SEACA, Public Counsel, CBC, and NRDC Comments on the CASP DEIR November 23, 2011 P. 53 of 78 . (DEIR, pp. 12-6, 12-11).
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The DEIR assumes, without explanation, that development and operation of the Project (DEIR, p. 12-14). This assumption is without merit, given the increased population that the Project will generate, and the associated increases in construction and residential and commercial traffic, conceded by the DEIR to constitute a significant and unavoidable impact. The DEIR has made no effort to predict or quantify potential noise impacts under the Proposed Alternative, but merely assumes they do not exist. Because no noise estimates are made, it is impossible to
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hides behind the already high noise levels in the Project area, and fails to disclose the contribution that the Project itself will make to existing conditions. basic purpose of providing decisionmakers and the public with detailed information about the effect the project is likely to have on the environment. (Pub. Res. Code ยง21061). Because the DEIR fails to admit to any Project-impacts to noise, it suggests a series of mitigation measures that fail to reduce impacts to the existing residential areas and existing community. While Mitigation Measures Noise and Vibration 1a through 1d address and mitigate noise impacts to new developments, public buildings, and other features of the Project, they fail in any way to minimize the effects of new noise impacts to existing sensitive receptors including two existing schools Albion Street Elementary School and Ann Street Elementary School and residential areas. Feasible and reasonable mitigation includes sound walls, improved window/wall insulation, and pavement changes that can reduce sound levels from highway traffic.
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The DEIR also appears to rely on maximum interior noise levels set forth in the CASP as a backstop. However those levels set forth in Sections 8.4.4, 8.4.5 and 8.4.6 of the CASP as ranging from 45 dBL to 65 dBL are much lower than existing exterior noise levels, and there is no indication in the CASP or the DEIR how or whether these reduced noise levels could be achieved.
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With respect to construction noise, the DEIR again creates an analytical vacuum by failing to show how construction noise could impact sensitive receptors or increase noise levels at existing monitoring stations. We are pleased that the DEIR has set forth specific and enforceable mitigation measures that will be applicable to new development projects. However, we caution the City to reanalyze whether Mitigation Measure Noise and Vibration 2 is adequate. For example, it allows the use of jackhammers, drills, and impact wrenches as early as 7 a.m. and as late as 9 p.m. Allowing noisy equipment use to last several hours after many children typically go to bed is not adequate mitigation.
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Even more troublesome, as discussed in more detail below, the cumulative impacts analysis of noise and vibration, totaling a single paragraph, acknowledges that noise in the Project Area and surrounding area will increase, but suggests nothing to address this impact and fails to reach a significant conclusion regarding cumulative noise impacts. (DEIR, p. 17-6). The is particularly problematic because the administrative
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