2020-08-27 OPPOSED - BAUERS m VMEop
A T T O R N E Y S
BRUCE T. BAUER
ATTORNEY
ADMITTED IN CA
August 27, 2020
Via Email & U.S. Mail
Jon McMillen (jmcmillen@laquintaca.gov)
City Manager, City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Cheri Flores (clflores@laquintaca.gov)
Planning Manager, City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Nicole Sauviat Criste (ncriste@terranovaplanning.com)
Consulting Planner, City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
RE: The Coral Mountain Development / La Quinta Wave Park
Dear Mr. McMillen and Ms. Flores and Ms. Criste:
REPLY To:
1800 E. Tahquitz Canyon Way
Palm Springs, California 92262
T (760) 322-2275 • F (760) 322-2107
ba uer0sbemp.com
Our office represents certain homeowners in The Quarry Homeowners Association within
the City of La Quinta (the "City").
1. THE PROPOSED WAVE PROJECT
We write to you regarding the City's consideration of a proposed development in the City.
According to a press release issued in February 2020, Meriwether Companies and Big Sky
Wave Developments announced plans for Coral Mountain, a master -planned resort
community in the City. This project has come to be known the "Wave Project" because the
centerpiece of the project is to be the "world's largest artificial wave" emanating out of Kelly
Slater -designed wave basin which would hold about 18 million gallons of water.
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Palm Springs, CA Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322-2275 T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbem%com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 2
The proposed Wave Project requested by applicant, CM Wave Development, LLC (the
Applicant"), would include a sports and wellness community in the City would consist of a
full -service resort, residential homes, a private club, multiple dining venues and adventure
sport offerings. The $200 million proposed Wave Project complex would have a 150-room
hotel and up to 600 villa homes and would be situated on the grounds of what was a
proposed and entitled low -density, golf -centered master -planned community sometimes
referred to as the "Coral Mountain Project."
2. THE SCOPE OF THE PROPOSED WAVE PROJECT CONTINUES TO GROW
FAR BEYOND WHAT WAS FORSEEN IN PRIOR ENTITLEMENTS.
The scope of the Wave Project that the Applicant previously announced keeps growing.
We have learned that the Applicant has requested that, in addition to the wave pool, sports
park and 150-room hotel, that the City approve, 600 overnight rental villas (2 to 5 bedroom
each), four (4) entertainment/special events (of four (4) days duration or 16 days and
nights of special events per year) (the "Special Events"), and 60,000 square feet of
neighborhood commercial uses on 7.8 acres. With the requested additional changes, the
Applicant then is seeking permission to allow approval of an amusement and
entertainment sports park with an enormous amount of overnight guests in excess of 4,000
per night ((one can estimate that it might have 600 overnight guests for its planned 150-
room hotel (4 pillows per room x 150 rooms), plus 3,600 overnight guests for the planned
600-villas (averaging 3 bedrooms each, 6 pillows X 600=3,600 overnight), for a total over
4,000 overnight guests coming and going.) The Wave Project then promises to bring
significant changes to the City and its surrounding and adjoining communities compared to
what was previously approved for this area. Naturally, a project of this nature, that
continually morphs and increases exponentially should be given additional scrutiny.
In addition to the above activities of the hotel and villas, there are the 16 days of special
events that the Applicant has requested. Each day of these televised special events might
easily bring in tens of thousands (each event the Applicant would be permitted to have
2,500 guests per day — this would be in addition to the guests that are staying at the
resort's villas and hotel) of additional people per day (and that does not include the days
that will be needed for staging and dismantling of each of the weekend events.) We have
no idea whether these special events will be synchronized to coincide during the otherwise
busy Coachella and Stagecoach festival season — which would exacerbate and magnify
exponentially an already congested time of the year.
It is clear that the Wave Project bears NO relationship to the development that had been
originally entitled for that area. We are concerned, however, that the City may allow the
Applicant for the Wave Project to utilize existing entitlements, in part, that evaluated that
golf -centered master planning community back in 2003, to entitle the Wave Project that is
a development of an entirely different sort. The Wave Project is not akin to a low -density
golf -centered master -planned community. No one can seriously contend such. Rather,
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 3
the Wave Project is a "horse of a different color' entirely and should not be able to utilize
important components of existing entitlements such as an existing environmental impact
report and zoning. The Wave Project, in reality, will be largely a commercial endeavor and
not a residential development and will be more of an entertainment -based venue. The
Wave Project will be comprised of a commercial /high -density project that will cause far
more impact on the surrounding communities that could ever have been conceived in prior
entitlements. The Project is not in keeping with the existing zoning. The quiet and serene
atmosphere currently enjoyed by surrounding the residents in the City's neighborhoods will
be destroyed. Moreover, the Wave Project will impact traffic, noise, native wildlife, crime,
pollution, etc., in ways that could not have been conceived when the prior project was
approved.
As such, we do not believe the Wave Project, as proposed, should move forward with the
City since it is not in keeping with the character and entitlements envisioned by the City
and its residents. However, should the City consider the Wave Project it must do so under
only the most exacting review standards.
3. AT A MINIMUM THE PROPOSED WAVE PROJECT WILL REQUIRE A FULL-
SCALE EIR.
We have learned too that the City has indicated that it may well permit the Applicant to
evade a full blown EIR for the Wave Project. The City, in its June 2020, "Environmental
Initial Study" indicated its likelihood that it would issue a mitigated negative declaration for
the Wave Project (see, p. 12, of that document.) That would be grave error on the part of
the City. In so finding, the City necessarily would have to make a finding that that the
Project could have a "significant effect on the environment" however, it would have to have
found that there would not be a significant effect because revisions in the Wave Project
have been made by or agreed to by the Applicant. We cannot agree with that conclusion
given the scope and scale of the Wave Project.
We have concerns regarding the Wave Project and would urge the City adopt the following
requirements in connection with any of its entitlement approvals:
1) Require the developer submit a new full and complete environmental impact
report in connection with the Wave Project;
2) That in connection with any such EIR, the developer formulate mitigation
schemes to solve any potential noise and traffic problems with the Wave
Project;
3) That in connection with any such EIR, that all such related testing for any
possible mitigations measures be undertaken during normal traffic patterns
that one would find at "high" season (including festival season since the
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 4
Wave Project will be constructed near the grounds for the Coachella
Festival); and,
4) Finally, that in connection with any such EIR, that data from the Kelly Slater
Surf Ranch (located in Lemoore, CA), be used to analyze the Wave Project
and at a time when that facility is being fully utilized.)
In short, given the significant impact that the Wave Project promises to make to the City,
the City must insist upon the strictest review of the Wave Project going forward and cannot
abide by the issuance of a mitigated negative declaration by the City.
4. BACKGROUND AND NEED FOR FULL CEQA REVIEW AND AN EIR.
The Andalusia Specific Plan, in which the Wave Project occurs, was approved by the
County of Riverside in 1988 as part of the Rancho La Quinta Specific Plan. At the time of
the original County approval, the County also certified an environmental impact report (EIR
232 for SP 218)(the "1988 EIR") which included what are now the Trilogy and Andalusia
projects. That project would have resulted in 4,262 residential units, 380 acres of golf
course, and 35 acres of commercial development.
In 2000, the County approved Amendment # 1 to the Specific Plan, which renamed the
proposed project "Coral Mountain," reduced the maximum dwelling units to 2,762,
increased golf course lands to 567 acres, and decreased commercial lands to 23 acres. At
that time, the County also processed Addendum # 1 to EIR 232, and certified that
document.
In 2002, the entire Coral Canyon project was annexed into the City. As part of the
annexation process, the City accepted, as is the norm, the County' s approvals, and
agreed to allow development of the Coral Canyon Specific Plan per County approvals.
A. The Coral Mountain Project.
In 2003, the Andalusia Specific Plan, consisting of the northerly half of the Coral Mountain
Specific Plan, and allowing up to 1,400 residential units, 10 acres of commercial
development and 421 acres of golf course, was separated from the balance of the original
County Specific Plan. At that time, the City adopted Environmental Assessment 2003- 483
for the Specific Plan (the "2003 EIR".) As such, the Coral Mountain Project was conceived
as a residential master -planned community built around a golf course.
B. The Applicant's Acquisition of Coral Mountain and Re -Conception of
that Project into a Maior Entertainment Hub.
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 5
In May 2019, Meriwether Companies acquired Coral Mountain, a 400-acre land parcel (for
29M) located in La Quinta, CA in the eastern quadrant of the Coachella Valley. It became
immediately apparent that the Applicant had entirely different plans for Coral Mountain.
The Applicant conception of Coral Mountain had fundamentally changed into a vision that
it would be developed, instead, into a busy, commercial endeavor with a large influx of
overnight visitors and an entertainment hub.
On, September 12, 2019, a planning application for the Wave Project, also referred to
Andalusia West, was filed by the applicant, CM Wave Development, LLC (Garret Simon).
In that application, they sought the following items/approvals:
Tentative Tract Map
General Plan Amendment
Specific Plan Amendment
Zone Change
Environmental Assessment
In the City's letter to the Applicant, dated January 13, 2019 (in actuality the letter should
have been dated January 13, 2020), the City noted that the applicable existing CEQA
document for the Andalusia Specific Plan was the 2003 EIR, certified by the City in
December of 2003. Also as stated in that letter, the Applicant indicated its belief that the
Wave Project should be reviewed through an Addendum the 1988 EIR. The City found
correctly at the time of the January 13t" letter, that the information contained in 2003 EIR
was outdated. Moreover, the City correctly noted, as follows:
T]he information contained in [the 2003 EIR] is outdated, and did not
address greenhouse gas emissions, energy impacts, tribal cultural resources
or wildfire impacts at all. It also analyzed a golf- centered master planned
community and not a hotel or 15-acre surf pool. All of these changes and
unaddressed environmental issue areas are part of the CEQA documentation
process now and must be addressed if the City is to adequately analyze the
project under CEQA. Under Section 15164, an "addendum to an adopted
negative declaration may be prepared if only minor technical changes or
additions are necessary or none of the conditions described in Section
15152... have occurred."
The City was correct then. The 2003 EIR is not a proper starting point for a project of the
magnitude proposed by the Applicant. This conclusion is all the more important given
recent CEQA developments that now require a much more stringent review of the impact
of traffic on a proposed project.
We first discuss requirements of CEQA and, then, we will address how those requirements
must be satisfied for the Wave Project to be approved by the City.
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 6
C. CEQA Requirements.
CEQA requires that an agency analyze the potential environmental impacts of its proposed
actions in an environmental impact report ("EIR") (except in certain limited circumstances.)
The EIR is the very heart of CEQA. 14 CCR § 15003. "The foremost principle in
interpreting CEQA is that the Legislature intended [CEQA] to be read so as to afford the
fullest possible protection to the environment within the reasonable scope of the statutory
language." Communities for a Better Environment v. Calif. Resources Agency (2002) 103
Cal. App. 4th 98.
It is beyond dispute, then, that CEQA should apply to the Wave Project unless there was,
and is, an exemption to its requirements that would otherwise apply. Given the Wave
Project's expected dramatic impact on the public, there is no known exemption that would
apply here. Rather, given its dramatic impact, the need for a thorough CEQA analysis and
EIR of the Wave Project is underscored.
D. CEQA Has a Strong Presumption in Favor of EIR Preparation.
A strong presumption in favor of requiring preparation of an EIR is built into CEQA which is
reflected in what is known as the "fair argument" standard, under which an agency must
prepare an EIR whenever substantial evidence in the record supports a fair argument that
a project may have a significant effect on the environment. No Oil, Inc. v. City of Los
Angeles (1974) 13 Cal.3d 68, 75. 82; Friends of `B 'St. v. City of Haywood (1980) 106
Cal.App.3d 988, 1002.
The EIR is the primary means of achieving the Legislature's considered declaration that it
is the policy of this state to 'take all action necessary to protect, rehabilitate, and enhance
the environmental quality of the state.' [Citation.] The EIR is therefore 'the heart of CEQA.'
Citations.] An EIR is an 'environmental "alarm bell" whose purpose it is to alert the public
and its responsible officials to environmental changes before they have reached ecological
points of no return." Laurel Heights Improvement Assn. v. Regents of University of
California (1988) 47 Cal .3d 376, 392.
C. The 2003 EIR is not an Adequate Starting Point to Consider the
Project,
The City was right, in concluding that the above 2003 EIR was outdated and not a proper
starting point for the Wave Project. The Wave Project is significantly different in
comparison to Coral Mountain Project. There were, and are, significant differences in the
considerations of the 2003 EIR, the Coral Mountain project and the Wave Project. In the
2003 EIR, the developer analyzed a golf -centered master planned community
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 7
All of the unaddressed environmental issues of the Wave Project are part of the CEQA
documentation process now and must be addressed if the City is to adequately analyze
the Wave Project under CEQA.
Additionally, starting July 1, the California Environmental Quality Act will require projects in
California to account for how many new miles of automobile travel they produce, rather
than how much congestion they produce. CEQA will instead require developers to
measure how many miles of vehicle travel a project will produce. The effect on
cities may not be immediate, but it will be profound in the long run. It has the
potential to change the way planners consider projects, to end long-standing
practices that encourage car dependence, and to prioritize infill, mixed -use, and
transit -oriented development rather than sprawl and edge development.
L The Traffic Analysis Must Contain Certain Information.
Any traffic study that addresses the Wave Project's potential impact on traffic in the
surrounding area must address concerns under Senate Bill 743 (SB 743). SB 743 changes
the focus of transportation impact analysis in CEQA from measuring impacts to drivers, to
measuring the impact of driving. The change is being made by replacing level of service
LOS") with vehicle miles of travel (VMT) and providing streamlined review of land use and
transportation projects that will help reduce future VMT growth. This shift in transportation
impact focus is expected to better align transportation impact analysis and mitigation
outcomes with the State's goals to reduce greenhouse gas (GHG) emissions, encourage
infill development, and improve public health through more active transportation. Those
change were only recently adopted. The Natural Resources Agency finalized updates to
the CEQA Guidelines including the incorporation of SB 743 modifications. The Guidelines
changes were approved by the Office of Administrative Law and are now in effect.
The Wave Project is certainly not consistent with State guidelines to reduce GHG emissions
and enhancement of active transportation. Not only does any existing traffic study fail to
address the Wave Project's compliance with SB 743, it does not disclose potential impacts
from an increase in VMT.
ii. Negative Impacts to Sound G—uality from Noise from the
Wave Project will be Considerable.
The Applicant must also properly analyze and mitigate significant impacts from noise from
the Wave Project. As pointed out, the noise attendant to the Coral Mountain Project, and the
project envisioned by Applicant, are two entirely different projects. The former project
envisioned a quiet golf -based community with little noise emanating from that project. The
latter project, however, anticipates that the Applicant will be conducted concerts and hosting
large-scale surfing venues with music. The City enjoys an enviable quiet environment that
must be considered and not compromised in the manner sought by Applicant. The City
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 8
generally enjoys a quiet noise environment, with existing community noise being dominated
by highway and local traffic, intermittent aircraft flyovers, and commercial operations. Low
noise levels are considered to be a major economic asset of the City's resort and residential
atmosphere. As such, the City should carefully review proposals such as the Wave Project
which we believe to be incompatible with the quiet environment present in the City and that
it should be avoided.
The Wave Project would be located very close to many noise sensitive receptors,
including residential units. The type of development contemplated are known to
create many noise impacts, including noise from patrons shouting, operating stereos
in their cars, slamming doors, and honking in the drive-thru lane. Despite the City's
alleged committed to "quietude" in the City, it only discusses the potential impact of
the operational noise generated by the Wave Project in one short paragraph (most of
which only pertains to the construction of the Wave Project):
Construction of the Wave Project would generate sporadic, temporary
vibration effects adjacent to the Wave Project area but would not be
expected to exceed the significance thresholds. Operation of the Wave
Project would generate noise from project -related traffic or from on -site
sources (drive -through queuing, parking, amplified speech emanating
from the speaker and trash compactor) that would not exceed the
significance thresholds.
Agenda, Staff Report, p. 5-22.
The City has failed to properly analyze and mitigate significant impacts from noise.
As such, the City has not reasonably demonstrated that the Wave Project would not result
in significant impacts to noise quality and therefore does not qualify for the In -fill Exemption.
iii. Negative Impacts to Air Quality from the Wave Project
will be Considerable.
The Wave Project could result in significant impacts health effects from air quality
emissions. In Sierra Club v. County of Fresno (Friant Ranch, L.P.) (2018) 6 Cal.5th 502, the
Court held that air quality analysis must make a reasonable effort to substantively connect
a project's air quality impacts to likely health consequences. Any consideration of air quality
must address the health effects to nearby sensitive receptors from the large quantity of idling
vehicles consistent with a development of the type sought by Applicant. The analysis, in
order to actually demonstrate that there are no significant impacts to air quality, is required
to "connect" adverse human health effects to the levels of pollutants that would be emitted
by the Wave Project.
Jon McMillen, City Manager
Cheri Flores. Planning Manager
August 27, 2020
Page 9
CONCLUSION
Based on the above concerns, it is urged that the City does not approve the Wave Project
as proposed by Applicant. In any event, at a minimum, the City must require the Applicant
to submit a full environmental impact for the proposed Wave Project and, in any such
report, that the Applicant formulate mitigation schemes to solve any potential noise and
traffic problems at the Wave Project.
CC: Linda Evans, Mayor (levans@laquintaca.gov)
John Pena, Mayor Pro Tern Qpena@laquintaca.gov)
Kathleen Fitzpatrick, Council Member (kfitzpartick@laquintaca.gov)
Robert Radi, Council Member (rradi@laquintaca.gov)
Steve Sanchez, Council Member (ssanches@laquintaca.gov)