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E <br />Caroli Mortensen <br />January 13, 2012 <br />Page 9 <br />L` <br />The Landfill Expansion Project is reasonably foreseeable and consequently, <br />the environmental impacts of all of the landfill's proposed operations must be analyzed. <br />Inasmuch as the Landfill Expansion Project was not contemplated in 2003, the 2003 <br />DEIR certainly did not address these environmental impacts. <br />2. The Increase in Sunday Operations Will Have Potentially <br />Significant Impacts on Area Noise Levels. <br />According to the CEQA Guidelines, a project would result in a noise <br />impact if it would: (a) expose persons to or generate noise levels in excess of standards <br />established in the local general plan or noise ordinance; or (b) result in a substantial <br />temporary or periodic increase in ambient noise levels in the project vicinity above levels <br />existing without the project. CEQA Guidelines, Appendix G XII (a) and (d). <br />Accordingly, the 2010 DEIR states that a noise impact from any new landfill operation <br />would be potentially significant if it would cause noise levels at any of the noise sensitive <br />land uses to exceed the maximum allowable noise exposure levels identified in the San <br />Joaquin County Code. 2010 DEIR at IV.0-2. The County Code identifies maximum <br />allowable noise exposure levels of 65 dB Ldn for outdoor residential uses and 45 dB Ldn <br />for indoor residential uses. Id. at IV.0-4. <br />It is imperative to evaluate the existing environment when analyzing a <br />Project's potential environmental impacts. The SWFP ND did not analyze the noise <br />effects that would result from the SWFP Revisions and therefore unfortunately also did <br />not describe the existing (Sunday) background noise environment. A description of <br />existing ambient noise levels is particularly important in this instance because, on the vast <br />majority of Sundays, residents near the landfill currently enjoy quiet conditions because <br />the landfill is restricted from operating. On those 42 Sundays per year, the landfill's <br />noisy equipment is not running and no landfill -related trucks travel along area roadways. <br />Indeed, Forward's 2003 CUP likely limited the number of Sundays the landfill could <br />operate in order to protect the quality of life of nearby residents. <br />There are at least 20 residences located on Austin Road and French Camp <br />Road and some of the outdoor activity areas of these residences are as close as 25 feet <br />from the roadways' centerline. See 2010 DEIR at IV. C. -hand IV. C-15 footnote to Table <br />trucks travel along roadways, especially two-lane roadways, there is an elevated risk of <br />vehicular accidents. These impacts have not been analyzed. <br />SHUTE MIHALY <br />&—WEINBERGERu_P <br />