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November 8, 2024 Page 25 7357-013acp printed on recycled paper California Office of Noise Control Land Use Compatibility Guidelines.125 Ms. Toncheva concludes that operational noise impacts are therefore significant. The DEIR’s conclusion that operational noise impacts are less than significant is therefore not supported by substantial evidence. Ms. Toncheva’s comments also provide substantial evidence that noise from off-site elements of the Project, including the proposed sewer treatment plant located in Parcel B adjacent to the Project Site will result in a significant environmental impact.126 Ms. Toncheva’s comments demonstrate that the pumps on top of separation tanks could allow noise to propagate deep into an adjoining neighborhood, significantly disturbing noise sensitive receptors.127 Further, Ms. Toncheva concludes that the nearby lake would further exacerbate operational noise from the sewer treatment plant.128 Ms. Toncheva’s comments provide that the lake’s “smooth water surface reflects sound, and the effect can be amplified by morning and evening air inversions.”129 The Project’s sewer treatment plant results in significant, unmitigated operational noise impacts to nearby sensitive receptors, which must be analyzed and mitigated in a revised and recirculated EIR. Further, Ms. Toncheva’s comments point to the DEIR’s failure to adequately analyze the cumulative operational noise impacts associated with the Project. The DEIR includes a public comment that: “The Draft EIR should analyze noise impacts associated with proximity to the City of Pleasanton Operations Services Center, Fire Training Facility, and Police Department practice range.”130 The DEIR fails to adequately address the potentially significant cumulative operational noise impacts of these projects, even though these facilities are mentioned as dominant noise sources near the Project site.131 The DEIR’s failure to adequately analyze the cumulative operational noise impacts of these Projects is a failure to proceed in the manner required by law. The DEIR fails to analyze noise impacts to the adjacent Senior East County Lakes Project. Ms. Toncheva’s comments demonstrate that the DEIR’s failure to include analysis of the Senior East County Lakes Project in the environmental baseline for the Project results in an underestimation of the Project’s operational noise impacts. 125 https://www.lci.ca.gov/docs/OPR_Appendix_D_final.pdf 126 Toncheva Comments, p. 3. 127 Toncheva Comments, p. 3. 128 Toncheva Comments, p. 3. 129 Toncheva Comments, p. 3. 130 DEIR, pg. 3.12-1. 131 DEIR, pg. 3.12-10.