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Original Joint Proposal City /Districts' Proposed Port Counter <br />New :Proposal..offer <br />11.Effectiveness of Port should begin North Counter - offer to City and <br />Port's Obligations - Except Field noise resolution pro -• Districts:. OK to new pro - <br />for ILS relocation techni- cess (item 8 above) inmedi- posal. <br />cal studies, the Port's ob- ately. <br />ligations would become ef- <br />fective only after it has <br />received FAA approval of <br />the ADP and all litigation <br />challenging the Port's or <br />FAA's ADP approval has been <br />finally resolved which .al- <br />lows the Port to proceed <br />with the ADP <br />12. Additional Litigation OK No Counter - offer required <br />The City and School Dis-to City or Districts <br />tricts will dismiss their <br />lawsuits against the Port, <br />will not file a lawsuit to <br />challenge the FAA',s ap- <br />proval of the ADP, and will <br />not oppose future actions <br />to implement the ADP or de- <br />velop the Airport to reach <br />the passenger and cargo <br />levels which' were used to <br />develop the ADP mitigation <br />measures and the noise in- <br />sulation offered by the <br />Port. <br />Airport Development Program <br />Proposed Settlement Terms <br />San Leandro and School Districts v. Port) - <br />16905- 1 <br />4