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November 8, 2024 Page 26 7357-013acp printed on recycled paper The DEIR must be revised and recirculated to include analysis of the Project’s and nearby projects’ cumulative operational noise impacts before the Project can proceed. ii. The DEIR Underestimates Construction Noise Impacts The DEIR concludes that construction noise impacts are less than significant. This is not correct. Construction noise will exceed the Federal Transit Administration’s 80 dBA threshold at nearby sensitive receptors.132 Ms. Toncheva calculated that construction noise at nearby residences would be over 82 dBA.133 The DEIR’s construction noise analysis assumes shielding from the existing 6-foot high sound wall located along the project’s western boundary adjoining the residential land uses.134 Ms. Toncheva’s comments provide that the DEIR provides no evidence in the form of measurement data, or clarification on the type of wall, to support the determination that the 6-foot wall would shield the Project’s noise impacts.135 The DEIR provides that “[w]hile the proposed project would raise the project site by approximately 6 feet adjacent to the western boundary of the project site, the proposed project would include a retaining wall and good neighbor wall to minimize impacts relate to existing visual characteristics of the site.”136 The DEIR does not provide any definition of a “retaining wall” or a “good neighbor wall” or provide the public with any certainty that this would constitute a noise buffer to mitigate the Project’s construction noise impacts. Moreover, if the Project site is raised 6 feet, then a 6-foot sound wall will do nothing to reduce noise impacts. The DEIR must be revised and recirculated to accurately characterize, analyze, and mitigate significant noise impacts associated with construction and operation of the Project. VI. THE DEIR FAILS TO ADEQUATELY ANALYZE AND MITIGATE THE PROJECT’S SIGNIFICANT CUMULATIVE IMPACTS The environmental and public health impacts of the Arroyo Lago and Senior East County Lakes projects will overlap in time and location, and may be significant both individually and cumulatively. The DEIR fails to account for the Senior East County Lakes Project in the cumulative projects analysis.137 The projects also 132 Toncheva Comments, p. 5. 133 Id. 134 DEIR, p. 3.12-19. 135 Toncheva Comments, p. 4. 136 DEIR, p. 3.1-16. 137 DEIR, Table 3-1: Cumulative Projects.