are well known and accepted in the literature on non- survey techniques. Since IMPLAN provides a comprehensive system (i.e., the complete Source: IMPLAN, 2020 input-output table or social accounts), it is possible to trace impacts of change in one sector on other sectors in a detailed fashion. The ability to edit data makes IMPLAN a dynamic economic modeling tool. Software users have the ability to edit all underlying data, from value added, employment, and final demands to production functions, byproducts, and regional purchase coefficients - and many other components. Outputs from the analysis include: Direct Spending: Includes on-airport spending on employment, operations, and capital projects related to the airfield and businesses/organizations that use the airfield. It also includes off-airport spending by local military personnel that may be shipped to Luke AFB for training if Kelly Field closes for repair. Thus, direct spending is associated with both the providers and the users of airfield services. Induced Benefits: Includes impacts above the original direct spending created by the successive rounds of spending in the San Antonio-New Braunfels MSA economy until the original direct impact has been incrementally exported from the local area.

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Jobs and Income: This measure quantifies the income generated by aviation and the number of jobs supported by Kelly Field and its runway access. Total Output in Dollars: Includes the combined impacts of direct and induced spending. Taxes: This measure quantifies the tax revenue contribution of business and military activity related to Kelly Field to local and State units of government in Texas. 5.3 ECONOMIC IMPACT VALUE OF KELLY FIELD The economic impact of Kelly Field was measured to determine the annual value that it contributes to the local and regional economy. For this analysis, only those business and military missions relying on the airfield were counted toward the Direct annual economic value; Direct impacts are detailed in Section 5.2. One way of analyzing this was to develop a scenario where the airfield is assumed to be shut down for specified durations of time for repair. Companies that use the airfield for their routine business operations, along with the active military aviation operations would be impacted by a runway closure. 5.3.1 Economic Impact Components The first major component in estimating the economic impact of Kelly Field is to collect all the input data needed for the IMPLAN modeling, as described below and detailed in Table 5-2. Employment & Payroll: Jobs and associated payroll related directly to the presence of an airfield at PSA. Capital Spending: Includes capital maintenance and average spending on capital development for aviation-related companies and portions of the local military operation. Employment & Payroll To collect airfield-related employment and payroll at Kelly Field, on-airport businesses and military missions that require airfield access were identified and interviewed. The aircraft manufacturing industry at Kelly Field is almost completely dependent on the airfield to provide access to jets needing maintenance or overhaul. Similarly, aviation fuel sales, flight training, air cargo, and aircraft storage require aeronautical access. In total, 5,829 direct jobs are reliant on access to the runway at Kelly Field and provide over $612 million in payroll. In addition to these direct jobs, there are other jobs that result from capital spending at Kelly Field. These direct jobs are estimated by IMPLAN to include an additional 333 jobs, for a grand total of 6,162 direct jobs. Capital Spending Since its inception in 1998, public and private-sector partners have invested more than $800 million in the redevelopment of the PSA campus. PSA has grown significantly in recent years. In 2018, projects totaled $49 million in investment. In 2019 through August, capital investments totaled $55 million.7 On average, total investment at PSA has been about $40 million per year.

7 Source: Texas Comptroller Report, 2018.

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For purposes of this analysis, only the capital spending by activities dependent on the airfield was identified. Phone interviews with the various companies impacted by a possible runway closure yielded an estimate of average annual capital spending at $13.3 million per year. It is assumed that this historic average capital investment will continue into the future. Table 5-2 – Kelly Field Economic Impact Components KELLY FIELD COMPONENT NUMBER OF JOBS PAYROLL CAPITAL SPENDING PSA 2,527 $260M+ $1.9B+ JBSA 3,302 $352M+ $435M+ IMPLAN ESTIMATED 333 - - ADDITIONAL TOTALS 6,162 $612M+ $2B+ Source: Wiedemann & Associates, CHA, 2020 5.4 APPLICATION TO KELLY FIELD The final step in the analytical process of regional economic impact analysis is the estimation of the induced or multiplied effects of Kelly Field’s direct and indirect aviation impacts. Using the IMPLAN software, multiplier tables were generated for the San Antonio-New Braunfels MSA for all the potential impacted industries. Results and data from the estimation of direct and indirect impacts were applied to the appropriate multiplier process and the results were summed to obtain output and employment totals reliant on aviation activity at PSA. This section provides a summary of Kelly Field’s direct and induced economic impacts. This documentation is the culmination of work involving the survey data, the secondary source data, and the IMPLAN multipliers in determining the economic impact of Kelly Field. The economic impact methodology first identified the direct spending and employment at Kelly Field for both military and civilian activities. Armed with this information, regional re-spending multipliers derived from IMPLAN were applied to the data to determine the multiplied impacts of direct spending (called induced impacts). Table 5-3 presents a summary of Kelly Field’s direct and induced economic impacts.

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Table 5-3 – Direct and Induced Economic Impacts of Kelly Field ITEM AMOUNT Direct Impacts Airport-related Income for Businesses $259,683,600 Airport-related Income for Military $352,010,100 Total Airport-related Income $611,693,700 On-Airport Expenditures for Businesses (including capital costs) $1,892,437,200 On-Airport Expenditures for Military (including capital costs) $435,768,400 Total On-Airport Expenditures $2,328,205,600 Airport-related Employment for Businesses 2,624 Jobs Airport-related Employment for Military 3,538 Jobs Airport-related Employment (Total) 6,162 Jobs Induced Impacts Induced Direct Impacts for Businesses $533,410,200 Induced Direct Impacts for Military $297,098,600 Total Induced Direct Impacts $830,508,800 Total Induced Employment Impacts for Businesses 3,129 Jobs Total Induced Employment Impacts for Military 2,040 Jobs Total Induced Employment Impacts 5,169 Jobs Grand Total Dollar Impacts $3,158,714,400 Grand Total Income Impacts $873,595,700 Grand Total Employment Impacts 11,330 Jobs Grand Total State/Local Tax Impacts $49,540,400 Source: Wiedemann & Associates, CHA, 2020 As shown, Kelly Field supports 11,330 jobs and approximately $3.16 billion in annual economic impact. The runway-dependent businesses and military functions generate $49.5 million in State and local taxes and provide incomes of approximately $873.6 million to Texas residents. Appendix A presents a detailed summary of the IMPLAN economic impact re-spending process, by economic sector. Appendix A presents a detailed summary of the IMPLAN economic impact re-spending process, by economic sector. 5.4.1 State and Local Tax Impacts When discussing economic impacts of Kelly Field, many people are interested in the collective tax benefits to the local municipalities and the State of Texas. In Texas, there are a variety of taxes paid by airport tenants and aviation users: Sales Tax Property Taxes Motor Vehicle License Tax Aviation Fuel Tax Payroll Taxes Other Miscellaneous Taxes All these tax impacts were estimated by the IMPLAN model for expenditures at the State and local level. As shown in Table 5-4, the estimated annual State and local tax impacts from aviation for Kelly Field total $49,540,400 (see Appendix A for details). This tax revenue benefits all citizens of the area, not just those in aviation.

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Table 5-4 – State and Local Tax Impacts TAX ENTITY AMOUNT OF TAXES Sub-County General Taxes $6,090,200 Sub-County Special Districts Taxes $13,534,600 County Taxes $4,984,900 State Taxes $24,930,700 TOTAL TAXES $49,540,400 Source: Wiedemann & Associates, CHA, 2020 5.4.2 Upstream Economic Connections Although the purpose of this economic evaluation was to focus on Kelly Field, the economic activity at Kelly Field is not confined to PSA and JBSA-Lackland. Much of it starts elsewhere, as suppliers are tapped to provide the materials needed for final production at businesses on the airfield, and the upstream distribution of the economies associated with the airfield. Aerospace and Manufacturing are the largest industry components dependent on the runway at Kelly Field. For example, the aerospace economic footprints in Bexar County in 2020 were significant, expending more than $126 million with 66 suppliers in the County. In addition, the aerospace industry at Kelly Field expended more than $30 million with on-site providers of parts and labor. This impact, along with employment of more than 2,300 indicates the potential degree of disruption that could occur if the runway at Kelly Field was inaccessible. Economic Significance of Kelly Field in MSA With an economic impact of nearly $3.2 billion, Kelly Field is a highly significant component of San Antonio-New Braunfels MSA, relative to the total output for the region. The relationship between Kelly Field output and MSA output is illustrated below. Economics of Kelly Field and San Antonio-New Braunfels MSA

Source: Wiedemann & Associates CHA, 2020 To be more than 1 percent of the total MSA output shows the significance of the economic contributions represented by the civil and military components of Kelly Field. The fact that jobs are less than 1 percent of the MSA shows that they are productive jobs. That is, 0.77 percent of the total jobs within the MSA produce 1.29 percent of the total output. Another way of looking

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at this is to consider the average production of output per job in the MSA, which is $168,730. At Kelly Field, the average production is $278,800 per job – a 65 percent increase. IMPLAN Linkages Examination of the IMPLAN results shows that impacts from the economic activities at Kelly Field extend to 364 economic sectors (out of 546). That is, upstream and downstream linkages run throughout the San Antonio-New Braunfels MSA economy. The top ten sectors, based on economic output include the following in rank order: Aircraft Manufacturing Federal Government - Military Payroll Owner-Occupied Dwellings Aircraft Engine and Engine Parts Manufacturing Other Aircraft Parts and Auxiliary Equipment Manufacturing Wholesale Machinery Equipment and Supplies Other Real Estate Monetary Authorities and Depository Credit Intermediation Hospitals Insurance carriers, except direct life The influence of the aeronautical Kelly Field IMPLAN Linkages activity is evident in the ranking, with three of the top five sectors directly supporting the MRO work at Kelly Field. It should be noted that the Air Transportation (FBO, Charter/Flight School, Air Cargo) category ranked fourteenth overall. However, these are not the only Indirect Cluster Linkages Cluster analysis is a technique to group similar industries into clusters based on their respective economic observations. The endpoint of cluster analysis is a set of clusters, where each cluster is distinct from each other cluster, and the objects within Source: CHA, 2020 each cluster are broadly similar to each other. In other words, the economic contributions of Kelly Field provide upstream linkages to specific industry sectors, and those industry sectors or inherently connected to sets of sectors within a specific cluster. For example, the top three economic sectors of contribution for Kelly Field include; Aircraft Manufacturing, Aircraft Engine and Engine Parts Manufacturing, and other Aircraft Parts and

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Auxiliary Equipment Manufacturing. These top three sectors are indirectly linked upstream to a Cluster of Manufacturing and Aerospace and Defense. Additionally, as part of the Kelly Field operations and DoD functions, the airfield is indirectly connected to operations within the Medical and Disaster Response Industry including; the San Antonio Military Medical Center (SAMMC), American Red Cross, FEMA, and the San Antonio Military Health System (SAHMS). These linkages show an indirect connection with the Medical Industry. Below is a representation of some of the focal points that hold an upstream linkage to major industry sectors within the MSA and San Antonio Region. Upstream Economics Connected to Kelly Field

Source: CHA, 2020 The connections described here are all upstream linkages within the San Antonio-New Braunfels MSA. As previously discussed, the MSA Economic Impacts, which includes all of the upstream linkages to industry sectors from Kelly Field totals over $245 Billion annually, and of that Kelly field links to over $3 Billion on that impact. These upstream linkages form a significant component for Kelly Field and its importance to the local and regional community. In addition to relating employment linkages between industries, cluster analysis uses location quotients (LQ) to determine if geographic location of industries is higher or lower than average. An LQ of 1.0 means that a region and the nation are equally specialized in a particular industry. Therefore, cluster analysis seeks LQs of greater than 1.0 to provide significance to the cluster. In addition, certain clusters below the 75th percentile specialization are recognized in the cluster analysis because they are significant. In Bexar County, the Aerospace and Defense employment cluster is related to two other clusters – IT and Medical Devices. Although these linkages are indirect, they do “crosspollinate” and provide significance to the geolocation of the Military and Aerospace functions at Kelly Field. Direct employment of these linkages totaled 2,993 in 2017 – a number that has certainly risen since then. Because these clusters say something about the economic fabric of the region, it is important that they are associated with Kelly Field.

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In our phone survey, businesses noted informal linkages with the use of local hotels and restaurants for their transient customers and employees. In addition, parts and materials were purchased locally in the operation of their businesses. 5.4.3 Economic Impact from Runway Closure The second major component of the economic impact analysis is identifying the impact of closing the runway either on a temporary or permanent basis. This is to include both impacts to civilian operations directly and indirectly connected to the runway, as well as military organizations dependent on the runway to accomplish their respective mission. Runway Closure Costs for Businesses For the businesses that are dependent upon aviation activity and rely on access to Kelly Field, the closure of the runway would cost jobs, business activity, and potentially loss of missions. These losses would become permanent if the airfield were not reopened. Estimates of the value of this loss equate to the economic impact of the 2,557 direct civil jobs that are tied to the reliance of access to the runway at Kelly Field. The IMPLAN modeling estimates the annual impact of these jobs on the San Antonio-New Braunfels Metropolitan Statistical Area (MSA). As shown later in this report, there is roughly a $1.9 billion annual direct impact from these activities. Impacts from Permanent Runway Closure This does not include the induced impacts of this output from successive rounds of re- Loss of 2,557 Private Sector Jobs spending. and $1.9B Contribution to Greater San Runway Closure Costs for the Military Antonio Area In addition to these losses, the runway Loss of 764 Military Jobs closure could impact military jobs at Kelly Negative Impacts to 3,302 Military Jobs Field. On a temporary basis, there would be additional expense of deploying their Source: Wiedemann & Associates, CHA, 2020 aircraft and personnel to another USAF Base for training. Those additional costs have been estimated by the military and total $2,420,400 per month, or $29,044,800 per year. Some estimates show an 18-month repair period, which would push the costs to $45,567,200. In addition to these, there are an estimated 764 direct military jobs dependent upon the use of the runway that would be impacted by a temporary closure. These direct costs are estimated at $94,081,200 annually. However, there is a much larger impact if the runway is closed on a permanent basis. Discussions with military personnel indicated that up to 3,302 jobs would be impacted negatively if the airfield were not available. The direct costs associated with a permanent runway closure would be $435,768,400. These direct costs do not include the induced spending that would result from them. This larger impact was used in the analysis to ensure that the study presents the significance of Kelly Field to the economic vitality of PSA.

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5.5 ECONOMIC IMPACT ANALYSIS SUMMARY AND FINDINGS

The takeaway from the economic impact Summary of Kelly Field analysis of Kelly Field shows that there is Economic Impact Analysis significant economic dependence on the runway by businesses located within the PSA campus and the military flying missions of JBSA-Lackland. Interruption of access to the runway could have devastating economic impact consequences on a number of businesses located on the airfield, as well as the military missions. If, for example, the runway was to be unusable for an extended length of time, many companies which rely on air access for customers would have to relocate. Similarly, the dislocation of military training, aircraft maintenance, and other DOD priorities has a significant impact on the region. Source: Wiedemann & Associates, CHA, 2020. Any permanent closure of the runway would have large economic repercussions in the region. Our analysis identified total impacts of nearly $3.2 billion, supporting 11,300 jobs. This represents roughly 1.3 percent of local Gross Regional Product and almost 0.8 percent of total jobs in the metropolitan region. In addition, there is a vast array of upstream linkages that feed the operation of companies at Kelly Field. It was documented that in Bexar County alone, aerospace companies expended more than $126 million with 66 suppliers in the County. Interruptions in these supply chain links due to potential runway closure impact much more than just those companies on Kelly Field. Other linked industries such as IT and Medical Devices would be impacted as well. Not insignificant are the tax revenues that are generated by the economic activity that occurs at Kelly Field. In this regard, State and Local taxes total roughly $49.5 million annually. This does not include the $177.9 million in Federal taxes generated each year. Kelly Field is a significant infrastructure component of the overall economic fabric of the Greater San Antonio areas. its economic significance has been demonstrated in this analysis. It is hoped that decisions concerning the future of the runway and its long-term maintenance will consider these impacts in the analysis of potential alternative solutions.

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KELLY FIELD PLANNING AND DESIGN

6.1 AIRFIELD DESIGN STANDARDS The FAA establishes design and safety standards for airfield facilities, including but not limited to, dimensions, separation distances, protection zones, and clearance requirements. These standards vary according to an airport’s Runway Design Code (RDC)/Runway Reference Code (RRC) as defined in AC 150/5300-13A Airport Design (Section 3.5.1). The RDC for Kelly Field is D- VI-2400, as detailed in the Kelly Field Master and ALP (Section 3.2.2). The DOD establishes design and safety standards in UFC 3-260-01 Airfield and Heliport Planning and Design. 6.1.1 Airfield Capacity Airfield capacity refers to the maximum number of aircraft operations (takeoffs or landings) an airfield can accommodate in a specified amount of time. For airports such as Kelly Field, where capacity is not anticipated to be a constraining factor, the FAA recommends using the “long-range planning” methodology for calculating capacity. The common methodology for determining the long-range capacity is to calculate the airport’s Annual Service Volume (ASV). An Airport’s ASV is the estimate of the total number of aircraft operations an airfield can accommodate, based on runway layout, aircraft fleet mix, weather trends, and operational characteristics of the Airport. Further, using FAA guidance, the ASV for a single runway airport such as Kelly Field was calculated at over 200,000 annual operations. According to the Kelly Field Master Plan (Section 3.2.2), the total annual operations by 2035 is projected to be between 39,000 and 45,000 (depending on the growth scenario), representing 20 to 23 percent of the estimated airfield capacity. Based on this evaluation, overall airfield capacity is not anticipated to be a concern over the 20-year planning horizon for this Comprehensive Plan. 6.1.2 Runway Length Minimum runway lengths are required for varying aircraft, payload weights, and destination lengths for both civilian and military aircraft. Minimum runway lengths for Kelly Field are primarily driven by the requirements for the Predictable Landing Surface Strategy (PLSS) as the existing Runway 16-34 is planned to remain the same in the 20-year planning horizon, as further described in Section 7.3. The Kelly Field Alternative Landing Surface Analysis, Part II (Section 3.2.5) determined that an ALS with an 8,000-foot runway would be adequate for all Group D-VI civilian operations (the critical aircraft at SKF) and for all F-16 and most C-5M military operations, as long as the north and south arm/de-arm aprons on Taxiway B and F are kept operational. Based on further discussions between PSA and JBSA, a it was determined that 9,600 feet would be required to accommodate all C-5M operations, including no flap landing training, as further described in Section 7.3. 6.1.3 Runway Width Minimum runway widths are based on an airport’s RDC and approach visibility minimums in order to provide adequate pavement and safety clearance for aircraft maneuvers. 6.1.4 Taxiway Design Standards Taxiway design standards include requirements for pavement width, shoulder width, taxiway separation, fillet design, and safety and object free area dimensions.

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6.1.5 NAVAIDs and Approach Category A runway’s approach capability is predicated on the type of approach NAVAIDs and lighting with which it is equipped, and the approach procedure minimums established by the FAA. Both ends of the existing Runway 16-34 are capable of instrument approaches and provide an ILS, including a 2,400-foot High Intensity Approach Lighting System with centerline sequenced flashers (ALSF- 1), which support approach minimums with a 200-foot decision height (i.e. cloud ceiling) and ½- mile visibility. Similar to runway length, NAVAIDs and approach category considerations are primarily driven by the requirements for the PLSS, as the existing Runway 16-34 is planned to remain the same in the 20-year planning horizon, as described in Section 7.3. Since the Alternative Landing Surface is to serve as a back-up runway to existing Runway 16-34, NAVAIDs and approach category for the PLSS should be identical. 6.2 ENVIRONMENTAL AND BUILT CONSIDERATIONS 6.2.1 Floodplains Leon Creek runs through JBSA-Lackland and a portion of PSA property. The creek has been prone to flooding, which has been an issue for the aircraft engine test cells on the southernmost tip of PSA, alongside SW Military Drive. The test cells—among only a handful of such facilities in the country—are essential to certification of engine specifications after work is conducted by StandardAero. In recent years, PSA has pursued a Leon Creek levee project to protect the test cells from future flooding. 6.2.2 Drainage On-site drainage has been an issue within PSA, especially north and east of the Jointly Used Flying Facilities, as determined in previous drainage studies. It was determined that most of the existing storm drain system (and surface channels) at the time did not have capacity to adequately contain a 50% (2-year) Annual Chance storm event. In order to address these concerns, PSA undertook a phased drainage mitigation plan that would ultimately convey flood waters to Leon Creek. The nearly mile-long drainage channel project is being built through the flood-prone areas. The infrastructure will increase safety for thousands of workers and reduce the risk of property damage and lost productivity as aerospace and other businesses continue to grow at PSA. These improvements are also important to mitigate flooding within the Boeing San Antonio facility and the southern end of Runway 16-34, which has had coverage of as much as 1,500 feet of runway surface in recent flood events, causing the airfield to close. Examples of recent flooding conditions on PSA property can be seen in Figure 6-1.

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Figure 6-1 – PSA Property Flooding Conditions

Source: Kelly Field Master Plan, 2019 6.2.3 Historic Places The PSA property contains two areas categorized as National Register of Historic Places Districts: the Kelly Field Historic District and the Bungalow Colony Historic District. The Kelly Field Historic District (Figure 6-2) is located adjacent to the airfield and consists of 39 variously purposed buildings. Built between 1940 and 1943, these buildings were constructed during the rapid expansion period leading up to World War II, and include the hangar used by President John F. Kennedy during his November 1963 visit to San Antonio. Of these 39 historic buildings, three are within Kelly Field’s USAF Exclusive Use Areas under leaseback from PSA: PSA Building 1601, 1603, and 1610. Figure 6-2 – Kelly Field Historic District at PSA

Source: PSA, Fly and Associates, 2015

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KELLY FIELD FUTURE CONDITIONS

This section of the Comprehensive Plan sets out the future conditions of Kelly Field with a 20- year planning horizon. It strives to reconcile and coordinate planned development between PSA and JBSA to ensure an efficient development of Kelly Field that meets the needs of all users. Future conditions are categorized by three timeframes of development: short-term within the next five years, mid-term within five to ten years, and long-term within ten to twenty years. However, this Comprehensive Plan provides the flexibility for development to be achieved earlier or later than prescribed based on financial availability, need, and preference of Field users. Moreover, the overall goal of the future conditions presented in this Comprehensive Plan is to establish attainable short-term development priorities that lay the foundation for the long-term development vision of Kelly Field in 20 years. 7.1 PORT SAN ANTONIO EXCLUSIVE USE AREAS With regard to the PSA Exclusive Use Areas defined in Section 4.1.1 and shown in Figure 4-4, planned landside development in the North Airfield is consistent with the PSA preferred development concept (Near-Term Concept 3) and Airport Capital Improvement Program (ACIP) presented in the Kelly Field Master Plan and ALP (Section 3.2.2) and shown in Figure 3-4 and excerpt below. However, development of the GA Terminal and Operations Facility and Cargo Building is excluded as this will be consistent with recommendations presented in the Consolidated Facilities Plan (Section 3.2.8). The Master Plan also includes three long-term development concepts for the North Airfield Flex Development Area, though a preferred concept was not selected in order to provide flexibility in the future. No new development is planned for the South Airfield as presented in the Master Plan and ALP (Section 3.2.2). Details of planned development are described below with implementation phasing described in Section 7.5. 7.1.1 North Airfield North Airfield Near-Term Concept 3 Near-Term Concept 3 (PSA Kelly Field Master Plan) Construct a ±100,000 SF manufacturing/assembly facility with surface parking in the undeveloped land between buildings #607 and 1420. Demolish building #1420 and replace with a ±100,000 SF manufacturing/assembly facility with surface paring. Expand the GA apron fronting the two new ±100,000 SF manufacturing/assembly facilities and building #1410. Source: Kelly Field Master Plan, 2019

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Demolish buildings #1425, 1426, 1427, 1428, 1438, and 1440 and replace with two ±115,000 SF manufacturing/assembly facilities with surface parking. Construct four ±50,000 SF specialized MRO facility hangars with surface parking in the undeveloped land between the demolished building #1428 and building #1470 (FIS and Multi-Use Cargo Facility). Expand/rehabilitate the GA apron fronting the three northern specialized MRO facility hangars. The site of the previously planned multi-purpose facility will be reserved for future aeronautical development. Demolish building #1470 (FIS and Multi-Use Cargo Facility) and construct two ±15,000 SF GA hangars with surface parking. Expand/rehabilitate the GA apron fronting the two new GA hangars. Consolidated Facilities (Figure 7-1) Figure 7-1 – Layout of Consolidated Construct a ±14,000 SF consolidated Facilities facilities complex, ±40,000 SF hangar, and surface parking with approximately 88 spaces to serve the FBO, U.S. Customs & Border Control FIS for passenger and cargo inspections, and PSA operations. Construct a ±400,000 SF GA apron that can accommodate 16 tie-down parking spaces and six larger aircraft parking adjacent to the hangar. Access to the GA apron is to be provided from an ADG-III connector taxiway that can accommodate aircraft with Source: Consolidated Facilities, 2020/2021 wingspans up to 118 feet. Conceptual Rendering of Consolidated Facilities

Source: SEI Design Group, CHA, 2019.

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ACIP (PSA Kelly Field Master Plan) Construct new and additional security/perimeter fencing in proximity of the eastern edge of the North Airfield extending from building #1410 to the intersection of the Mid-Airfield and Billy Mitchell Boulevard. Widen the eastern taxiway A connector fillets in order to meet edge safety margin requirements for ADG-VI aircraft with wingspans up to 262 feet. Rehabilitate apron with the replacement of ±230,000 linear feet of joint sealant and ±40 concrete panels. Improvements to Kelly Field Drainage project Improvements to Hangar 1425. Flex Dev Area Long-Term Concept 1 7.1.2 North Airfield Flex Development Area Long-Term Concepts 1 and 3 (PSA Kelly Field Master Plan) Construct two ±250,000 SF non-aviation customer facilities with surface parking and truck access in the undeveloped land between building #1530, SW 36th Street, and Sam Houston Road. Construct an ADG-VI taxilane between the two new ±115,000 SF manufacturing/assembly facilities and four new ±50,000 SF specialized MRO facility hangars described in the North Airfield in order to provide access to future aviation development outside of the scope of this Comprehensive Plan. Source: Kelly Field Master Plan, 2019 Long-Term Concept 2 (PSA Kelly Field Master Plan) Construct a ±1M SF non-aviation customer facility with Flex Dev Area Long-Term surface parking and truck access in the undeveloped land Concept 2 between building #1530 and SW 36th Street extending southward between Sam Houston Road and Davy Crockett Road partially outside of the scope of this Comprehensive Plan. Construct an ADG-VI taxilane that can accommodate aircraft with wingspans up to 262 feet between the two new ±115,000 SF manufacturing/assembly facilities and four new ±50,000 SF specialized MRO facility hangars described in the North Airfield in order to provide access to future aviation development outside of the scope of this Comprehensive Plan. Source: Kelly Field Master Plan, 2019

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7.2 U.S. AIR FORCE EXCLUSIVE USE AREAS Planned development in the USAF Exclusive Use Areas, including the Kelly Field District and PSA Leaseback District, is consistent with their ADPs described in Section 3.1.2 and Section 3.1.3, respectively. Due to the Kelly Field District ADP and PSA Leaseback District ADP being designated as FOUO, only an overview of planned development is provided herein. As a reminder, future development recommended in this Comprehensive Plan has been evaluated for conflict compatibility concerning development outlined in these ADPs. 7.2.1 Kelly Field District The Kelly Field District ADP encompasses all of the required infrastructure and program needs for JBSA and its mission partners within the Kelly Field District over the next 20 years; however, as noted in the ADP, it is a snapshot in time which may need to be adapted in the future to allow the Kelly Field District to achieve its vision. The ADP strives to optimize mission operations, eliminate current deficiencies, address the physical location of new facilities and functions, and address the integration with other supporting or limiting elements within the Kelly Field District and throughout JBSA. The Kelly Field District is characterized by three campuses: the 433rd AW Campus, 149th FW Campus, and Go West Campus. The ADP notes that although the majority of the future development within each campus was proposed by their respective organizations, they are not necessarily the proponents of all projects within the campus. 433rd AW and 149th FW Campuses Future development of the 433rd AW and 149th FW Campuses include 45 and 32 projects, respectively, ranging in size and complexity, broadly including:

Demolishing and replacing, renovating, and/or constructing new buildings and facilities Improving, reorganizing, and/or constructing new airfield infrastructure, such as aprons and taxiways Improving vehicular and pedestrian circulation Providing undeveloped areas for future development as needed

Go West Campus Future development in the Go West Campus, including 18 projects, is dependent on land acquisition in order to facilitate the relocation and/or expansion of missions, facilities, and airfield infrastructure. The Go West Campus is envisioned to relocate the Growdon Gate to serve as an anti-terrorism/force protection (AT/FP)-compliant access control point with commercial vehicle inspections. 7.2.2 PSA Leaseback District The PSA Leaseback District ADP is characterized by four groupings of leased buildings and land from PSA for the exclusive use of JBSA and its mission partners; however, the only grouping applicable to this Comprehensive Plan is “Kelly Downtown.” Only five buildings within the “Kelly Downtown” component are within the defined limits of Kelly Field. In this regard, future development is envisioned to be consistent with existing conditions, though the function and use may change or be consolidated over time as needed.

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7.3 JOINTLY USED FLYING FACILITIES 7.3.1 Air Traffic Control Tower Figure 7-2 – Relocated Kelly Field ATCT The existing ATCT will be relocated approximately - 125 feet to the northwest as recommended and approved in the 2017 memorandum “Siting Approval for Project KELL123018 ATCT” by 502nd ABW Commander Brig. Gen. Pringle (Figure 7-2). The new relocated ATCT will meet size and height requirements, as well as resolve safety deficiencies found at the current ATCT. The ATCT and air traffic services will continue to be operated by the USAF, including all ground and air movements of both military and civil aircraft in the controlled movement areas of Kelly Field. Implementation of the relocated Source: Siting Approval for Project KELL123018 ATCT is described in Section 7.5. ATCT, 2017 7.3.2 Aircraft Rescue and Fire Fighting The ARFF facility will remain in its existing location within the Kelly Field District just north of Taxiway G. 7.3.3 Runway The existing Runway 16-34 will remain in its current northwest/southeast orientation, remain 11,550 feet long and 300 feet wide, striped for 150 foot width aircraft operations, and retain blast pads on each end. While the critical aircraft for Kelly Field is not envisioned to change in the 20- year planning horizon, runway striping may be widened to accommodate larger, wider military aircraft (e.g., Boeing B-52 Stratofortress). Additionally, the 700-foot overrun beyond the Runway 16 end blast pad will be paved and extended by 300 feet, as recommended in the Kelly Field District ADP (Section 3.1.2). If a PLSS is pursued and implemented (Section 7.3.4), then existing Runway 16-34 will be marked as either Runway 16R-34L or Runway 16L-34R depending on whether the PLSS is located to the east or west. 7.3.4 Predictable Landing Surface Strategy The intent of the PLSS is to ensure that all Kelly Field users have continuous access to an operational runway during times when existing Runway 16-34 is temporarily closed for maintenance or other reasons such as airfield incidents. To this end, the Alternative Landing Surface Analysis, Part II (Section 3.2.5) recommended a three-phased implementation of COA No. 4 to achieve a 11,500-foot PLSS. However, following the completion of the Alternative Landing Surface Analysis, Part II, PSA and JBSA continued discussions and determined that an 8,000-foot long by 200-foot wide PLSS would be adequate for all Group D-VI civilian operations (the critical aircraft at SKF) and for all F-16 and most C-5M military operations; a 9,600-foot long PLSS would be required to accommodate all C-5M operations, including no flap landing training. Moreover, in order to provide the greatest flexibility for future development at Kelly Field that satisfies both PSA and JBSA needs, this Comprehensive Plan includes three airfield development scenarios with varying combinations of PLSS alternatives related to airfield infrastructure.

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The decision by PSA and JBSA officials to pursue any PLSS Alternative and corresponding Airfield Development Scenario will be based on financial feasibilities, mission support needs, and other considerations warranted at time of decision-making and implementation. In PLSS Alternatives 1-3, the PLSS will be marked as Runway 16L-34R, while in PLSS Alternative 4 the PLSS will be marked as Runway 16R-34L. In all airfield development scenarios, the PLSS will be developed to serve as a back-up runway to existing Runway 16-34. In this back-up role, the PLSS will not operate to address capacity reasons that may require simultaneous (independent) operation activity with existing Runway 16-34. Some non-simultaneous sequencing of activity on the runway and PLSS occur to enhance logistics and safety between military and civil aircraft movements in the controlled movement areas of Kelly Field, if stakeholders agree. Descriptions of the PLSS alternatives and airfield development scenarios are provided in Table 7-1 and Table 7-2, respectively. Graphics and conceptual renderings of PLSS Alternatives 1-4 are shown in Figure 7-3, Figure 7-4, Figure 7-5, and Figure 7-6, respectively. In order to aid decision makers in implementing the various airfield development scenarios, Figure 7-7 provides a decision matrix relative to the circumstances surrounding existing Runway 16-34 temporary closures, as well as funding and appetite to develop a PLSS at the time of decision. Lastly, implementation of the airfield development scenarios is discussed in Section 7.5 and a compatibility analysis is provided in Section 8. As discussed in Section 7.5 regarding implementation, PLSS Alternative 1 is the only alternative with an implementation timeline within the next five years. As such, at the time of publication of this Comprehensive Plan, PSA is conducting an Environmental Assessment in compliance with Federal National Environmental Protection Act (NEPA) protocols to determine environmental impacts related to the development of PLSS Alternative 1, including a noise impact analysis. This Comprehensive Plan does not contain an environmental impact analysis. Development of future PLSS Alternatives will require additional environmental impact analyses, which will be conducted at the time of their respective implementation.

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Table 7-1 – PLSS Alternatives PLSS ALTERNATIVE 1 ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4 ALTERNATIVE Non-Simultaneous Classification Temporary Runway ALS ALS Parallel Runway Length 8,380 feet 8,000 feet 8,000 feet 9,600 feet Width 150 feet 200 feet 200 feet 200 feet Approach Visual Non-Precision Precision Precision General East of Existing Runway East of Existing East of Existing West of Existing Location 16-34 Runway 16-34 Runway 16-34 Runway 16-34 Runway 16L-34R 16L-34R 16L-34R 16R-34L Identification Major Design Approx. 7,200 feet Follows PLSS Follows PLSS Follows PLSS Components of improvements to Alternative 1 Alternative 2 Alternative 1 Taxiway A, including New build ALS No change to Install ILS on 34 a 380-foot displaced between Taxiway new build ALS. end. threshold, and A/Temporary approx. 1,180 feet Install ILS on 34 Runway and of extension to end and adjust existing Runway Taxiway A. Taxiway A to 16-34. accommodate New hold Restore critical area. apron/runup apron Temporary along Taxiway B Runway as New Taxiways M, taxiway only. M1, and A3 Source: CHA, 2020 Table 7-2 – Airfield Development Scenarios AIRFIELD DEVELOPMENT SCENARIO 1 SCENARIO 2 SCENARIO 3 SCENARIO

PLSS 1. PLSS Alternative 1 1. PLSS Alternative 1 Alternatives 1. PLSS Alternative 1 2. PLSS Alternative 2 2. Full Reconstruction of and Order of 2. PLSS Alternative 4 Development 3. PLSS Alternative 3 Existing Runway 16-34 Narrative Develop a Temporary Develop a Temporary Develop a Temporary Runway Runway to safeguard against Runway to safeguard to safeguard against unplanned unplanned closures, then against unplanned closures, closures, then develop a ALS develop a non-simultaneous then fully reconstruct over two phases to satisfy the parallel runway to satisfy the existing Runway 16-34 to 20-year planning horizon for 20-year planning horizon for increase its lifespan and Kelly Field, that accommodates Kelly Field that remove near-future most airfield operations. accommodates all airfield temporary closures. operations. Source: CHA, 2020

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Figure 7-3 – PLSS Alternative 1

Source: CHA, Google Earth, 2020 Figure 7-4 – PLSS Alternative 2

Source: CHA, Google Earth, 2020

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Figure 7-5 – PLSS Alternative 3

Source: CHA, Google Earth, 2020 Figure 7-6 – PLSS Alternative 4

Source: CHA, Google Earth, 2020

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Figure 7-7 – Airfield Development Scenario Decision Matrix

Source: CHA, 2020 7.3.5 Taxiway System The existing taxiway system will remain intact until implementation of PLSS Alternative 1 that improves and extends Taxiway A to serve as a temporary runway, creates new Taxiway M, and provides new Taxiway A3 connector beyond the 380-foot displaced threshold. Four temporary painted islands will be activated to eliminate direct apron access from the temporary runway, as shown in Figure 7-3. If the Consolidated Facilities described in Section 7.1.1 is concurrently implemented with PLSS Alternative 1, then a dedicated taxiway to the Consolidated Facilities will be provided via new Taxiway M1. When the temporary runway (Taxiway A) is not in use, Taxiway A will continue to serve as a parallel taxiway to existing Runway 16-34. Upon implementation of PLSS Alternative 4, the temporary runway (Taxiway A) will be restored back to a taxiway only. If PLSS Alternative 3 is pursued following PLSS Alternative 2, a portion of Taxiway A will be removed and shifted to the east to avoid interference with the critical area associated with the ILS glide slope for the ALS. Figure 7-8 illustrates the taxiway system progression between PLSS Alternatives 1-3.

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Figure 7-8 – Taxiway System for PLSS Alternatives 1-3

Source: CHA, Google Earth, 2020 7.3.6 Navigational Aids and Instrument Approach Procedures Existing NAVAIDs and instrument approach procedures for Runway 16-34 will remain the same until implementation of a PLSS. All PLSS Alternatives will require the relocation of the TACAN; however, new NAVAIDs and instrument approach procedures for the chosen PLSS will be determined at the time of implementation depending on the selected airfield development scenario. 7.3.7 Approach and Airfield Lighting Existing approach and field lighting for Runway 16-34 will remain the same until implementation of a PLSS, which will require approach and airfield lighting that will be determined at the time of implementation depending on the selected airfield development scenario. 7.4 POTENTIAL KELLY FIELD EXPANSION AREAS Opportunities exist for Kelly Field to expand its geographic footprint through two potential expansion areas, as shown in Figure 7-9 and discussed below. These potential expansion areas are considered compatible with the existing planning context established by PSA, JBSA, and San

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Antonio; however, further compatibility analyses should be conducted once definitive functions and activities are proposed by their respective users. Figure 7-9 – Potential Expansion Areas at Kelly Field

Source: CHA, Google Earth, 2020 7.4.1 PSA Parcels within the potential expansion area for growth are owned by numerous private landowners and contain both residential and vacant land uses. Acquiring and incorporating these lands into Kelly Field could provide additional opportunities for aeronautical uses aligned with this Comprehensive Plan, including the Consolidated Facilities described in Section 7.1.1, as well as protecting Kelly Field’s airspace by ensuring compatible land uses in the future between the airfield and U.S. Route 90. 7.4.2 JBSA Adjacent to JBSA is a large tract of land identified as a potential expansion area for Kelly Field. Parcels within this tract of land are owned by private landowners and the City of San Antonio, and are currently used for commercial or industrial activities with some vacant parcels. If incorporated into Kelly Field, this tract of land could provide JBSA with additional opportunities for mission and/or aeronautical expansion aligned with the Kelly Field District ADP (Section 3.1.2). Parcels owned by San Antonio present opportunities for JBSA to pursue land swaps and/or grants in order to acquire land, while parcels owned by private landowners will likely rely upon fee simple purchase for acquisition. 7.5 IMPLEMENTATION Implementation of Kelly Field’s future conditions identified in this Comprehensive Plan are broadly outlined in the proceeding tables. Table 7-3 details projects to be implemented within the next five years representing the most critical short-term needs at Kelly Field, such as PLSS Alternative 1 (Temporary Runway). Table 7-4 details projects to be implemented after the most critical short-term needs but within a tangible 10 years to satisfy mid-term goals at Kelly Field. Table 7-5 details long-term projects envisioned to be implemented within the 20-year planning

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horizon of this Comprehensive Plan to achieve the full vision of Kelly Field. These tables include timing of the implementation, responsible party, estimated cost, and potential funding source, where available. However, many project details and their associated costs are deferred to their respective planning document to reduce redundancy or are unknown at this time and will be determined at the time of an implementation strategy. Table 7-3 – Short-Term Development Implementation (Year 0 to 5) RESPONSIBLE ESTIMATED POTENTIAL FUNDING PROJECT PARTY COST SOURCE PLSS Alternative 1 (All Airfield Development FAA, PSA, State, San PSA TBD Scenarios) Antonio Kelly Field Master Plan CIP Excluding the GA Terminal and See Kelly Field FAA, TxDOT, PSA Operations Facility & Cargo Building (part Master Plan San Antonio of the Consolidated Facilities) Consolidated Facilities Land needs include 7 residential parcels PSA TBD FAA, PSA, TxDOT and 3 commercial parcels JBSA Kelly Field District ADP JBSA See ADP JBSA JBSA PSA Leaseback ADP JBSA See ADP JBSA JBSA, Potential Expansion, JBSA $1.2M8 + Cost of Land Swap/Grant 4 parcels owned by private landowners JBSA San Antonio (as parcels are 7 parcels owned by San Antonio Parcels available for acquisition) Source: CHA, 2020

8 Bexar County Appraisal District, 2019 Parcels. Provided April 27, 2020 for informational purposes only.

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Table 7-4 – Mid-Term Development Implementation (Year 6 to 10) RESPONSIBLE ESTIMATED POTENTIAL FUNDING PROJECT PARTY COST SOURCE PLSS Alternative 2 or 4, or Full Reconstruction of Existing Runway 16-34 (Depending on PSA TBD PSA, JBSA, FAA Airfield Development Scenario 1-3) See Kelly Field FAA, TxDOT, PSA Kelly Field Master Plan CIP Master Plan San Antonio

JBSA Kelly Field District ADP JBSA See ADP JBSA JBSA PSA Leaseback ADP JBSA See ADP JBSA JBSA, Potential Expansion, JBSA $1.2M + Cost of Land Swap/Grant 4 parcels owned by private landowners JBSA San Antonio (as parcels are 7 parcels owned by San Antonio Parcels available for acquisition) Source: CHA, 2020 Table 7-5 – Long-Term Development Implementation (Year 11 to 20) RESPONSIBLE ESTIMATED POTENTIAL FUNDING PROJECT PARTY COST SOURCE PLSS Alternative 3 (Depending on Airfield PSA TBD PSA Development Scenario 1) See Kelly Field FAA, TxDOT, Kelly Field Master Plan CIP PSA Master Plan San Antonio JBSA Kelly Field District ADP JBSA See ADP JBSA JBSA PSA Leaseback ADP JBSA See ADP JBSA PSA, FAA, TxDOT, North Airfield Flex Development Area PSA TBD San Antonio JBSA, Potential Expansion, JBSA $1.2M + Cost of Land Swap/Grant 4 parcels owned by private landowners JBSA San Antonio (as parcels are 7 parcels owned by San Antonio Parcels available for acquisition) Source: CHA, 2020

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KELLY FIELD COMPATIBILITY ANALYSIS

A comprehensive compatibility analysis was conducted on the future conditions of Kelly Field presented in Chapter 7, including the criteria, standards, and recommendations detailed by the DOD, FAA, City of San Antonio, and numerous other adopted plans reviewed in Chapter 3. A review of the compatibility analysis is described in the proceeding sections. 8.1 AIRPORT DESIGN CRITERIA FOR PLSS DEVELOPMENT 8.1.1 UFC 3-260-01 Airfield and Heliport Planning and Design (DOD) UFC 3-260-01 prescribes a host of criteria for the development of DOD aviation facilities, including airfield design, imaginary surfaces, and clear zones. A summary of the applicable design criteria for the USAF Class B runways at Kelly Field is provided in Table 8-1 with a compatibility analysis provided below and shown in Figure 8-1, Figure 8-2, Figure 8-3 and Figure 8-4. Table 8-1 – UFC 3-260-01 Airfield Design Criteria (USAF Class B Runways) ITEM UFC DESIGN CRITERIA Runway Length Determined by Major Command (MAJCOM) Runway Width 150 feet Runway Centerline to Parallel Not established for non-simultaneous parallel runway operations. Runway Centerline Separation Runway Centerline to Parallel 1,000 feet Taxiway Edge Separation Primary Surface Width 2,000 feet wide centered on the runway centerline extending 200 feet beyond each runway end. Approach-Departure Surface Starting 200 feet from the runway end; 2,000 feet wide centered (Sloped Portion) on the extended runway centerline and expanding to 9,000 feet wide over a distance of 25,000 feet at a slope of 50:1. Note: These dimensions are based on the assumption that the runway end and established airfield elevation are the same, if they differ than additional criteria applies. Transitional Surface The area extending outward and upward at right angles to the runway centerline and the runway centerline extended at a slope ratio of 7:1 connecting the primary surface to the inner horizontal surface (150 feet above the established airfield elevation) or the approach-departure clearance surfaces, whichever occurs first. Clear Zones An area 3,000 feet square centered on the end of the runway. Source: DOD UFC 3-260-01, 2019 Airfield Design Runway Length Minimum runway lengths for USAF Class B runways are determined by MAJCOM. The minimum runway lengths determined for the C-5 and F-16 in operation at Kelly Field are 6,000 and 8,000 feet, respectively. In this respect, all PLSS Alternatives comply with UFC design criteria. Runway Width A minimum of 150 feet is required for USAF Class B runways widths. In this respect, all PLSS Alternatives comply with UFC design criteria.

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Runway to Parallel Runway Separation A minimum separation requirement is not established for non-simultaneous parallel runway operations for USAF runways. In this respect, all PLSS Alternatives comply with UFC design criteria as there will only be non-simultaneous operations with the existing Runway 16-34. Runway to Parallel Taxiway Edge Separation A minimum 1,000-foot separation between USAF Class B runway centerlines and parallel taxiway edges is required. In this respect, PLSS Alternatives 2 and 3 do not comply with UFC design criteria as only 414 feet is provided between the PLSS centerline and Taxiway A edge. However, PLSS Alternatives 1 and 4 do comply with UFC design criteria. Imaginary Surfaces Primary Surface The primary surface for USAF Class B runways requires an area to be clear of above-ground obstacles measuring 2,000 feet wide centered on the runway centerline by 200 feet beyond each runway end. In this respect, PLSS Alternative 1 and 4 do not comply with UFC design criteria as numerous existing buildings and smaller support structures are within the primary surface. However, PLSS Alternative 2 and 3 do comply with UFC design criteria. Compatibility resolutions to primary surface obstructions are discussed in Section 9.1. Approach-Departure Surface (Sloped Portion) The sloped portion of the approach-departure surface for USAF Class B runways requires a 50:1 clearance starting 200 feet from each runway end. In this respect, PLSS Alternatives 1-3 do not comply with UFC design criteria as existing buildings penetrate the approach-departure surface. However, PLSS Alternative 4 does comply with UFC design criteria as any existing building in the approach-departure surface would need to be acquired from private ownership for its development, which in turn would be removed. Compatibility resolutions to approach-departure surface penetrations are discussed in Section 9.1. An obstruction analysis that includes recent tree height data should also be conducted to verify that tree obstructions are not present. Transitional Surface The transitional surface for USAF Class B runways requires a 7:1 clearance in the area between the primary surface and 150 feet above the established airfield elevation or the point of intersection of the approach-departure surface and inner horizontal surface, whichever occurs first. In this respect, all PLSS Alternatives do not comply with UFC design criteria as penetrations from existing buildings exist. Compatibility resolutions to transitional surface penetrations are discussed in Section 9.1.. Clear Zones CZs for USAF runways require an area measured 3,000 feet square centered on each runway end to be clear of any development except for highway and street right-of-way and non-livestock agriculture uses. In this respect, PLSS Alternatives 1-3 do not comply with UFC design criteria as numerous existing buildings and smaller support structures are within the CZs. However, PLSS Alternative 4 does comply with UFC design criteria as any existing building in the CZ would need to be acquired from private ownership for its development, which in turn would be removed. Compatibility resolutions to clear zone obstructions are discussed in Section 9.1.

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Accident Potential Zones I and II APZs I for USAF Class B runways are beyond the CZs and measured 3,000 feet in width and 5,000 feet in length along the extended runway centerline. APZs II are beyond the APZ Is and measured 3,000 feet in width by 7,000 feet in length. Under authority of Air Force Instruction (AFI) 32-7063, guidance on land use guidelines are established for application in developing AICUZ Studies. Land uses beyond Kelly Field in the APZs I and II of existing Runway 16-34 include over an estimated 5,000 residents, numerous commercial and industrial employers, institutions such as schools and city services, and vacant or agricultural land. Implementation of any PLSS Alternative would expand the APZs I and II to the east or west, but would not likely introduce new land uses or additionally impact existing land uses; therefore, complies with UFC design criteria. Figure 8-1 – PLSS Alternative 1 Developed to UFC Design Criteria

Source: CHA, Google Earth, 2020 Figure 8-2 – PLSS Alternative 2 Developed to UFC Design Criteria

Source: CHA, Google Earth, 2020

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Figure 8-3 – PLSS Alternative 3 Developed to UFC Design Criteria

Source: CHA, Google Earth, 2020 Figure 8-4 – PLSS Alternative 4 Developed to UFC Design Criteria

Source: CHA, Google Earth, 2020 8.1.2 CFR Title 14, Part 77 (Civil) Part 77 prescribes a host of design criteria for a runway ends’ established approach type, either currently available or planned to be available, in order to determine obstructions to air navigation and communication facilities. Part 77 design criteria is provided in Table 8-2 with a compatibility analysis provided below and shown in Figure 8-6, Figure 8-7, Figure 8-7, and Figure 8-8.

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Table 8-2 – CFR Title, 14 Part 77 Design Criteria

A = Utility runways B = Runways larger than utility C = Visibility minimums greater than 3/4 mile D = Visibility minimums as low as 3/4 mile * = Precision instrument approach slope is 50:1 for inner 10,000 feet and 40:1 for an additional 40,000 feet Source: CFR Title 14, Part 77, 2010. Source: NOAA, date unknown Primary Surface The primary surface for visual runways requires an area to be clear of above-ground obstacles measuring 500 feet wide center on the runway centerline by 200 feet beyond each runway. In this respect, PLSS Alternative 1 complies with Part 77 design criteria. The primary surface for runways with a non-precision approach with minimums as low as 3/4 mile or a precision approach require an area to be clear of above-ground obstacles measuring 1,000 feet wide center on the runway centerline by 200 feet beyond each runway. In this respect, PLSS Alternatives 2-4 comply with Part 77 design criteria. Approach Surface The approach surface for visual runways larger than utility require a 20:1 clearance starting 200 feet from each runway with a beginning width of 500 feet and expanding to 1,500 feet over 5,000 feet. In this respect, PLSS Alternative 1 complies with Part 77 design criteria. However, an obstruction analysis that includes recent tree height data should also be conducted to verify that tree obstructions are not present.

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The approach surface for runways with a non-precision approach with minimums as low as 3/4 mile require a 34:1 clearance starting 200 feet from each runway with a beginning width of 1,000 feet and expanding to 4,000 feet over 10,000 feet. In this respect, PLSS Alternative 2 complies with Part 77 design criteria. However, an obstruction analysis that includes recent tree height data should also be conducted to verify that tree obstructions are not present. The approach surface for runways with a precision approach require a 50:1 clearance starting 200 feet from each runway with a beginning width of 1,000 feet and expanding to 4,000 feet over 10,000 feet, followed by a 40:1 clearance for an additional 40,000 feet widening to 16,000 feet. In this respect, PLSS Alternatives 3 and 4 comply with Part 77 design criteria. However, an obstruction analysis that includes recent tree height data should also be conducted to verify that tree obstructions are not present. Transitional Surface The transitional surface requires a 7:1 clearance in the area between the primary surface and the inner horizontal surface (150 feet above the established airfield elevation) or the point of intersection of the approach surface, whichever occurs first. In this respect, no PLSS Alternative complies with Part 77 design criteria as one or more buildings and/or support structures penetrate the transitional surface. Compatibility resolutions to transitional surface penetrations are discussed in Section 9.1. Figure 8-5 – PLSS Alternative 1 Developed to Part 77 Design Criteria

Source: CHA, Google Earth, 2020 Figure 8-6 – PLSS Alternative 2 Developed to Part 77 Design Criteria

Source: CHA, Google Earth, 2020

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Figure 8-7 – PLSS Alternative 3 Developed to Part 77 Design Criteria

Source: CHA, Google Earth, 2020 Figure 8-8 – PLSS Alternative 4 Developed to Part 77 Design Criteria

Source: CHA, Google Earth, 2020 8.1.3 Advisory Circular 150/5300-13A Airport Design (FAA) FAA AC 150/5300-13A prescribes a host of design criteria for the development of aviation facilities based on an airport’s established critical aircraft. FAA design criteria are typically less restrictive than Part 77 design criteria, therefore a comprehensive compatibly analysis is often deferred to Part 77 design criteria, as presented in Section 8.1.2. However, Part 77 does not prescribe standards regarding runway width, therefore, this is evaluated below. Runway Width Based on Kelly Field’s RDC of D-VI-2400 and visibility minimums detailed in the Kelly Field Master Plan and ALP (Section 3.2.2), a minimum runway width of 150 feet is required. In this respect, all PLSS Alternatives comply with FAA design criteria.

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8.1.4 Airport Design Criteria Compatibility Analysis Summary Table 8-3 – Compatibility Analysis Summary of PLSS Alternatives Developed to UFC Design Criteria (Military) PLSS ALTERNATIVES ALTERNATIVE 1 ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4

Runway Length COMPLIANT COMPLIANT COMPLIANT COMPLIANT

Runway Width COMPLIANT COMPLIANT COMPLIANT COMPLIANT Runway to Parallel COMPLIANT COMPLIANT COMPLIANT COMPLIANT Runway Separation Runway to Parallel AIRFIELDDESIGN COMPLIANT NON-COMPLIANT NON-COMPLIANT COMPLIANT Taxiway Separation

Primary Surface NON-COMPLIANT COMPLIANT COMPLIANT NON-COMPLIANT Transitional NON-COMPLIANT NON-COMPLIANT NON-COMPLIANT NON-COMPLIANT

Surface SURFACES

IMAGINARY IMAGINARY Approach Surface* NON-COMPLIANT NON-COMPLIANT NON-COMPLIANT COMPLIANT

Clear Zones NON-COMPLIANT NON-COMPLIANT NON-COMPLIANT COMPLIANT

CLEAR ZONES Source: CHA, 2020 * Based on desktop review using AGIS data obtained in 2018 with recommendation to obtain more recent tree height data to verify conclusions. Table 8-4 – Compatibility Analysis Summary of PLSS Alternatives Developed to FAA/Part 77 Design Criteria (Civil) PLSS ALTERNATIVES ALTERNATIVE 1 ALTERNATIVE 2 ALTERNATIVE 3 ALTERNATIVE 4

Runway Length COMPLIANT COMPLIANT COMPLIANT COMPLIANT

Runway Width COMPLIANT COMPLIANT COMPLIANT COMPLIANT Runway to Parallel COMPLIANT COMPLIANT COMPLIANT COMPLIANT Runway Separation Runway to Parallel AIRFIELDDESIGN COMPLIANT COMPLIANT COMPLIANT COMPLIANT Taxiway Separation

Primary Surface COMPLIANT COMPLIANT COMPLIANT COMPLIANT

Transitional Surface NON-COMPLIANT NON-COMPLIANT NON-COMPLIANT NON-COMPLIANT SURFACES

IMAGINARY IMAGINARY Approach Surface* COMPLIANT COMPLIANT COMPLIANT COMPLIANT Source: CHA, 2020 * Based on desktop review using AGIS data obtained in 2018 with recommendation to obtain more recent tree height data to verify conclusions.

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8.2 NOISE Development of a PLSS will create new noise contours that differ from those associated with existing Runway 16-34. The PLSS noise contours will be largely dependent on two factors: the implemented airfield development scenario and combination of Kelly Field users from JBSA and PSA. PLSS Alternative 1 will establish a temporary runway 1,075 feet to the east of existing Runway 16-34, while PLSS Alternatives 2 and 3 will establish an ALS only 575 feet to the east. PLSS Alternative 4 will establish a non-simultaneous parallel runway 575 feet to the west of existing Runway 16-34. The 2019 AICUZ Study (Section 3.1.1) established the Runway 16-34 noise contours and examined their compatibility with land uses in the surrounding community up to 65 decibel levels. In all airfield development scenarios, implementation of a PLSS to the east or west of exiting Runway 16-34 will not likely introduce new land uses or additionally impact existing land uses within the 65-decibel range. While this Comprehensive Plan does not include a noise impact analysis on any PLSS alternative, the EA mentioned in Section 7.3.4 will conduct a noise impact analysis on PLSS Alternative 1 in compliance with the NEPA process. Moreover, development of a PLSS is consistent with recommendations in the 2019 AICUZ Study concerning noise, however the next iteration of the AICUZ Study for Kelly Field should include and examine any implemented PLSS to ensure compatibility. The 2011 JLUS (Section 3.3.1) utilizes the AICUZ noise contours to establish a Noise MIA that reflects higher average aircraft noise exposure based on computer modeling that incorporates the frequency and type of aircraft operations. The extent of the Noise MIA is generally the same 65 decibel level range used in the AICUZ Study for analysis. Therefore, akin to the AICUZ noise compatibility analysis, expanding the noise contours to the east or west of existing Runway 16- 34 from development of a PLSS would not likely introduce new land uses or additionally impact existing land uses within the 65-decibel range and is consistent with recommendations in the 2011 JLUS concerning noise. 8.3 SAN ANTONIO UNIFIED DEVELOPMENT CODE, ZONING 8.3.1 Base Zoning The base zoning for the PSA and USAF Exclusive Use Areas is MI-2S, which is Mixed Heavy Industrial with an authorized specific use (Section 3.7.4). The MI-2 zone sets restrictions, standards, and guidelines on a myriad of development issues, including: Uses and conditions Blocks, lots, street, sidewalks, parking and loading design Parks and open space Building design and articulation Signs, buffers, natural resource protection, and performance standards Master Plan consistency

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Planned development in the PSA and USAF Exclusive Use Areas are consistent with the MI-2S base zoning, therefore no impacts are anticipated. Additionally, the planned Consolidated Facilities is consistent with the I-1 industrial base zoning regarding the parcels to be acquired. 8.3.2 AHOD The AHOD (Section 3.7.4) states no material change in the use of land and no structure or tree shall be erected, altered, planted or otherwise established at a height greater than 200 feet above the ground or penetrate a 100 to 1 (100:1) slope from the nearest point of the nearest runway of any airport unless a permit therefor shall have been applied for and granted. Additionally, height restrictions conform to DOD UFC and Part 77 criteria (Section 8.1.1 and 8.1.2, respectively) for imaginary surfaces and FAA flight procedures. Therefore, no planned structure or alteration of existing structure can be taller than 200 feet, penetrate these established imaginary surfaces, or cause an alteration to established FAA flight procedures, whichever occurs first. However, the FAA may permit and provide a variance in part of the Federal notification process required for proposed activities under Part 77 for these restrictions. Non-conforming uses and variances are permitted upon review by San Antonio. The AHOD also restricts land uses within its boundary, specifically: No use may create electrical or visual interference with any electric facility or instrumentation, wherever located within the AHOD. No use may make it difficult for flyers to distinguish between airport lights, result in in glare in the eyes of flyers using the airport, or impair visibility in the vicinity of the airport. No use may create bird strike hazards. No use may otherwise endanger the landing, taking-off, or maneuvering of aircraft. Planned development throughout Kelly Field (Chapter 7) is consistent with the AHOD zoning, therefore no impacts are anticipated. However, if any PLSS Alternative is implemented, San Antonio should review the AHOD boundaries to determine if adjustments are needed to ensure continued safety in proximity of Kelly Field. 8.3.3 MAOZ The MAOZ (Section 3.7.4) restricts land uses, building size and heights, visual and electrical interferences, and storage of flammables within MOAZ-1 and MOAZ-1, which are concurrent with the APZ Is and APZ IIs established in the 2019 AICUZ Study (Section 3.1.1) and discussed in Section 8.1.1. Implementation of the Phase I and Phase II/III PLSS would expand the MOAZ-1 and MOAZ- 2 to the east by 1,075 and 500 feet, respectively, which contains only a small portion of Kelly Field that does not have planned development (Chapter 7) and is consistent with the MOAZ, therefore no impacts are anticipated. Land uses beyond Kelly Field in the MOAZ-1 and MOAZ-2 of existing Runway 16-34 include over an estimated 5,000 residents, numerous commercial and industrial employers, institutions such as schools and city services, and vacant or agricultural land. Implementation of any PLSS Alternative would expand the MOAZ-1 and MOAZ-2 to the east or west, but would not likely introduce new land uses or additionally impact existing land uses. Therefore, if any PLSS

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Alternative is implemented, San Antonio should be updated the MOAZ boundaries and continue regulating future land uses to ensure compatibility. 8.3.4 MLOD The MLOD (Section 3.7.4) establishes lighting standards for two Military Lighting Regions (MRL): MRL-1 is any area three miles or less from an installation, and MRL-2 is any area greater than three miles and up to five miles from an installation. Moreover, only MRL-1 applies to this Comprehensive Plan, which includes the following applicable standards to Kelly Field: Restricted luminaire Backlight, Uplight, and Glare (BUG) ratings for those protruding light horizontally from or above its source, including only 50 lumens in the Uplight High (UH) and Uplight Low (UL) zones, 100 lumens total (less than a 25W incandescent lamp). No luminaire in a new development shall be aimed, directed, or focused so as to cause direct light toward an adjacent military base or installation. Maximum correlated color temperature of 3000K for all outdoor light sources. Additional standards apply for the following: o Commercial lighting o Non-residential uses o Parking lot and parking structure lighting o Outdoor sign lighting o Externally illuminated signs o Street lighting o Tower and structure lighting

Planned development throughout Kelly Field (Chapter 7) is consistent with the MLOD zoning, therefore no impacts are anticipated. 8.4 ADOPTED PLANS Implementation of any PLSS Alternative and other proposed facilities included in this Comprehensive Plan were reviewed against applicable adopted plans to ensure consistency and/or compatibility with their respective recommendations, guidelines, or standards. A summary of this analysis is provided in the proceeding sections. Consistent refers to the complete and full adoption of adopted plans; whereas, compatible refers to the less than complete and full adoption of adopted plans but nevertheless achieves its intentions without adverse effects. 8.4.1 JBSA-Lackland Kelly Field District ADP All development proposed in this Comprehensive Plan is anticipated to be consistent with recommendations in the JBSA-Lackland Kelly Field District ADP except implementation of a PLSS, as discussed below. PLSS Alternative 1 PLSS Alternative 1 (temporary runway), included in all airfield development scenarios, will require the creation of a new hold apron/runup apron along Taxiway B upon implementation. During times when existing Runway 16-34 is temporarily closed and the temporary runway is open,

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Taxiway D that provides connection from JBSA to PSA will also be closed and additional aircraft movements will be required. No other issues are anticipated, therefore, PLSS Alternative 1 is considered compatible with the JBSA-Lackland Kelly Field District ADP. PLSS Alternatives 2 and 3 PLSS Alternatives 2 and 3 (permanent PLSS east of existing Runway 16-34), included in airfield development scenario 1, will not introduce additional compatibility issues than those presented in PLSS Alternative 1. Therefore, PLSS Alternatives 2 and 3 are considered compatible with the JBSA-Lackland Kelly Field District ADP. PLSS Alternative 4 PLSS Alternative 4 (non-simultaneous parallel runway west of existing Runway 16-34), included in airfield development scenario 2, will have some compatibility issues with the JBSA-Lackland Kelly Field District ADP. The ADP outlines future military airfield development and improvements that would need to be adjusted in order to accommodate PLSS Alterative 4, including the relocation of planned taxiways, aprons, and buildings/structures. However, due to the ADP being designated as FOUO, specific compatibility issues cannot be presented herein. 8.4.2 JBSA-Lackland AICUZ Study The AICUZ Study recommends that noise zones, CZs, APZs, and other safety of flight concerns associated with military airfield operations be incorporated into local community planning programs in order to maintain the airfield’s operational requirements while minimizing the impact to residents in the surrounding community. In this regard, proposed facilities in this Comprehensive Plan is consistent with AICUZ recommendations. In regard to development of a PLSS, a compatibility analysis of the CZs/APZs and noise zones are presented in Section 8.1.1 and Section 8.2, respectively. 8.4.3 JBSA-Lackland PSA Leaseback District ADP All development proposed in this Comprehensive Plan, both military and civilian, is anticipated to be consistent with the recommendations in the JBSA-Lackland PSA Leaseback District ADP to retain the five Kelly Field PSA leaseback buildings, though their function and use may change or be consolidated over time as needed. 8.4.4 JBSA IFS All military development proposed in this Comprehensive Plan is anticipated to be consistent with the IFS required by JBSA and the USAF. 8.4.5 JBSA ICEMAP The Consolidated Facilities proposed in this Comprehensive Plan will require the acquisition of two to six parcels, depending on Growdon Rd. ingress/egress issue resolutions, that will expand the geographic boundary of PSA and aeronautical infrastructure and operations. Additionally, PLSS Alternative 4, if implemented, will require acquisition of numerous parcels and will expand the geographic boundary of JBSA and aeronautical infrastructure and operations. Both expansions are consistent with Action 11 for JBSA-Lackland that recommends executing the JBSA- Lackland land use management strategies outlined in its Compatible Land Use Strategy, including the acquisition of lands to protect the Kelly Field airspace and to ensure surrounding compatible

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land uses. Potential JBSA expansion areas identified in Section 7.4 should be further evaluated under Action 4 that recommends JBSA engage with San Antonio to explore the use of annexation and transfer of development rights to achieve surrounding compatible land uses. 8.4.6 JBSA BASH Plan All development proposed in this Comprehensive Plan, both military and civilian, is anticipated to be consistent with the recommendations and guidance prescribed in the JBSA BASH Plan to prevent and minimize wildlife hazards. 8.4.7 Kelly Field Master Plan and ALP This Comprehensive Plan recommends most of the proposed facilities and airfield components detailed in the Kelly Field Master Plan and ALP, except the location and design of the civil aviation terminal. The civil aviation terminal proposed in the Master Plan is located at the southern end of the North Airfield adjacent the USAF Exclusive Use Area, accessible from Frank Luke Dr. at the intersection of Billy Mitchell Blvd. The Master Plan proposed a ±35,000 SF building with surface parking and serve as a multi-purpose facility with the FIS and security center. However, the civil aviation terminal recommended in this Comprehensive Plan, referred to as the Consolidated Facilities (Section 3.2.8), will provide a ±14,000 SF multi-purpose complex at the northern end of the PSA North Airfield and Growdon Road with access from U.S. Highway 90. Akin to the Master Plan, the complex will serve the FBO, FIS for passenger and cargo inspections, and PSA operations. Additionally, a ±40,000 SF hangar and surface parking with approximately 88 spaces will be provided. The site of the previously planned multi-purpose facility will be reserved for future aeronautical development. Therefore, this Comprehensive Plan is not consistent but compatible with the Master Plan. The future conditions sheet of the ALP does not include any PLSS Alternative and other proposed facilities included in this Comprehensive Plan; however, it will be updated as part of this Comprehensive Plan to be consistent. 8.4.8 Kelly Field Alternative Landing Surface Analysis, Part II The long-term goal envisioned for Kelly Field in the Alternative Landing Surface Analysis, Part II included a 11,550-foot ALS; however, following additional discussions between PSA and JBSA, an 8,000-foot alternative was determined adequate for most military and all civilian users to maintain their operations, as presented in PLSS Alternatives 1-3 (Section 7.3.4). A 9,600-foot alternative is also presented in PLSS Alternative 4 that maintains all military user operations. While the design and phasing of an ALS has also changed, the intent of a PLSS to provide an alternate landing and departure surface for times when Runway 16-34 is not operational remains the same. Therefore, this Comprehensive Plan is not consistent but compatible with the Alternative Landing Surface Analysis, Part II. 8.4.9 2018 Kelly Field ATCT Siting Study The preferred 5A site for the relocated ATCT presented in the 2018 Kelly Field ATCT Siting Study was 80 feet northwest of the existing ATCT. However, the 2017 memorandum “Siting Approval for Project KELL123018 ATCT” recommended the ATCT be relocated approximately 125 feet northwest of the existing ATCT, which was approved by 502nd ABW Commander Brig. Gen. Pringle and carried forward in this Comprehensive Plan. Therefore, this Comprehensive Plan is consistent with the 2017 memorandum recommendations and compatible with the 2018 Kelly

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Field ATCT Siting Study recommendations, both of which resolve minimum size and height requirements, and safety deficiencies. 8.4.10 Coordination of Airport Roles All development proposed in this Comprehensive Plan, both military and civilian, is anticipated to be consistent and supportive of the roles and operations outlined in the Coordination of Airport Roles review by LeighFisher for San Antonio and PSA. 8.4.11 PSA Design and Development Standards Development of any proposed facility in this Comprehensive Plan that is located on PSA property will undergo a review of the PSA Design and Development Standards at the time of implementation. This Plan strives to be consistent and compatible with the design and development standards, but it does not provide engineering-grade plans required for review. 8.4.12 JBSA-Lackland JLUS The JLUS is centered on the compatibility analysis of three distinct geographies: the Air Safety MIA, Noise MIA, and Main Base AOC. The Air Safety MIA is based on the CZs and APZs defined in JBSA-Lackland AICUZ (Section 3.1.1); the Noise MIA are areas of higher average aircraft noise exposure based on computer modeling that incorporates the frequency and type of aircraft operations; the Main AOC is a 1,500 to 3,000-foot conceptual buffer around the perimeter of the main base intended to encompass property with direct adjacency and to reflect areas of potential security vulnerability. A compatibility analysis of the Main Base AOC is not warranted as the only civilian component in this Comprehensive Plan is the PSA Exclusive Use Area, which is beyond the 3,000-fooot conceptual buffer of the JBSA-Lackland Main Base. A compatibility analysis of the Air Safety MIA regarding development of a PLSS is presented in Section 8.1. with resolutions offered in Section 9.1. A compatibility analysis of the Noise MIA regarding development of a PLSS is presented in Section 8.2. 8.4.13 DOD Unified Facilities Criteria 3-260-01 Airfield and Heliport Planning and Design All development proposed in this Comprehensive Plan is consistent with UFC 3-260-01 except those noted otherwise in Section 8.1.1 regarding development of a PLSS. 8.4.14 FAA Advisory Circular 150/5300-13A Airport Design All development proposed in this Comprehensive Plan is consistent with AC 150/5300-13A except those noted otherwise in Section 8.1.3 regarding development of a PLSS. 8.4.15 San Antonio Approved Master Development Plan, PSA All civilian development proposed in this Comprehensive Plan is anticipated to be consistent with the MDA approved by San Antonio. However, in conjunction with the proposed PLSS and Consolidates Facilities beyond the current PSA boundary, it is recommended that PSA coordinate with the City of San Antonio to revise the PSA boundary shown on the MDP. 8.4.16 San Antonio SA Tomorrow All development proposed in this Comprehensive Plan, both military and civilian, is anticipated to be consistent with the goals and vision set forth in the San Antonio SA Tomorrow Comprehensive Plan and Multimodal Transportation Plan.

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8.4.17 San Antonio Unified Development Code, Development Standards This Comprehensive Plan strives to be consistent and compatible with the development standards, but it does not provide engineering-grade plans required for development applications through the San Antonio Development Services Department. 8.4.18 San Antonio Unified Development Code, Historic Preservation and Urban Design This Comprehensive Plan does not include redevelopment, alteration, or demolition of any of the five historic buildings identified in Section 6.2.3. Therefore, the Comprehensive Plan is consistent with UDC recommendations for historic preservation. 8.4.19 San Antonio Thoroughfare Plan Map The San Antonio Thoroughfare Plan Map proposes a secondary arterial road, referred to as the “North & South Connector,” that bisects JBSA and connects South Callaghan Road and Military Drive (State Route 13). While the proposed arterial road would enhance north-south transportation options near JBSA and Kelly Field, San Antonio has no immediate plans to pursue its implementation within the 20-year planning horizon of this Comprehensive Plan due to potential environmental impacts and cost of development. Therefore, the Comprehensive Plan is not consistent but compatible with the Thoroughfare Plan Map. 8.4.20 TxDOT Airport Compatibility Guidelines All development proposed in this Comprehensive Plan, both military and civilian, is anticipated to be consistent with the guidelines prescribed in the TxDOT Airport Compatibility Guidelines.

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KELLY FIELD COMPATIBILITY RESOLUTIONS

A summary of the compatibility issues identified in Chapter 8 and recommended resolutions are described below. 9.1 AIRPORT DESIGN CRITERIA FOR PLSS DEVELOPMENT There are 21 joint-use airports included in the FAA NPIAS that allow shared military and civilian use among the Air Force, Army, and Navy branches of the DOD, as shown in Table 9-1. Each joint- use airport is owned by the DOD and maintained and operated according to the use agreement between their respective military and civilian entities. The airfield design of each airport is also dependent on the missions it supports and their respective use agreement, which may include compliance or waivers to the UFC and/or Part 77 criteria. This variety of joint-use airports across the United States illustrates that numerous airfield designs and mixof operations can be accommodated on an airport-by-airport basis through unique use agreements. Further, a summary analysis and compatibility resolution of the UFC and Part 77 criteria in respect to a PLSS is discussed below. Table 9-1 – Joint-Use Airports in the FAA NPIAS Military Military Component Civilian Component Location Branch Air Force AF Plant 42 Palmdale Regional Airport (PMD) Palmdale, CA Air Force Charleston AFB Charleston International Airport (CHS) Charleston, SC Air Force Dover AFB Civil Air Terminal at Dover AFB (DOV) Dover, DE Air Force Eglin AFB Destin-Fort Walton Beach Airport (VPS) Valparaiso, FL Air Force Grissom AFB Grissom Aeroplex (GUS) Peru, IN Air Force JBSA-Lackland Port San Antonio (SKF) San Antonio, TX Air Force March ARB March Inland Port Airport (RIV) Riverside, CA Air Force Scott AFB (Mid America) MidAmerica St. Louis Airport (BLV) Belleville, IL Air Force Sheppard AFB Wichita Falls Regional Airport (SPS) Wichita Falls, TX Air Force Westover ARB Westover Metropolitan Airport (CEF) Chicopee, MA Ft. Pickett, Blackstone Army Army Allen C. Perkinson Airport (BKT) Blackstone, VA Air Force (AAF) Army Camp Guernsey AAF Guernsey Municipal Airport (GUR) Guernsey, WY Army Dillingham AAF Dillingham Airfield (HDH) Waialua, HI Ft. Leonard Wood, Forney Waynesville-St. Robert Regional Airport Army Ft. Leonard Wood, MO AAF (TBN) Army Robert Gray AAF Killeen- Regional Airport (GRK) Ft. Hood/Killeen, TX Army Camp Grayling, Grayling AAF Grayling AAF (GOV) Graylin, MI Army Ft. Huachuca, Libby AAF Sierra Vista Municipal Airport (FHU) Sierra Vista, AZ Ft. Leavenworth, Sherman Army Sherman AAF (FLV) Ft. Leavenworth, KS AAF Army Ft. McCoy Sparta/Ft. McCoy Airport (CMY) Sparta, WI Army Ft. Stewart, Wright AAF MidCoast Regional Airport (LHW) Ft. Stewart, GA Marine Corps Air Station Navy Yuma International Airport (NYL) Yuma, AZ (MCAS) Yuma Source: FAA, CHA, 2019

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9.1.1 UFC 3-260-01 Design Criteria (Military) Application of the UFC design criteria to any airfield development scenario results in numerous compliance issues with respect to the primary surface, transitional surface, approach-departure surface (sloped portion), and CZs; see Section 8.1.1 for a detailed analysis. Compliance issues related to PLSS Alternatives 1, 2, and 3 are limited to consideration of PSA-owned buildings and structures, as shown in Figure 8-1, Figure 8-2, and Figure 8-3, respectively. Compliance issues related to PLSS Alternative 4 are limited to consideration of buildings and structures on JBSA- Lackland, most of which are within TxANG and/or USAFRC campuses, as shown in Figure 8-4. 9.1.2 CFR 14, Part 77 Design Criteria (Civil) Application of the Part 77 design criteria to any airfield development scenario results in a limited number of compliance issues with respect to the transitional surface only; see Section 9.1.2 for a detailed analysis. Similar to the UFC design criteria, compliance issues related to PLSS Alternatives 1, 2, and 3 are limited to PSA and compliance issues related to PLSS Alternative 4 are limited to JBSA-Lackland, as shown in Figure 8-5, Figure 8-6, Figure 8-7, and Figure 8-8, respectively. 9.1.3 Resolutions for Airport Design Criteria In all airfield development scenarios, Part 77 compliance issues are likely to be resolved and approved by the FAA through marking and lighting, or removal of unused infrastructure. However, in order to resolve UFC compliance issues, this Comprehensive Plan provides two options that may be pursued at the time of implementation of a PLSS. Option 1: Waivers and/or Mitigations Option 1 includes pursuing waivers from the USAF for non-compliant buildings and structures to avoid their demolition and to retain their use. Thereafter, in instances where waivers are not acceptable, mitigation tactics would be pursued to satisfy the UFC design criteria. If waivers and/mitigations are not sufficient to comply with the UFC design criteria, then Option 2 should be pursued. Option 2: Long-Term Land Lease Option 2 includes PSA pursuing a long-term land lease from the USAF for the land needed to implement a PLSS designed to Part 77 FAA criteria. 9.2 AIR TRAFFIC CONTROL FOR A PLSS Existing Runway 16-34 was developed to UFC design criteria and is operated by the USAF. In the event a PLSS is developed to UFC design criteria using waivers and/or mitigations via Option 1 presented in Resolutions for Airport Design Criteria (Section 9.1.3), then the PLSS would be operated by the USAF akin to existing Runway 16-34. However, if a PLSS is developed using a long-term land lease via Option 2, then the USAF would require operational approval for air traffic control over a PLSS developed to Part 77 FAA criteria. Therefore, air traffic control is largely dependent on the outcome of the airport design criteria resolution.

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9.3 LIABILITY FOR A PLSS For all airfield development scenarios, PSA would verify that its indemnification and liability policy described in the 2013 JUA are adequate for a PLSS, especially for a PLSS developed to Part 77 FAA criteria.

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APPENDIX A

January 2021 DRAFT Appendix A Appendix A – IMPLAN Tables for Kelly Field

Kelly Field Economic Impact Summary Type Direct Indirect Total Employment 6,162 5,169 11,330 Income $611,693,700 $261,902,000 $873,595,700 Output $2,328,205,600 $830,508,800 $3,158,714,400

State and Local Taxes $49,540,400

Employment Description Direct Indirect Induced Total Total 6,162 1,198 3,970 11,330 11 Ag, Forestry, Fish & Hunting 0 0 18 18 21 Mining 0 5 5 10 22 Utilities 0 3 6 9 23 Construction 67 6 32 105 31-33 Manufacturing 2,446 75 27 2,548 42 Wholesale Trade 0 228 88 316 44-45 Retail trade 0 14 629 644 48-49 Transportation & Warehousing 66 146 129 341 51 Information 0 39 56 95 52 Finance & insurance 0 45 350 395 53 Real estate & rental 0 56 203 259 54 Professional- scientific & tech svcs 0 199 166 365 55 Management of companies 0 76 48 124 56 Administrative & waste services 0 204 232 436 61 Educational svcs 0 1 107 108 62 Health & social services 0 0 794 794 71 Arts- entertainment & recreation 0 10 110 119 72 Accommodation & food services 0 45 535 580 81 Other services 0 29 384 413 92 Government & non NAICs 3,583 17 51 3,651 Multiplier 1.84

R.A. Wiedemann & Associates, Inc. in association with CHA A-1 Appendix A – IMPLAN Tables for Kelly Field

Income Description Direct Indirect Induced Total Total $611,693,722 $77,247,662 $184,654,357 $873,595,740 11 Ag, Forestry, Fish & Hunting $0 $4,539 $114,107 $118,647 21 Mining $0 $690,040 $1,090,299 $1,780,339 22 Utilities $0 $278,414 $555,797 $834,211 23 Construction $4,319,974 $381,777 $2,013,660 $6,715,411 31-33 Manufacturing $246,989,720 $6,359,395 $1,561,891 $254,911,006 42 Wholesale Trade $0 $20,957,072 $7,519,008 $28,476,080 44-45 Retail trade $0 $722,089 $22,047,154 $22,769,243 48-49 Transportation & Warehousing $6,546,537 $8,185,683 $6,709,589 $21,441,809 51 Information $0 $3,546,828 $4,163,302 $7,710,130 52 Finance & insurance $0 $2,984,718 $20,422,465 $23,407,183 53 Real estate & rental $0 $2,236,903 $6,447,073 $8,683,977 54 Professional- scientific & tech svcs $0 $13,918,734 $10,859,887 $24,778,621 55 Management of companies $0 $4,537,626 $2,857,611 $7,395,237 56 Administrative & waste services $0 $7,601,673 $8,948,702 $16,550,375 61 Educational svcs $0 $48,050 $4,151,126 $4,199,177 62 Health & social services $0 $1,039 $48,266,560 $48,267,599 71 Arts- entertainment & recreation $0 $261,254 $3,152,431 $3,413,685 72 Accommodation & food services $0 $1,252,953 $13,822,602 $15,075,555 81 Other services $0 $1,522,146 $15,247,247 $16,769,393 92 Government & non NAICs $353,837,490 $1,756,727 $4,703,843 $360,298,061 Multiplier 1.43

R.A. Wiedemann & Associates, Inc. in association with CHA A-2 Appendix A – IMPLAN Tables for Kelly Field

Output Description Direct Indirect Induced Total Total $2,328,205,595 $252,288,905 $578,219,940 $3,158,714,439 11 Ag, Forestry, Fish & Hunting $0 $16,310 $685,108 $701,417 21 Mining $0 $2,251,273 $3,205,961 $5,457,234 22 Utilities $0 $3,052,711 $5,227,842 $8,280,554 23 Construction $13,300,000 $1,204,748 $6,643,800 $21,148,547 31-33 Manufacturing $1,849,920,266 $43,272,058 $14,945,569 $1,908,137,893 42 Wholesale Trade $0 $74,685,347 $28,887,466 $103,572,813 44-45 Retail trade $0 $1,815,413 $55,730,337 $57,545,750 48-49 Transportation & Warehousing $20,954,911 $21,648,544 $16,759,731 $59,363,187 51 Information $0 $16,153,249 $23,015,556 $39,168,805 52 Finance & insurance $0 $11,223,914 $85,722,334 $96,946,248 53 Real estate & rental $0 $12,577,526 $104,185,331 $116,762,857 54 Professional- scientific & tech svcs $0 $26,061,004 $22,392,245 $48,453,249 55 Management of companies $0 $10,388,981 $6,542,556 $16,931,537 56 Administrative & waste services $0 $16,177,246 $19,293,370 $35,470,616 61 Educational svcs $0 $93,147 $6,711,376 $6,804,523 62 Health & social services $0 $1,966 $85,650,549 $85,652,515 71 Arts- entertainment & recreation $0 $536,677 $9,033,818 $9,570,495 72 Accommodation & food services $0 $3,003,819 $37,827,276 $40,831,095 81 Other services $0 $2,854,064 $30,044,961 $32,899,026 92 Government & non NAICs $444,030,418 $5,270,908 $15,714,754 $465,016,080 Multiplier 1.36

Tax Impact Summary Impact Direct Indirect Induced Total Sub County General $1,296,867 $895,670 $3,897,683 $6,090,220 Sub County Special Districts $2,945,375 $1,982,934 $8,606,285 $13,534,594 County $1,125,292 $725,481 $3,134,173 $4,984,946 State $6,300,544 $3,544,423 $15,085,700 $24,930,668 Federal $123,764,117 $15,723,318 $38,371,507 $177,858,942 Total Tax Impact $135,432,196 $22,871,827 $69,095,348 $227,399,371

R.A. Wiedemann & Associates, Inc. in association with CHA A-3