A Condition of Approval (CP-1) has been added in the FEIR which sets the following new restrictions (FEIR, Mitigation Monitoring and Reporting Plan, page 54) :
- No construction equipment may be delivered via Circle Oaks Drive
- Extra-legal loads (exceeding 80,000 lbs) and construction equipment deliveries (as defined in Table 3.5) must be delivered through Walt’s “Gate 1”
While the new restrictions are welcomed by the community of Circle Oaks to help reduce noise levels created by transportation of construction equipment through the community, the restriction falls short of the continued serious concerns about pedestrian safety and the deteriorated condition of Circle Oaks arterials that may still be used by Walt Ranch for all other purposes which were not restricted. (See original articles: Circle Oaks Roads and Infrastructure and Noise and Acoustics)
The Condition of Approval does not:
- Restrict use of Circle Oaks roads for delivery of agricultural equipment which should be also be included
- Restrict the use of heavy equipment weighing less than 80,000 lbs.
Walt Ranch incorrectly compares the project noise to highway noise, in other words, construction generated traffic should be compared with traffic on local streets such as Circle Oaks Drive. The improper comparison shields an actual 10 dBA increase (perceived as a doubling of loudness). A doubling of loudness by a noise sensitive receiver (homes located next to Circle Oaks Drive) can elicit extreme concern or anger on the part of the receptor. (Eric Yee Report, page 2)
- Anticipated noise from truck traffic (see EIR Traffic Section 4.7.3-2) anticipates 38 one-way trips to and from Walt job site during peak AM and PM hours, some of which will be hauling rock and debris off-site.
- Mitigation Measure 4.8-1 does not address anticipated noise from dump or hauling trucks during construction or grape hauling during project operation (Eric Yee Report, page 1). Truck traffic will be as close as 40 feet from some residences, creating sound levels (86 dBA or higher) which exceed Federal and State standards (Eric Yee Report, page 1).
- Traffic concerns and noise level exceedance on Circle Oaks Drive can be resolved entirely by restricting ALL Walt Ranch vehicles to use of the alternate Walt entrance (Gate 1).
- Alternatively, sound monitoring equipment should be installed at Walt Ranch project’s sole expense at appropriate locations to monitor and record violations of Federal and State Noise standards.
Mitigation Measure (4.8-1) requires installation of temporary sound walls, where construction occurs less than 150 feet from sensitive receptors; no sound wall is require where construction occurs more than 150 feet away from sensitive receptors.
- As a practical matter and as stated by acoustics expert, Eric A. Yee of Salter and Associates (Eric Yee Report, page 2), installation of a temporary sound wall will not provide any desired relief from excess noise. According to Yee, “the barrier would need to be 10 feet taller than the highest source of noise” to have any positive effect which is impractical given the terrain.
- The better and more practical solution to help reduce noise pollution in Circle Oaks from construction activities are to implement noise reduction practices, when possible, on each individual piece of construction equipment utilized on the site. The MMRP requires mufflers and acoustic shields, but remains silent as to requiring use of rubber tracked equipment. Rubber track heavy equipment are much quieter during operation and are generally preferred in an agricultural application. The Walt project should contain an additional Condition of Approval requiring use of rubber tracked heavy equipment whenever possible.
Mitigation Measure 4.8-2 has been modified to accept the information provided by our Noise Expert, that the proposed blasting activity exceeds Cal Trans significance thresholds for vibration.
- No blasting is being permitted within 775 feet of residences, which has resulted in removal of from blasting activities from vineyard blocks 15, 16, and 68
- Vineyard Block 68 (Off Juniper Drive) has been removed from the Vineyard footprint and will no longer be developed, as a result of the blasting and access restrictions in place on Circle Oaks Drive (ECPA Approval Letter, Section 2.17: Concerns Regarding Block 68)
Note: Charles M. Salter and Associates Report by Eric A. Yee, submitted 3/29/2016 is incorrectly dated as 11/17/2014