Shareholders cite 39 failures to make complete disclosures about the Well #8 project. Part 2.

This is Part 2 of our 3-part series on the Well #8 Neighbors Group filing describing 39 deficiencies in City’s Initial Study and draft Mitigated Negative Declaration for the Well #8 permit application.  A permit may not be granted until the disclosure defects are remedied. Part 1 is here. The entire 21-page document includes text and graphics supporting the comments.

CONSTRUCTION NOISE IMPACTS

Comment #16. The statement in the MND/IS (page 79) that the “increase in noise levels would not be significant” is incorrect as written. Perhaps it would be true after mitigation.  This should be corrected because it is a summary conclusion.

Comment #17. The City’s limits on noise are misstated in both the MND/IS (pages 86-87) and in Appendix B, the Noise Impact Report (page 7), making uncertain whether the noise analysis is correct and the mitigation measures appropriate.

Comment #18. The Noise Impact Report fails to consider auxiliary sources of noise at the drill site, specifically the pump for drilling fluids, mechanisms for separating cuttings from drilling fluids, pipe clanging, and backup alarms.

Comment #19. The Noise Impact Report estimates noise levels at receptors based on noise levels measured 10 feet from an unidentified reference drilling rig, and there is no basis for believing that a drilling rig used on Well #8 would have similar noise characteristics.

Comment #20. Mitigation NV-1 requiring a muffler on the drilling rig should be revised to specify that the muffler shall be one specified at page 9 in the Noise Impact Study—if that is still an appropriate recommendation after adjusting for any double-counting.

Comment #21. The MND/IS does not address what, if any, additional noise mitigation measures are available to keep construction noise below the City’s limits if Mitigation NV-2 (requiring the site be surrounded by a 24-foot-tall sound barrier with a minimum STC rating of 30) is not sufficient in practice.

Comment #22. Mitigation measure NV-2 is a design standard that should be supplemented with a performance standard requiring the operator to do whatever is necessary to meet the City’s noise limits.

Comment #23, As an additional mitigation measure if the Project is approved, Crestview should be required to have a noise expert measure at the receptor points the noise levels actually caused by the Project when operating at its noisiest and certify those results to the City and neighbors at least 10 days before nighttime operations begin, and if the operation is out of compliance with the City’s noise standard it shall be brought into compliance before nighttime operations begin.

OPERATIONS NOISE IMPACTS

Comment #24. It is unlikely the pumphouse can meet the aesthetic design approved by City staff and also be an acoustically-rated enclosure specified by the noise impact consultant.

Comment #25. Proposed mitigation NV-3 in the MND/IS should be modified to require simultaneous conformity to the exterior of the building design previously submitted by Crestview.

Comment #26. The MND/IS does not consider what, if any, additional noise mitigation measures are available to bring operations noise down to the City’s limits if Mitigation NV-3 (requiring the pumphouse be an acoustic enclosure with minimum STC rating of 40) is not sufficient in practice.

Comment#27. Mitigation measure NV-3 is a design standard that should be supplemented with a performance standard requiring the operator to do whatever is necessary to meet the City’s noise limits.

Comment #28, As an additional mitigation measure, Crestview should be required to have a noise expert measure at the receptor points the noise levels actually caused by the Project when operating at its noisiest and certify those results to the City at least 10 days before nighttime operations begin, and if the operation is out of compliance with the City’s noise standard it shall be brought into compliance before nighttime operations begin.