Do you have a project moving through the discretionary approval process that requires noise impact analysis? As many project proponents are finding out, the economic disruption caused by COVID-19 has fundamentally altered ambient noise conditions.
We can all confirm that current conditions are substantially quieter – almost eerily so! Comparing potential future project noise to an ambient baseline is not possible for the foreseeable future.
A few municipalities have begun issuing guidance for noise analysis during COVID-19. For instance, the City of San Francisco issued a guidance statement on May 14, 2020, which establishes existing ambient noise conditions while shelter in place orders are in effect.
Drawing upon the best practices being identified by municipalities, here are 5 steps to ensure that you are completing a legally defensible noise impact analysis given the current challenges.
1. Determine the nature of your particular project environment.
For proposed noise-sensitive land use development projects (i.e., residential or school projects), the need to establish the “baseline” ambient noise conditions is typically more critical than for other types of development.
2. Identify the project site surrounding land uses.
What would the dominant noise source in the project vicinity normally be? In most cases, the dominant noise source is traffic. If that is the case, and there are minimal stationary noise sources (i.e., commercial, industrial, or mechanical equipment noise sources) in the project vicinity, you can proceed with documenting the ambient noise environment through traffic noise modeling. However, if there is a chance that there are potential stationary noise sources that could also impact your project, then you may also need to model off-site stationary noise sources that, under “normal” conditions, could be impacting your project site.
3. Rely on existing documented noise conditions that occurred in the project vicinity prior to March 2020.
This can be done by identifying completed or ongoing projects near your project site from which you can source noise measurement data. This can include ambient noise measurement data found in the City’s General Plan, or any relevant Specific Plans. Of course, there are numerous challenges to using other data sources (e.g., noise data may not be presented using the appropriate metric, and/or information may not be available or hard to obtain). Such limitations or challenges should be documented in the noise analysis, and the data sources used should be cited.
4. Commit to taking ambient noise measurements once any applicable shelter in place order has been lifted.
If final approval of the environmental documentation has not occurred and the shelter in place order has been lifted, noise monitoring should be conducted to verify the accuracy of any noise analysis completed using the above recommended data sources.
5. Manage all of this in consultation with a qualified noise consultant.
Working with experienced noise technical staff helps to ensure your project is in compliance with local, state, and federal standards, including CEQA and NEPA, and that it will be valid once our economy resumes outside mass shelter in place orders.
The current pandemic has impacted people and organizations across all industries.
With no definitive end to stay at home orders, as well as uncertainty surrounding what day-to-day life will look like in a post-COVID-19 world, it is important to be able to model current noise impacts for the future. Using historical data, and collating it against evolving regulations is vital in creating a defensible analysis.
FirstCarbon Solutions [FCS] comprises over 100 individuals offering due diligence, technical analysis, planning, environmental compliance, permitting, and mitigation/monitoring services for public and private projects. FCS has more than 30 years of experience navigating the complexities of CEQA and securing project approvals. Contact us for a free consultation to learn more about how we can help with your specific requirements.
