Advisory Board: Airport Land Use Commission
Subject: Watsonville Pilots Association vs. City of Watsonville
Presenter: Jamar Stamps, ALUC staff
Contact: (925) 655-2917
INTRODUCTION
In August 2021, the Watsonville Pilots Association (WPA) filed a lawsuit against the City of Watsonville (City) after the city council approved a 21-unit Townhome Project (Project) near the Watsonville Municipal Airport. The WPA challenged the City’s approvals (adoption of a mitigated negative declaration (MND) and zoning and general plan amendments). The Court agreed with WPA in a February 3, 2026 ruling (Exhibit A), concluding the City approved a project based on a development entitlement process that did not comply with the State Aeronautics Act (SAA).
BACKGROUND
State Aeronautics Act
The SAA (Public Utilities Code (PUC) sections 21001 et seq.), administered by the California Department of Transportation, Division of Aeronautics, mandates the Division establish guidelines to assist municipalities with airport land use planning. The California Airport Land Use Planning Handbook (Handbook) serves as those guidelines.
The SAA also requires every county with a public use airport to establish an Airport Land Use Commission (ALUC). However, two alternatives are available to counties:
1) Alternative Process counties: If the county conducts appropriate hearings and adopts a resolution finding no noise, public safety or land use impacts exist, they can declare the county exempt from the ALUC requirement.
2) No Procedure counties: If the county has only one public use airport owned by a city, the county and affected city may adopt the necessary Handbook elements into their planning documents (i.e., general plan, specific plans, etc.). Said planning documents must be submitted to the Division of Aeronautics.
Santa Cruz County, which contains the City of Watsonville, is the only No Procedure county due to a 1994 amendment to the SAA that modified the requirement for all counties to have ALUCs.
21-unit Townhome Project at 547 Airport Boulevard (Watsonville)
In August 2021, the City of Watsonville approved the development of 21 townhomes on a 1.57-acre parcel located at 547 Airport Boulevard (Exhibit B). The City also approved a California Environmental Quality Act (CEQA) Mitigated Negative Declaration (MND). CEQA allows lead agencies to prepare a MND (prior to an Environmental Impact Report or EIR) if there is no substantial evidence that the project or any of its aspects may have a significant effect on the environment. The City’s environmental analysis included references to the Handbook guidance, mentioning the project site is within “Safety Zone 6” and relied on a 2018 noise study that evaluated sites near the airport but did not evaluate the project site, to conclude there would be no airport land use compatibility impacts. However, this was done without an established ALUC or compliance with either ALUC alternative, or SAA mandated Handbook guidance incorporated into their General Plan.
Following the City’s approval, the WPA filed the subject lawsuit with two main arguments:
1) The City’s Project approvals violated the SAA and that those approvals must be reversed.
2) The City’s decision to issue a MND for its environmental review was improper, and an EIR should have been completed.
The Court agreed with WPA in a February 3, 2026 ruling, concluding the City approved a project based on a development entitlement process that did not comply with the SAA. The City was required to rescind the project approvals, and the development as proposed would not be allowed to proceed on the subject property until the City’s general plan was brought into compliance with the SAA.
City of Watsonville’s History with SAA Compliance
The City’s 2005 General Plan was adopted in 1994, which predated establishment of the SAA. In 2006, the City attempted adopting an updated General Plan (2030 General Plan), however the adoption of their 2030 General Plan was challenged due to noncompliance with the SAA. After a successful legal challenge by the WPA, the City had to rescind adoption of the updated 2030 General Plan and reestablish their prior 2005 General Plan as their governing planning document until the 2030 General Plan was updated in compliance with the SAA.
In 2013, the City again certified a revised EIR and approved a revised 2030 General Plan. WPA sued again alleging the revised 2030 General Plan and its EIR again violated the SAA and CEQA. In 2014, the Court again ruled in favor of the WPA and ordered the City to rescind certification of the revised 2030 General Plan. The City rescinded its revised 2030 General Plan in October 2014, which again left the City’s 2005 General Plan as the operative overarching planning document for the City.
To date, the City has not updated its General Plan to comply with the SAA. However, the City is actively developing another update to their General Plan (2050 General Plan). According to the Watsonville General Plan Update 2050 website, the City is incorporating feedback received from their outreach and engagement phase and appear to finally be considering airport land use policies and how to “integrate the airport with the rest of the City of Watsonville.” The City anticipates public hearings and final adoption by Summer 2026.
STAFF ANALYSIS
After review, ALUC staff concludes that Contra Costa County would not experience the same or even similar challenges. The primary issues at hand for the City of Watsonville included:
1) Santa Cruz County does not have an ALUC, therefore leaving cities with public use airports within the County having to self-certify their compliance with the State Aeronautics Act (SAA).
2) The City did not comply with the SAA by either establishing an ALUC or incorporating California Airport Land Use Planning Handbook guidance into their General Plan in accordance with the SAA.
3) The City proceeded to attempt to process general plan and zoning updates and land use entitlements within Airport Influence Areas without duly established airport land use regulations.
Contra Costa County has an established ALUC and is therefore compliant with the SAA. Individual cities within Contra Costa County’s Airport Influence Areas have incorporated general plan policies addressing or referencing the Contra Costa ALUC and mandatory compliance with airport land use compatibility criteria (Exhibit B). Neither Contra Costa County nor the incorporated cities within the County would face the SAA compliance issues stated throughout the Watsonville lawsuit. Therefore, ALUC staff recommends no further action. However, after discussion, the Commission may also provide direction to staff as they see fit.