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City of s=u Ana -The tina,i7' May 11, 2020 Page 17 of 23 The DF.IR's Non , JVactAa#sis it Not Su. pporled by Substantual Evidence The 17FIR incorrectly concludes, without substantial evidence, that the proposed Project will not have a substantial impact relating to noise on its Riture residents or worker} in the area. The Project Applicant and City conducted no on -site study to determine aircraft noise levels from John Wayne Airport at the site and rely solely on the fact that the Project is located outside the 60 decibel or higher contour zone for the airport to conclude there will be no significant noise impact. This analysis fails because it needs to include sitc-specific facts and application relating to the actual aircraft noise levels and their effects.' A more detailed analysis of this issue can be found below under section III of this comment letter. 2. The DEIA Finding That the I'ra}'ect Conflict nntb theJohn Wayne Aa'rpart Envlanns Land Use Plan 01;-2) and that the Pavject Would Not Racult in Ex sssive No se for a Pnject Subyect to an Aatporl hand Use Plan (IIA7. 5) iu Mitegakd to Less Than Szgnrficavt Levels is Not Supported by Substantial Evidence The Project has the potential to expose residents of the Project to significant aviation noise conflicts with the John Wayne Airport rmrvirores band Use Plan Policies 3.2.1 and 3.2.4; as well as a conflict with the City of Santa Ana's General Plan Goals 1, Policy L3 (DF.IR at 5.7-26, 59-22) The Project site is 2 miles fmtn John Wayne Airport and within that airport's flight path. Although the EIR theorises without supporting evidence that impacts may be insignificant because the site is outside the 60 CNEL contour for excessive noise, it nevertheless also proposes that the Project will comply with Title 24 of the California Code on interior noise levels, which could (again theoretically) ensure a less than significant impact with mitigation. This mitigation measure is impermissibly deferred because there is no project -specific analysis relating to how compliance with the noise code sections will sufficiently mitigate potential noise impacts on residents The IDEIR needs to specify bow code compliance will ensure safe and insignificant noise levels for residents and works on the site. 5 3. The DEIA'sAntheiicsAnal4&isNot Supported bvSubstantial Evddence 116 See The Bowery, Noise Impact Analysis, Dec. 3, 2019. Available at httns: (/ceganetagcca.eov 120190800d 1 /31Attxhment/jsSTi--. 75C-137