Construction Noise Thresholds

Think it’s Noisy Now? Just You Wait! (Text Version)

Welcome!

This is my first post on Substack. They tell me I should tell you a little bit about myself and the type of community I’m looking to build. Sorry, no time for that now. You can read all about me on the “About” page.

This post is to alert you about an urgent action needed to be taken regarding the Los Angeles Department of City Planning (DCP) and their actions to revise and update their California Environmental Quality Act (CEQA) thresholds. If you do not know, CEQA thresholds are the metrics by which a given impact is judged to be significant. The thresholds now under revision are for construction noise.

What’s the Issue?

The current noise threshold for daytime construction is 10 dBA (a measure of sound intensity) over background noise for activities lasting more than one day and 5 dBA over background for activities lasting more than 10 days in a three-month period.  The DCP proposes to remove the current threshold and instead set a maximum threshold of 80 dBA.  Here is the evidence offered to support this change (pg 7 of draft report):

What DCP leaves out is that anyone living near a major street is already exposed to a noise level of more than 65 dBA and a 5 dBA increase puts you at or above the USEPA suggested threshold of 70 dBA (a level where hearing loss begins to occur). Now, the DCP wants to expose you to levels of up to 80 dBA. Or how about this “evidence” as stated on page 12:

In other words, the DCP does not care about you. They are not revising thresholds to be more protective of your hearing, they are not revising thresholds based on new medical or scientific data, they are revising thresholds to serve developers. By raising noise thresholds so high, they eliminate a significant impact from the scope of CEQA so DCP can justify that the project is exempt from CEQA regulation.

What Can You Do?

You have until Monday Feb 19^th to provide written comments via email or hard copy. Your comments do not have to be long (I’m submitting 17 pages!), and it’s best if you can include your personal experience related to construction noise. Here’s an example:

Subject: Updated CEQA Thresholds
Dear City Planning Staff,
I do not support the proposed revisions to the construction noise and vibration thresholds. Our city is already too noisy and your report provides no medical evidence that an 80 dBA threshold is an acceptable limit. I do not support the revisions and I urge you to continue to follow the existing thresholds.

Send your comments via email to mindy.nguyen@lacity.org or by hard copy to Los Angeles City Planning, 200 N Spring St., Room 525, Los Angeles CA 90012.  Both email and hard copy must include reference to “Updated CEQA Thresholds.”

The Noisy Details

Have you sent in your email yet? Why not? The deadline is coming up and you need to take action now. If you’ve sent an email, thanks! If not, please consider sending it in soon. And if you want to know more, then read on.

In response to Executive Directive No 7 signed by Mayor Bass, the Department of City Planning is updating their 2006 CEQA Thresholds Guide. A draft report on construction noise and vibration and two sections dealing with historical and cultural resources have been issued for public comment.  No table of contents or project overview has been presented.  It’s fair to assume that DCP plans to gut the 2006 Guide so that fewer issues of concern are addressed, and fewer development projects trigger significant impact.

For example, the DCP proposes to remove the daytime construction noise threshold over ambient and instead set a maximum threshold of 80 dBA.  The 2006 Guide sets a threshold of 10 dBA over ambient for activities lasting more than one day and a threshold of 5 dBA over ambient for activities lasting more than 10 days in a three-month period.  To justify their position, the DCP offers this evidence:

Page 7 - “In other words, while a two- or three-year construction project could result in a 5 dBA impact for a single day, the conclusion that this should be considered a significant effect on the environment would be overly conservative, as the impact would be temporary in nature and not necessarily impactful to public health.”

Page 12 - “Furthermore, residents of urban areas are used to temporary construction noise and its increase to ambient noise levels of 10 to 25 dBA and higher, from time to time during daytime hours.“

Page 13 - “Daytime construction noise levels are further reduced by existing building codes for certain types of buildings.  For example, the State has established noise insulation standards for new multi-family residential units, hotels, and motels via the California Noise Insulation Standards (Title 24, California Code of Regulations).”

Of course, the report fails to provide any quantitative data as to noise level versus construction activity and the number of days the 5 dBA level was exceeded.  Or how about the following issues their report fails to address:

• Anyone living along a major street is exposed to a noise level of 67 dBA or more.  A 5 dBA increase exceeds the USEPA guidance threshold of 70 dBA which was set to avoid hearing loss.

• Exposure to noise can lead to various health issues such as heart disease, high blood pressure and stroke, ulcers, other digestive disorders, and mental health issues.  No attempt was made to review any medical literature in the study.

• Most of our housing stock predates 1939.  This is 35 years prior to the enactment of the State noise insulation standards for new building construction.

If any of this makes you mad, I urge you to reach out to DCP and voice your displeasure.  Tell the DCP that what they are doing isn’t right.  That you do not want protective CEQA thresholds weakened or removed, you want them strengthened and based on solid science.  That just because the public may be “use to” construction noise, that is not an excuse to justify the raising of thresholds to make permitting easier for developers and the DCP.

---