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Air Quality & Greenhouse Gas Report 2020-01-02Tuesday, April 21, 2020 at 13:26:33 Pacific Daylight Time Page 1 of 1 Subject:RE: Wave AQ & GHG Report Analysis Date:Thursday, January 2, 2020 at 9:19:31 AM Pacific Standard Time From:Cheri Flores To:Nicole Criste ACachments:image002.png, image001.jpg Hi Nicole Let’s chat about this today also before sending it on to the applicant. Cheri L. Flores | Planning Manager City of La Quinta 78495 Calle Tampico La Quinta, CA 92253 Ph. 760-777-7067 www.laquintaca.gov PLEASE NOTE: City Hall will be closed on December 31st, 2019 and January 1st, 2020. Please plan accordingly for any business needs that might need to be addressed during this time frame. We thank you for your understanding and look forward to seeing you next year! From: Nicole Criste <ncriste@terranovaplanning.com> Sent: Thursday, January 2, 2020 9:14 AM To: Cheri Flores <clflores@laquintaca.gov> Subject: Wave AQ & GHG Report Analysis ** EXTERNAL: This message originated outside of the City of La Quinta. Please use proper judgement and cauVon when opening aXachments, clicking links or responding to requests for informaVon. ** Cheri, See aXached memo from Kelly regarding the air quality and GHG analysis. May I send it on to the project team? Nicole Sauviat Criste Principal  TERRA NOVA PLANNING & RESEARCH, INC.® 42635 Melanie Place, Ste 101  PALM DESERT, CA 92211  (760) 341-4800  FAX#: 760-341-4455  E-Mail: ncriste@terranovaplanning.com TERRA NOVA PLANNING & RESEARCH, INC. ® 42635 MELANIE PLACE, SUITE 101, PALM DESERT, CA 92211 (760) 341-4800 TECHNICAL MEMORANDUM January 2, 2020 TO: Nicole Criste, Principal Planner FROM: Kelly Clark, Associate Planner RE: Review of the Air Quality and Greenhouse Gas Reports for The Wave – Coral Mountain, La Quinta The purpose of this memorandum is to provide comments on the Air Quality and Greenhouse Gas Reports and analysis for The Wave – Coral Mountain Project. Project Summary The Project consists of a master planned themed resort comprised of a recreational pool (wave pool), a 150-key hotel, 104 attached dwelling units (DU), 496 detached DUs, 60,000 square feet of retail, a pop-up village park, and a total of 265 parking spaces. The Project is anticipated to be constructed in three phases, with buildout occurring in late 2026. Phase 1 (2021) includes the resort (wave pool and hotel uses), 96 attached DUs, 38 detached DUs, and 10,000 square feet of retail use. Project Phase 2 (2023) adds 25,000 square feet of retail. Project Phase 3 (2026) adds 462 detached DUs and 30,000 square feet of retail use. CalEEMod Version 2016.3.2 was used to calculate construction-source and operational-source criteria pollutant (VOC, NOx, SOx, CO, PM10, and PM2.5) and GHG emissions from direct and indirect sources. Comments and Questions In general, the Air Quality and Greenhouse Gas Reports analyzed Project emissions against the appropriate SCAQMD thresholds. However, there are questions regarding CalEEMod inputs and emission projections for the Project. 1. Construction Hauling Currently, the Air Quality and Greenhouse Gas Reports do not account for “hauling” emissions because “earthwork activities are expected to balance on site and no import or export of soils would be required” (AQ Report, pg 27). Two comments: December 5, 2019 Page 2 of 4 I. The preliminary grading plan shows a subtotal cut/fill of 896,838 CY/918,759 CY with an import of 21,920 CY (see screenshot below). If the cut and fill calcs balanced on- site, that would still require an import of 21,920 CY, which was not accounted for in the construction hauling emissions and will require a re-run of CalEEMod. Haul trips should consider actual haul locations to determine miles per haul. CalEEMod assumes a 20-mile haul trip, one-way. This may need to be adjusted for accuracy. Also, the CalEEMod re-run will need to be specific about which Phase(s) will require material import. II. It is unclear how the balanced earthwork material is divided amongst the three separately phased site plans and whether or not this division would have an impact on material being hauled from one phase area to another. This could potentially result in a 0.3-0.75-mile haul trip depending on the location of earthwork and stockpile area. For example, Phase 1 will generate substantial cut in order to dig the wave pool. If all cut is to remain on Phase 1 property, the analysis is adequate, but an explanation must be added. If, on the other hand, Phase 1 cut is being moved to Phase 3 property, hauling must be incorporated into the analysis. Please provide further explanation and re-run CalEEMod, if necessary. 2. Sensitive Receptors The sensitive receptor analysis in the Air Quality Report does not consider the addition of Phase 1 sensitive receptors (new residences, hotel guests) when Phases 2 and 3 are being constructed. The Air Quality Report, specifically section 3.6 Localized Significant – Construction Activity, should be updated accordingly to include the sensitive receptors present on the property when each subsequent phase is constructed. 3. Vehicle Miles Traveled (VMT) It does not appear that a VMT analysis was prepared, or a general VMT assumption made, for the hotel and wave pool land uses. Default VMTs (CalEEMod) were used in both reports that are similar to those of residential and commercial land uses (5.4 – 12.5 miles per trip), which is equivalent to traveling from Palm Springs. It is anticipated that the wave pool and hotel will attract regional attention, meaning passenger vehicles would likely be traveling from greater distances such as the Los Angeles or San Diego areas, which are approximately 130 miles west of the Project area. The default trip miles do not adequately account for emission impacts associated with the typically long-distance travel associated with hotel uses or the proposed wave pool. Therefore, the December 5, 2019 Page 3 of 4 air quality and greenhouse gas emission projections and impacts should be reevaluated to include VMTs more appropriate for the hotel and wave pool land uses. 4. Project Buildout Year The following paragraph is located on page 43 of the Greenhouse Report: “As previously noted, the 2017 Scoping Plan identifies a reduction target of 40% below 2020 levels by 2030. As such, the appropriate reduction target for 2030 would be 2.88 MTCO2e/yr. For analysis purposes herein, the SP threshold for the Project’s buildout year of 2026 was calculated by linear interpolation between the 2020 target of 4.8 MTCO2e/yr and the 2030 target of 2.88 MTCO2e/yr. As such, the target for the Project’s buildout year of 2021 is 3.65 MTCO2e/yr.” Please confirm if the buildout year cited in the last sentence is in fact 2021, or if it is supposed to be 2026. Please recalculate SP threshold and reassess Project impacts for 2026 if necessary. 5. Wave Pool Energy Demand and Emissions It is unclear if the energy demand and emissions of the wave pool equipment was accounted for in CalEEMod. The wave pool will have an unusually high energy demand which should be calculated based on existing operations at other facilities. Please provide further analysis and explanation of this energy demand. Re-run CalEEMod with Project-specific energy demand numbers, if necessary. 6. Wave Pool Water Demand and Emissions It is stated that water demand projections are based on default CalEEMod values for a “recreational swimming pool” (CalEEMod output notes for Phase 3 Operations). Intuitively, this assumption is incorrect because it does not account for wave pool daily water loss, evapotranspiration for a pool of the proposed size, annual cleanings or repairs that may require full drainage and re-fills, etc. Further analysis should be conducted for water demand (which should be consistent with the Water Supply Assessment for the project) and specific water demand calculations should be applied to CalEEMod. December 5, 2019 Page 4 of 4 7. New “Vehicle Trips” Values in CalEEMod It is unclear why the following defaults were adjusted in CalEEMod. Please provide further explanation. Below is a screenshot of an example (from left, default values in 3rd column and new values in 4th column). Please provide the Project’s CalEEMod excel file for review in addition to the responses to this memo. If you have any questions, please do not hesitate to contact me, Kelly Clark, at 760-341- 4800 or by email at kclark@terranovaplanning.com. Thursday, April 23, 2020 at 12:33:07 Pacific Daylight Time Page 1 of 2 Subject:Re: The Wave Tech Memo Date:Thursday, January 2, 2020 at 8:30:04 AM Pacific Standard Time From:Nicole Criste To:Kelly Clark ACachments:image001.png, image002.png, image003.png, The Wave AQ GHG Tech Memo.docx Kelly, Nice job! I’ve made some minor edits. Please review, and if you’re OK with them, finalize, and I’ll provide to Cheri. Thanks! Nicole Nicole Sauviat Criste Principal  TERRA NOVA PLANNING & RESEARCH, INC.® 42635 Melanie Place, Ste 101  PALM DESERT, CA 92211  (760) 341-4800  FAX#: 760-341-4455  E-Mail: ncriste@terranovaplanning.com From: Kelly Clark <kclark@terranovaplanning.com> Date: Friday, December 27, 2019 at 2:18 PM To: Nicole Criste <ncriste@terranovaplanning.com> Subject: Re: The Wave Tech Memo Here ya go – I added sensi_ve receptors to the mix. From: Nicole Criste <ncriste@terranovaplanning.com> Date: Friday, December 27, 2019 at 2:00 PM To: Kelly Clark <kclark@terranovaplanning.com> Subject: Re: The Wave Tech Memo Do you want to tweak the memo and resend? Nicole Sauviat Criste Principal  TERRA NOVA PLANNING & RESEARCH, INC.® 42635 Melanie Place, Ste 101  PALM DESERT, CA 92211  (760) 341-4800  Page 2 of 2 FAX#: 760-341-4455  E-Mail: ncriste@terranovaplanning.com From: Kelly Clark <kclark@terranovaplanning.com> Date: Friday, December 27, 2019 at 1:59 PM To: Nicole Criste <ncriste@terranovaplanning.com> Subject: Re: The Wave Tech Memo Also – a thought just crossed my mind. Because the project is being built in phases, that means construc_on would be occurring near sensi_ve receptors in the Phased areas AND they would need to combine opera_onal and construc_on emissions for max daily emissions. Right now the emissions don’t show any overlap of op and const. From: Nicole Criste <ncriste@terranovaplanning.com> Date: Friday, December 27, 2019 at 1:27 PM To: Kelly Clark <kclark@terranovaplanning.com> Subject: Re: The Wave Tech Memo Thanks! Nicole Sauviat Criste Principal  TERRA NOVA PLANNING & RESEARCH, INC.® 42635 Melanie Place, Ste 101  PALM DESERT, CA 92211  (760) 341-4800  FAX#: 760-341-4455  E-Mail: ncriste@terranovaplanning.com From: Kelly Clark <kclark@terranovaplanning.com> Date: Friday, December 27, 2019 at 1:18 PM To: Nicole Criste <ncriste@terranovaplanning.com> Subject: The Wave Tech Memo Nicole- adached is the drae tech memo for the Wave project in La Quinta. Please let me know if you have any ques_ons/would like to discuss. Thanks! AQ/GHG Comment 2. (Sensitive Receptors): The current LST analysis already uses the shortest distance interval of (25 meters/82 feet) for sensitive receptors. The current level of emissions analysis would also apply to project homes occupied while Phases 2 and 3 are under construction since some of these would be within the same distance interval. Additional discussion can be provided by UXR to disclose the location of such sensitive receptors as they occur in a phased manner. Comment 3. (Vehicle Miles Traveled): The calculation of VMT for hotel and wave pool uses beyond the CalEEMod default values may be deemed too speculative for evaluation, unless an updated methodology is employed for the TIA, such that it can also be incorporated consistently into the AQ/GHG report. Biological Comments 2. Performance standards are included in the bat conservation plan and not a separate set of standards. Comment 3. This is a preference comment. Technical reports can make recommendations. Mitigation is ultimately addressed by the CEQA document and City. Noise Comment 6. This is a preference comment. Technical reports can make recommendations, mitigation is ultimately addressed by the CEQA document and City. Comment 11. Does not give a reason for why text needs to be deleted. Comment 12. The court Case is not out of context. It cites a CEQA court case for why there is no single noise that renders noise impacts as significant. The report then proceeds to provide an example. Comment 15. The noise analysis covers the phasing for the project. This comment can be addressed by a minor revision to wording by UXR. Comment 16. The paragraph is in in line with the discussion on the proceeding page. Comment 20. This is a preference comment. Technical reports can make recommendations, mitigation is ultimately addressed by the CEQA document and City. Comment 21. The whole report is a quantified analysis of the projects noise impacts. UXR can add an additional discussion to sensitive receptors as they occur in a phased manner. Commented [NC1]: That is sufficient, as long as we address phased development. Commented [NC2]: Since the TIA calculated VMT, the AQ report should use those calculations. That is all we are asking. Commented [NC3]: Under CEQA, if the performance standards for a mitigation measure are not included, an opposing party has grounds to both attack the mitigation measure as insufficient, and to claim deferred mitigation, since the study and IS do not demonstrate the effectiveness of the mitigation. Commented [NC4]: This was not an issue for the TIA, where Urban agreed to change their “recommendations” to mitigation measures. The biologist is the expert, and should be including requirements for mitigation measures to demonstrate that the project has mitigated its impacts. That is not the function of either the IS writer or the City. Commented [NC5]: See previous comment – a noise engineer is an expert, not MSA or the City. Commented [NC6]: The report makes the discussion of impact unduly convoluted. A simple discussion of what is perceptible and what is excessive is all that is needed. Commented [NC7]: There is no discussion on page 55, it is a Table. If the applicant does not want to clarify the technical study, that is his choice. Commented [NC8]: See previous comments regarding expert technicians. This was not an issue for the TIA, so I do not see why it is an issue here. Commented [NC9]: The analysis does not discuss or quantify what the impacts to Phase 1 residents will be from Phase 2 construction. That analysis must be added. Grading & Hydro Comments 1. Construction Hauling. Understanding Grading and volumes will let you know this is irrelevant questions since the volume discussed is less than 10% (2” on the site) of the margin of error. We say it balances on site she should believe us. Comment 2. Sensitive Receptors you don’t normally monitor/mitigate short term impacts of construction except with normal City ordinances when you can start & when you need to stop work. No need for anything more. Comment 4 VMT using LA & SD as an anticipated trip is excessive and not normal. Unless this City want to make it so. Comment 5 Wave Pool Energy Demands irrelevant if IID is ok to provide. We are not proposing Co-Gen at this time (are we?) Comment 6 Wave Pool Water Demands also irrelevant with CVWD acceptance of the WSA Comment 8 Special Events no reason to study this today. TUP will provide all mitigation based on the event and necessity Comments on the actual plan should be reviewed by an Engineer that understands what the difference between the pads to the 100yr water surface elevation and a high point in a road TERRA NOVA PLANNING & RESEARCH, INC. ® 42635 MELANIE PLACE, SUITE 101, PALM DESERT, CA 92211 (760) 341-4800 TECHNICAL MEMORANDUM December 27, 2019 TO: Nicole Criste, Principal Planner FROM: Kelly Clark, Associate Planner RE: Review of the Air Quality and Greenhouse Gas Reports for The Wave – Coral Mountain, La Quinta The purpose of this memorandum is to provide comments on the Air Quality and Greenhouse Gas Reports and analysis for The Wave – Coral Mountain Project. Project Summary The Project consists of a master planned themed resort comprised of a recreational pool (wave pool), a 150-key hotel, 104 attached dwelling units (DU), 496 detached DUs, 60,000 square feet of retail, a pop-up village park, and a total of 265 parking spaces. The Project is anticipated to be constructed in three phases, with buildout occurring in late 2026. Phase 1 (2021) includes the resort (wave pool and hotel uses), 96 attached DUs, 38 detached DUs, and 10,000 square feet of retail use. Project Phase 2 (2023) adds 25,000 square feet of retail. Project Phase 3 (2026) adds 462 detached DUs and 30,000 square feet of retail use. CalEEMod Version 2016.3.2 was used to calculate construction-source and operational-source criteria pollutant (VOC, NOx, SOx, CO, PM10, and PM2.5) and GHG emissions from direct and indirect sources. Comments and Questions In general, the Air Quality and Greenhouse Gas Reports analyzed Project emissions against the appropriate SCAQMD thresholds. However, there are questions regarding CalEEMod inputs and emission projections for the Project. 1. Construction Hauling Currently, the Air Quality and Greenhouse Gas Reports do not account for “hauling” emissions because “earthwork activities are expected to balance on site and no import or export of soils would be required” (AQ Report, pg 27). Two comments: December 5, 2019 Page 2 of 4 I. The preliminary grading plan shows a subtotal cut/fill of 896,838 CY/918,759 CY with an import of 21,920 CY (see screenshot below). If the cut and fill calcs balanced on- site, that would still require an import of 21,920 CY, which was not accounted for in the construction hauling emissions and will require a re-run of CalEEMod. Haul trips should consider actual haul locations to determine miles per haul. CalEEMod assumes a 20-mile haul trip, one-way. This may need to be adjusted for accuracy. Also, the CalEEMod re-run will need to be specific about which Phase(s) will require material import. II. It is unclear how the balanced earthwork material is divided amongst the three separately phased site plans and whether or not this division would have an impact on material being hauled from one phase area to another. This could potentially result in a 0.3-0.75-mile haul trip depending on the location of earthwork and stockpile area. For example, Phase 1 will generate substantial cut in order to dig the wave pool. If all cut is to remain on Phase 1 property, the analysis is adequate, but an explanation must be added. If, on the other hand, Phase 1 cut is being moved to Phase 3 property, hauling must be incorporated into the analysis. Please provide further explanation and re-run CalEEMod, if necessary. 2. Sensitive Receptors The sensitive receptor analysis in the Air Quality Report does not consider the addition of Phase 1 sensitive receptors (new residences, hotel guests) when Phases 2 and 3 are being constructed. The Air Quality Report, specifically section 3.6 Localized Significant – Construction Activity, should be updated accordingly to include the sensitive receptors present on the property when each subsequent phase is constructed. 3. Vehicle Miles Traveled (VMT) It does not appear that a VMT analysis was prepared, or a general VMT assumption made, for the hotel and wave pool land uses. Default VMTs (CalEEMod) were used in both reports that are similar to those of residential and commercial land uses (5.4 – 12.5 miles per trip), which is equivalent to traveling from Palm Springs. It is anticipated that the wave pool and hotel will attract regional attention, meaning passenger vehicles would likely be traveling from greater distances such as the Los Angeles or San Diego areas, which are approximately 130 miles west of the Project area. The default trip miles do not adequately account for emission impacts associated with the typically long-distance travel associated with hotel uses or the proposed wave pool. Therefore, the Deleted: for Deleted: Phase 1 Deleted: ing December 5, 2019 Page 3 of 4 air quality and greenhouse gas emission projections and impacts should be reevaluated to include VMTs more appropriate for the hotel and wave pool land uses. 4. Project Buildout Year The following paragraph is located on page 43 of the Greenhouse Report: “As previously noted, the 2017 Scoping Plan identifies a reduction target of 40% below 2020 levels by 2030. As such, the appropriate reduction target for 2030 would be 2.88 MTCO2e/yr. For analysis purposes herein, the SP threshold for the Project’s buildout year of 2026 was calculated by linear interpolation between the 2020 target of 4.8 MTCO2e/yr and the 2030 target of 2.88 MTCO2e/yr. As such, the target for the Project’s buildout year of 2021 is 3.65 MTCO2e/yr.” Please confirm if the buildout year cited in the last sentence is in fact 2021, or if it is supposed to be 2026. Please recalculate SP threshold and reassess Project impacts for 2026 if necessary. 5. Wave Pool Energy Demand and Emissions It is unclear if the energy demand and emissions of the wave pool equipment was accounted for in CalEEMod. The wave pool will have an unusually high energy demand which should be calculated based on existing operations at other facilities. Please provide further analysis and explanation of this energy demand. Re-run CalEEMod with Project-specific energy demand numbers, if necessary. 6. Wave Pool Water Demand and Emissions It is stated that water demand projections are based on default CalEEMod values for a “recreational swimming pool” (CalEEMod output notes for Phase 3 Operations). Intuitively, this assumption is incorrect because it does not account for wave pool daily water loss, evapotranspiration for a pool of the proposed size, annual cleanings or repairs that may require full drainage and re-fills, etc. Further analysis should be conducted for water demand (which should be consistent with the Water Supply Assessment for the project) and specific water demand calculations should be applied to CalEEMod. 7. New “Vehicle Trips” Values in CalEEMod Deleted: or Deleted: has a Deleted: been Deleted: prepared and approved? December 5, 2019 Page 4 of 4 It is unclear why the following defaults were adjusted in CalEEMod. Please provide further explanation. Below is a screenshot of an example (from left, default values in 3rd column and new values in 4th column). If you have any questions, please do not hesitate to contact me at 760-341-4800 or by email at kclark@terranovaplanning.com. Deleted: for