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2021-08-07 BachliMemo to: Nicole Sauviat Criste, Consulting Planner, City of La Quinta Copies to: La Quinta City Council TLQMA: Board of Directors From: Fritz E. Bachli, Professor / Consultant of Global Economics and Environmental Science Subject: Coral Mountain Wave Project / Draft EIR / Citizen Comment, Dead-Line: 8/6/2021 Date: August 6, 2021 Ladies and Gentlemen, The following perspective on the “Wave Project” is based on my educational background in the field of Environmental Sciences and thirteen years of living experience here at Trilogy. I am not surprised about the many concerns residents are voicing in opposition to the “Wave Park”? The City of La Quinta must be concerned about the environmental complaints which are piling up at the City Hall? Even re-zoning appears not a welcoming answer to accommodate the “Wave Park!” However, common sense reminds us: “If it’s not a fit – leave it!” It’s surprising that the Project applicant has not been able to locate a suitable alternative location in our city or elsewhere? The purpose of zoning is simple. It is designed to ensure balanced communities. Zoning allows the government to control development of the land and ensure the public is satisfied with their community. The Draft EIR claims that improving community health is one of the priorities of city government in order to sustain life which can be enjoyed by residents? If citizens believe it’s not a fit – the city hall should listen and not promote it! Hopefully my contributions will support the NOPs (Notice of Preparation) filed by concerned citizens. Following are three key points taken directly from the Draft EIR which are of major concern to me as a Trilogy Resident? 1. NOISE -The project will not generate operational noise levels that have any significant impact on any sensitive receptors including residents in the surrounding communities. Areas in the vicinity of the planned project are repeatedly defined as “Golf Course and Residential Communities!” Trilogy, perhaps other communities as well, belong to a category of housing which is not recognized as such in the Draft EIR? Trilogy with 1238 homes, housing approx. 2500 residents, existed long before the planned construction of a Wave Park! The City Council of LQ should recognize that 55+ Communities are the choice for many aging people who want to focus attention to their mental, emotional and physical wellbeing. These adults enjoy the serenity of quiet neighborhoods. 55+ adults often decide that the value of time is for elderly individuals the greatest asset that they possess. Disappointing enough, the Draft EIR does not recognize the needs expressed by residents who selected a 55+ community? Trilogy residents are accustomed to noise levels of approx. 30 dBA! It will literally be a “bad awakening” when they must live in an environment where 60 to 80 dBA is defined as the new normal! (Measuring Instrument: METERK / MK 09 / Sound Level Meter) 2. AIR QUALITY The National Heart Association classified the Southern Californian Counties as some, if not the worst, air quality regions in our nation! -The Wave Park is seven miles of the 1-10 freeway. The site is found outside the designated “blowsand” area but is still exposed to seasonal wind activities capable of producing fugitive dust from undeveloped ground conditions?” The Draft EIR is incomplete without reporting available Health Data documented in the annual Eisenhower Hospital and Imperial County Health Assessments and Improvement updates? This is a substantial oversight and a sign of ignorance towards the constituents exposed and complaining about an ever-increasing air contamination problem in the area? Fugitive dust readings on my own patio and tests conducted at locations of Trilogy residents who are hypersensitive to dust and suffering from pulmonary diseases are often exposed to PM-2.5 particles at a level of 31.0 mg/3 and in terms of PM-10 particles of 110.2 mg/m3. (Measuring Instrument: Dylos 1700) Such levels can be compared with a very bad “hair day” in Beijing / China! Elevated PM-10 and PM- 2.5 levels are associated with increases of asthmatic conditions, increase in Emergency Room visits and increased mortality rates. Air Quality Standards considered safe and obtained from AQMD are taken from monitoring stations in Palm Springs 18 miles southeast from the project, the Indio station is 6 miles away and the distance to Mecca amounts to 11 miles. Air quality is a very local phenomenon and measurements taken miles away from the project are not representative of the actual situation as it is occurring at the project site and at individual sites of sensitive receptors. Special events, four times a year, with a daily expectancy of 2500 “Wave Park” guests, thousands of visitors per year will unquestionably contribute to a further overload of environmental conditions for the area right across the street from the Trilogy community! Mobile measuring devices which provide immediate on-site particle readings are becoming household items! Some time ago, I demonstrated to an AQMD team from the City Hall of La Quinta during a visit to the Golf Course Perimeter a slide presentation and test methods I used to measure PM-10 and PM-2.5 particle loads at the Trilogy community. They were surprised about the immediate results with handheld high quality measuring devices and the accurate readings when compared with fixed measuring stations. -SCAQMD has the legal obligation to enforce air pollution regulations!” From the moment a legitimate complaint is filed, and actions taken by the AQMD may literally take weeks, months or even years. Very frustrating process which might have been improved when compared in previous years? -LST’s (Localized Significance Threshold) limits were developed in response to environmental justice and health concerns raised by the public regarding the exposure to individuals to criteria pollutants in local communities. Is Trilogy qualifying for such an exemption? 3) WATER --The Wave Park could result in cumulatively significant impacts to water supplies and infrastructure if not reviewed by the City and CVWD? I wish there would be more concrete definition in the (Draft EIR) like this one. An eye opener for ordinary residents without in depth knowledge in the field of water issues! A surfer confessed to me that Wave Parks are fun. But pulling ground water especially in the desert and deleting aquifers is against all common-sense Environmental principles. Such water is not being used to benefit a society. It’s being used for middle, upper financial elite classes for leisurely escapism. AKA a vacation while the world burns, farm animals have to be slottered due to lack of food and water. The greenhouse effect takes its tall! CONCLUSION/ REASON: Fugitive Dust from Project Site to Trilogy Dylos Particle Meter / Model 1700 THE PROJECTED WAVE PARK IS NOT A PLANNED COMMUNITY THAT COMPLIMENTS EXISTING DEVELOPMENTS IN THE SURROUNDING AREA AND IS CONTRIBUTING TO THE ALREADY EXISTING ENVIRONMENTAL OVERLOAD IN THE SURROUNDING ENVIRONMENT. This Photo by Unknown Author