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The introduction of haul trucks vs. automobiles is a completely different noise source. <br /> The frequency content (low rumble) of trucks vs. the tire-on-pavement higher frequency <br /> content of an automobile is distinctly different. Based upon the Appendix C I of the Draft <br /> EIR, the existing roadway traffic volumes along East River Road during the nighttime <br /> hours is as little as 3 automobiles between the hours of 1:00 a.m. and 2:00 am. The <br /> project is expected to result in one haul truck passby every two minutes during that <br /> period. <br /> Even with the proposed mitigation, background hourly noise levels are still expected to <br /> increase by over 10 dBA. Generally, CEQA considers a significant increase in noise to <br /> be 3 dBA. Lets not forget that the mitigation was supposed to be implemented during the <br /> temporary permit in August 2011. The noise measurement results did not support that <br /> the mitigation was effective. <br /> Overall Reporting of Noise Impacts <br /> I think that it is interesting that the original noise analysis indicated that the noise levels <br /> from the asphalt plant would be as low as 35 dBA Leq during operations, based upon <br /> noise measurement data collected by Bollard. Now, as the process has continued, the <br /> predicted noise levels are equal to the nighttime standard of 45 dBA I.eq. However, no <br /> noise measurements have ever been conducted by Bollard at the Adrienne residence. The <br /> j.c. brennan data indicates that noise levels from the batch plant could be as high as 55 <br /> dBA Leq, and is consistently above 45 dBA Leq. <br /> It is also interesting that the original analysis by Bollard estimated the sleep disturbance <br /> to be approximately 5% to 10% using an antiquated method for calculating the potential <br /> for sleep disturbance. This analysis was used even though Bollard was fully aware of the <br /> more recent research in calculating sleep disturbance. Now the EIR states that there is a <br /> 99% to 100% chance for sleep disturbance or potential for awakening. However, the <br /> conclusions are still misleading, due to the fact that they assume that the majority of <br /> people are awakening due to existing traffic and that the trucks (1 every 2 minutes) will <br /> not significantly affect the potential for awakening. <br /> If you or the county staff has questions,please contact me. <br /> Respectfully submitted, <br /> j.c. brennan &,associates, Inc. <br /> sident <br /> Member: Institute of Noise Control Engineering <br /> file: 2011-148 Munn Perkins-February 2012 - VI <br /> 3 <br />