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City of Santa Ana — Cabrillo Town Center Project <br />August 17, 2023 <br />Page 4of5 <br />C...... The Metro EIR Fails to Adequately Analyze the Project's Noise Impacts <br />Yet another reason why a subsequent EIR must be prepared is because the Metro <br />EIR does not adequately analyze the Project's noise impacts for several reasons. <br />i. The Metro EIR Fails to Identi <br />ft All Nearby Sensitive Receptors <br />First, as noted by noise expert Steve Rogers, the Metro EIR does not adequately <br />describe the environmental setting of the Project because it fails to capture all of the <br />nearby sensitive receptors. June 29, 2023 Letter from Steve Rogers to Talia Nimmer <br />("Exhibit B"). Specifically, although the Metro EIR identifies a total of 15 nearby <br />sensitive receptors, the locations selected are almost all on busy streets or close to <br />freeways, and therefore do not represent quieter locations that are set back and/or <br />shielded from major traffic routes. Id. at 2; Metro EIR at 4.9-3. For example, the <br />Metro EIR fails to include the Lake Dianne Apartments complex, which is located <br />immediately northeast of the Project site and represents the closest sensitive receivers <br />to the sources of noise associated with the Project. Exhibit B at 2. Thus, a subsequent <br />EIR must be prepared to assess ambient noise conditions for receivers further away <br />from major traffic routes and/or shielded by intervening structures such as the Lake <br />Diane apartment complex. <br />ii. The Metro EIR Fails to Adequately Characteri.Ze Ambient Noise <br />Conditions <br />With regard to the sensitive receptors which the Metro EIR does identify, it fails to <br />adequately characterize their ambient noise conditions. Rather, the sensitive receptors <br />are short-term (15-minute), daytime readings only and therefore do not capture the <br />quieter evening and nighttime periods, when any noise impacts from the Project will <br />be more disruptive to nearby receivers. Id. at 1. Further, they are insufficient to <br />determine 24-hour weighted average noise metrics, such as Community Noise <br />Equivalent Level ("CNEL" ), which is the basis of the noise standards in the City of <br />Santa Ana General Plan. Id. at 2. A subsequent EIR must be prepared to adequately <br />characterize the ambient noise conditions by (1) conducting 24-hour baseline noise <br />measurements at locations selected to represent baseline ambient noise conditions at <br />all sensitive receivers around the Project site; and (2) conducting continuous <br />monitoring or, at a minimum, conducting 15- minute readings at 9AM — 5PM <br />(daytime); 8PM — 10PM (evening); and 1AM — 3AM (nighttime). Id. at 5. <br />City Council 18 — 293 10/3/2023 <br />