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November 8, 2024 Page 24 7357-013acp printed on recycled paper Ironwood Drive.”121 The DEIR relies on mitigation that is also a Project design feature to conclude that transportation impacts cannot be mitigated. Mitigation measures must be fully enforceable through permit conditions, agreements, or other legally binding instruments.122 CEQA defines “mitigation” as “[a]voiding the impact altogether by not taking a certain action or parts of an action; [m]inimizing impacts by limiting the degree or magnitude of the action and its implementation; [r]ectifying the impact by repairing, rehabilitating, or restoring the impacted environment; [r]educing or eliminating the impact over time by preservation and maintenance operations during the life of the action; or [c]ompensating for the impact by replacing or providing substitute resources or environments.”123 The project design features are therefore not “mitigation” within the meaning of CEQA, because construction of approximately 1,000 feet of off-site sidewalk improvements and bicycle lane improvements is already a Project component. Moreover, as SWAPE’s comments demonstrate, MM TRANS-2b itself will result in GHG emissions impacts which must be mitigated in a revised and recirculated EIR. Further, the Project results in cumulatively significant GHG impacts, particularly when taking into account the proposed Senior East County Lakes Project. The additional 569 units and 10,000 square feet of support services will result in cumulatively significant GHG and transportation impacts that the DEIR fails to adequately analyze or mitigate. The DEIR must be revised and recirculated to accurately quantify the cumulative GHG and transportation impacts of the concurrent proposed Project on the Project site. D. The DEIR Fails to Adequately Analyze and Mitigate Significant Noise and Vibration Impacts i. The DEIR Underestimates Operational Noise Impacts The DEIR fails to adequately analyze and mitigate the Project’s significant operational and construction noise impacts. Furthermore, the DEIR fails to analyze noise impacts to the foreseeable Senior East County Lakes Project. The DEIR predicts future traffic noise levels, including project traffic increases, of 65 dBA along Busch Road.124 These levels exceed normally acceptable community noise exposure threshold of 60 dBA for single family residences, per 121 DEIR, p. 3.16-20. 122 Id. at § 15064(a)(2). 123 14 Cal. Code Regs. § 15370. 124 DEIR, p. 3.12-21, Table 3.12-8