Willdan & Terra Nova - Traffic Impact Analysis Comments 2019-12-031
Nichole Romane
From:Steve Libring <SLibring@willdan.com>
Sent:Wednesday, April 29, 2020 11:34 AM
To:Nichole Romane
Subject:Fw: Wave TIA comments
Attachments:The Wave TIA Comments 12.5.19.docx
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From: Nicole Criste <ncriste@terranovaplanning.com>
Sent: Tuesday, December 3, 2019 10:05 AM
To: Steve Libring <SLibring@willdan.com>; Cheri Flores <clflores@laquintaca.gov>
Cc: Nicole Criste <Ncriste@laquintaca.gov>
Subject: Wave TIA comments
Steve and Cheri,
My comments are attached. When you have reviewed and commented, and added your issues where needed, I can
revise and send out the memo.
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
December 5, 2019
The Wave – Coral Mountain
Traffic Impact Analysis Comments
1. The Specific Plan Amendment is for the entire Specific Plan area, on both the west and east
sides of Madison Street. The TIA must be modified to look at the entire project, including
the existing development’s trips and movements, the potential additional trips and
movements from build out of the east side, and the new trips and movements on the west
side.
2. The TIA project description is not adequate. The following needs to be described:
a. The entirety of the Specific Plan area, as described in #1, above.
b. The project description is inconsistent with the Specific Plan Amendment (SPA). The SPA
allows 750 residential units, while the TIA describes 600. The TIA must analyze
maximum potential development based on the SPA. Please note that this will change
not only total project numbers, but phase quantities as well.
c. The Phase descriptions are inconsistent with the project descriptions in both the TIA and
the SPA. The project description adds up to 600 housing units, the phasing description
592 units, and the SPA 750 units. The TIA must analyze the maximum allowed under the
SPA, and provide for existing and future units on the east side of the SPA. If the east side
of the SPA is currently calculated in the cumulative project analysis, it must be removed
from that analysis and added to the project analysis. Adjustments to the overall trip
generation for the project will result. Please see related comments below.
d. The project description must include a description of the General Plan Amendment and
Zone Change proposed (including descriptions and exhibits of existing and proposed
land use and zoning designations) to support the General Plan buildout analysis.
e. The Specific Plan allows short term vacation rentals, and calls them out specifically. The
number of short term rentals, and their associated trip generation characteristics (as
opposed to standard residential units) must be included in the analysis.
f. Specificity regarding the wave pool use must be added:
i. Is the wave pool to be open to the public? Based on trip generation and the
accompanying description on page 35, it appears that this is the case, since the only
external trips anticipated are for “off‐site lunch, wave pool employees, etc.” If the
surf pool is private, it must be so stated. If the surf pool is open to the public, the trip
generation rate will need to be adjusted (see #3 below).
ii. The average number of attendees per day on a typical day, a weekend day and a
special event day.
iii. There is no description of special events at the wave pool. Special events at the
wave pool must be described and analyzed in terms of attendees, distance of travel,
typical duration, anticipated number of events per year, etc.
g.
Commented [NC1]: Steve: I need you to read Section 3.6,
3.7, 3.8, 3.9, 3.10, 3.11 (Methodologies) to make sure they
are doing the work the way it should be done.
3. Urban Crossroads completed a Traffic Impact Analysis (TIA) for a resort surf wave pool
project in 2019. The trip generation for that project was developed based on analysis of
TIAs for similar projects in other locations, attendance at the surf pool, and other factors.
That trip generation rate should be used here, not a generic recreational facility trip
generation. It may need to be modified based on the characteristics of the project, as
described in #2, above. Further, the internal capture must be explained. The TIA assumes a
50% internal capture reduction for the surf pool. This must be explained based on a
properly detailed project description. Since it appears that the trip generation is currently
too low, it is likely that an increased trip generation will generate a lower internal capture
rate. Please note that if the trip generation rises, and additional outlying intersections are
affected (per City standard), they will need to be added to the analysis.
4. A separate analysis of special events under EAC and General Plan buildout conditions must
be provided. Please note that if special events affect freeway interchange(s) (based on City
and Caltrans standards), these interchange(s) will need to be analyzed.
5. The TIA must demonstrate that there is sufficient separation, per City standards, between
intersections (both signalized and unsignalized) on Madison Street and Avenue 58. If
minimum intersection spacing is not provided, its adequacy must be analyzed.
6. The TIA must clearly state that analysis was completed in conformance with Engineering
Bulletin 06‐13, and reference the requirements of the Bulletin throughout.
7. At multiple locations in the TIA, the discussion regarding impacts to the intersection of
Avenue 52 and Jefferson is flawed. First, the intersection is fully within the City of La Quinta,
so any preference by the City of Indio is irrelevant. Second, although La Quinta has in the
past considered a single lane roundabout to be preferred, if the project requires a second
lane to preserve acceptable LOS, this must be considered and analyzed, and mitigation
measures proposed. It is not acceptable to assume failure will continue if feasible mitigation
exists (which may include redesign of the roundabout). Alternatively, if the TIA when
revised still shows failure at this intersection, the project will be required to prepare an
Environmental Impact Report, and the City will need to consider adoption of Findings and a
Statement of Overriding Considerations.
8. Assumptions regarding fair share allocations are flawed. If the project triggers the need for
a traffic signal, the required signal will be installed by the project, and reimbursement will
be provided. Where this condition occurs, the fair share is the project’s percentage of traffic
on that intersection at the time the impact occurs, not 2040 traffic conditions. If the
intersection fails with or without project, the project’s fair share is the difference between
without and with project volumes at the Phase when the intersection fails, not 2040
conditions. The TIA must also include an analysis of when in project phasing each signal is
required, when it is funded and scheduled for installation in the CIP, and whether the CIP
Commented [NC2]: Steve: I cannot do the technical
analysis of whether they conform to the Bulletin. Please
take care of that and add any comments here.
Commented [NC3]: Cheri: Do we want to include here, or
leave it for later?
schedule will meet project needs. If these do not mesh, appropriate mitigation measures
must be included in the TIA.
9. The TIA references “recommendations” which are in actuality mitigation measures. Please
provide a Mitigation Measure section, eliminate the use of “should,” and tie the
construction of improvements to specific project events (initiation of grading, initiation of
construction, issuance of 1st, 10th, 100th building permit/certificate of occupancy, etc.).
References to “when warranted” must be eliminated, as they represent deferred
mitigation.
10. The Main Project Access and Madison Street require a traffic signal at General Plan build
out. There is no mitigation measure to that effect. This must be added to the document.
11. Provide a complete list of all improvements required by Phase, including road widening,
additional lanes, traffic signals, etc. in a tabular format, with trigger points (as enumerated
in #9 above). The TIA must clearly show in one central location, all improvements required
by the project and when they will be undertaken.
12. Throughout the document, please assure that references to the appropriate scenario are
made. For example, at the end of Section 1.5.3, which is a discussion of EAP conditions,
EAPC is referenced.