Project's noise impacts will be significant at surrounding homes
Residents in the city have the right to be protected from excessive noise resulting from new development. This project's residential neighbors are already exposed to excessive noise levels from other sources. That is mostly because they are just several hundred feet from the Union Pacific railroad tracks with an on-grade crossing at Nixon Road where loud train horns are frequently sounded. But those excessive noise levels are also because neighbors live near the intersection of two major streets, Ski Village Drive and North Mount Shasta Boulevard. When a residential neighborhood is exposed to noise levels greater than defined as being acceptable in the city's General Plan, then any new project-caused noise level increase of more than a few decibels is considered by CEQA to create a significant noise impact. This standard is used throughout California. But the IS-MND fails to analyze this obvious significant noise impact caused by the project's increase in noise as compared to the existing excessive noise levels nearby. That alone is a serious enough flaw to legally require the city to prepare an EIR to evaluate this issue.
inadequate ambient noise level measurements
The IS-MND was required by CEQA to evaluate if the project would generate "a substantial ...permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise
ordinance or of applicable standards of other agencies?" To do that, the IS-MND would have had to first measure the ambient noise levels near the project site. But it did not do that. By definition, the ambient noise level includes a 24-hour averaged measurement with some adjustments for increased nighttime noise sensitivity by residents. Yet no nighttime noise measurements were even included in the IS-MND. There is no evidence that the project's brief 10-minute noise measurements even included the sound of passing trains, typically spaced much more than 10 minutes apart. Yet train noise at that close distance is the loudest noise source these neighbors are exposed to. The IS-MND erroneously claims that the ambient noise level for a full day is essentially equal to a 10-minute noise test in midday, not realizing that nighttime conditions are much quieter than at noon.
With no nighttime measurements at all, none of the loud train noise measurements that occur about 24 times per day, and no noise measurements at any location for 23 hours and 50 minutes of a typical day, it cannot be said that the noise study in the IS-MND provides evidence to support its conclusion of a less-than-significant noise impact. The neighbors have a right to know what the ambient noise levels are at their homes so they can judge whether the increases due to project construction or operation may be excessive.
Then, the IS-MND never informs the public how loud the project's combined noise sources will be as heard at residential neighbors' homes. Instead, the IS-MND separately calculates noise emissions from car wash blower/dryers, from vacuum stations, and from vehicles arriving and leaving the project site. But it never adds them together. Yet that combined noise level is essential to compare with the city's standards or with the the ambient noise level. The IS-MND also never considers noise from people using the car wash or storage units, including their voices, shouts, amplified music from cars, or loud mufflers.
This analysis the IS-MND presents is so bad that it is as if the preparers of the project's noise study have never done a noise study before and had no idea what they were doing.
ordinance or of applicable standards of other agencies?" To do that, the IS-MND would have had to first measure the ambient noise levels near the project site. But it did not do that. By definition, the ambient noise level includes a 24-hour averaged measurement with some adjustments for increased nighttime noise sensitivity by residents. Yet no nighttime noise measurements were even included in the IS-MND. There is no evidence that the project's brief 10-minute noise measurements even included the sound of passing trains, typically spaced much more than 10 minutes apart. Yet train noise at that close distance is the loudest noise source these neighbors are exposed to. The IS-MND erroneously claims that the ambient noise level for a full day is essentially equal to a 10-minute noise test in midday, not realizing that nighttime conditions are much quieter than at noon.
With no nighttime measurements at all, none of the loud train noise measurements that occur about 24 times per day, and no noise measurements at any location for 23 hours and 50 minutes of a typical day, it cannot be said that the noise study in the IS-MND provides evidence to support its conclusion of a less-than-significant noise impact. The neighbors have a right to know what the ambient noise levels are at their homes so they can judge whether the increases due to project construction or operation may be excessive.
Then, the IS-MND never informs the public how loud the project's combined noise sources will be as heard at residential neighbors' homes. Instead, the IS-MND separately calculates noise emissions from car wash blower/dryers, from vacuum stations, and from vehicles arriving and leaving the project site. But it never adds them together. Yet that combined noise level is essential to compare with the city's standards or with the the ambient noise level. The IS-MND also never considers noise from people using the car wash or storage units, including their voices, shouts, amplified music from cars, or loud mufflers.
This analysis the IS-MND presents is so bad that it is as if the preparers of the project's noise study have never done a noise study before and had no idea what they were doing.
INADEQUATE NOISE MITIGATIONS
As an example of how absurdly flawed the IS-MND's noise study is, it proposes that the automated car wash possibly include six-foot high noise walls on the east side between the two-story apartment residence and the automated car wash's noisy blower-dryers that are proposed by the developer to be unenclosed at the wash tunnel's openings. (See illustrations above and below for simulated views of such 6-foot tall noise barriers.) The IS-MND never predicts how much noise such short noise barriers would be capable of reducing. Because they would not be tall enough to even interrupt the line-of-sight between the blowers-dryers and the apartment windows or other homes' windows, they would offer no noise reduction benefits. Because two driveways each 24 feet wide are needed for car wash access, those huge gaps in the noise wall would also render the wall ineffective. Instead, worse than not even having a noise wall there, such walls would increase traffic noise impacts from passing cars heard at those 2nd-story apartments by reflecting vehicular noise on Ski Village Drive and on the widened road to the warehouse entrance back toward the apartments. This is an example of the preparers of the IS-MND not understanding how to evaluate a project's noise impacts. And also creating such a mess that their proposed noise wall mitigation increases the harm to existing nearby residents even more than the applicant's unmitigated project would.
There is no evidence in the IS-MND that a six-foot high noise wall could work to sufficient quiet this noisy car wash. The noise study preparers merely added that suggestion without comparing if a 12-foot or 16-foot high wall might be needed instead. CEQA prohibits the imposition of such mitigations without any evidence they would reduce noise impacts to less than significance.
There is no evidence in the IS-MND that a six-foot high noise wall could work to sufficient quiet this noisy car wash. The noise study preparers merely added that suggestion without comparing if a 12-foot or 16-foot high wall might be needed instead. CEQA prohibits the imposition of such mitigations without any evidence they would reduce noise impacts to less than significance.
6-FOOT NOISE WALLS WILL NOT SHIELD 2-STORY APARTMENTS FROM CAR WASH NOISE
AND WILL CREATE THEIR OWN UNSIGHTLY VISUAL IMPACTS THAT THE IS-MND NEVER ANALYZES.
Views show that a short 6-foot tall noise wall will not block noise from car wash blower-dryer operation.
CEQA PROHIBITS MITIGATION THAT RELIES UPON FUTURE NOISE
STUDIES THAT SHOULD HAVE BEEN DONE ADEQUATELY AT THIS TIME
The IS-MND violates CEQA by not only failing to evaluate how loud the project will be and how severe its noise impacts will become at nearby homes, but also by requiring a future noise study to solve the excessive noise problem to neighbors. CEQA prohibits the use of deferred mitigations and future noise studies that prevent neighbors from evaluating how effective they will be at this time during public review. There is no technical reason that a proper noise study could not have been completed before the IS-MND was released. The alternative to such studies, that is, enacting performance standards with definite and enforceable noise limits, is not acceptable when no reason is presented for such a deferred study. The city would be denying neighbors their right to protect themselves from excessive noise. The city has no noise meter to even be able to monitor such project noise. CEQA prohibits the planning commission from relinquishing its formal duty to evaluate the project's noise impacts and turning over such a discretionary decision in the future to an unelected staff member at city hall.
city fails to protect adjacent home from loud car wash noise
The noisy car wash and mini-storage project is proposed adjacent on three sides to an existing home at 1315 Rd. No. 2M16. The IS-MND however never evaluates the combined noise level at this home's yard from operation of the car wash equipment, from vehicles on-site, from shouts, music and other voices, from additional traffic passing by this home a few feet away on Road No. 2M16 which currently has very little traffic, and from people and vehicles accessing the mini-storage units. The proposed, merely optional, 6-foot high noise barrier would be too short to block noise from the automatic car wash equipment and blower/dryer or from trucks with raised exhausts. What the IS-MND proposes instead of adequate analysis and noise mitigations now, is that a future, (likely-biased) noise study commissioned by the applicant someday evaluate the noise problem at this residence and suggest changes. This might only be triggered if the neighbors complain about excessive noise levels, but how will they know if project operations exceed 50 dBA? They don't own noise meters, and neither do City officials. Such complaints would fall upon deaf ears. Project noise from onsite vehicles or human activities is not even included in that 50 dBA mitigation. No mitigation at all is proposed for increased traffic noise from off-site vehicle passings in front of this house at 1315 Rd. No. 2M16. In short, due to incompetence on the part of the IS-MND, and failure by city officials to protect the neighbors by requiring a noise study that meets the City's minimum standards for noise studies, these neighbors are potentially doomed to suffering serious noise impacts.
In order to comply with CEQA, the public should require the city to prepare an EIR to better evaluate and solve these significant noise problems.
In order to comply with CEQA, the public should require the city to prepare an EIR to better evaluate and solve these significant noise problems.
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