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Air Quality & Greenhouse Gas Revised 2020-01-07Thursday, April 23, 2020 at 12:36:15 Pacific Daylight Time Page 1 of 1 Subject:AQ Memo for Wave Date:Tuesday, January 7, 2020 at 1:42:41 PM Pacific Standard Time From:Nicole Criste To:Kelly Clark Kelly, I forgot to ask last week: We need to add to the AQ memo that you wrote that AQ and GHG impacts need to address special events, consistent with the TIA. Can you make the addiNon for me please? Thanks! Nicole Thursday, April 23, 2020 at 12:36:57 Pacific Daylight Time Page 1 of 1 Subject:Revised AQ & GHG Memo for Wave Date:Tuesday, January 7, 2020 at 5:05:18 PM Pacific Standard Time From:Nicole Criste To:Cheri Flores CC:Nicole Criste AFachments:image001.png, The Wave AQ GHG Tech Memo 1.7.2020.pdf, The Wave AQ GHG Tech Memo 1.7.docx Cheri, The revised document, including the need for special events analysis as we discussed last week, is aQached for your review. 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 7, 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). 8. Special Events The Air Quality and Greenhouse Gas Reports did not analyze impacts from special events, which would generate significantly higher mobile-related emissions. The Air Quality and Greenhouse Gas Reports shall be updated to include a new CalEEMod run and analysis of special events using daily trips and trip rates consistent with the Traffic Impact Analysis. 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.