2021-07-06 CollinsSunday, August 8, 2021 at 08:50:37 Pacific Daylight Time
Page 1 of 3
Subject:Dra$ Environmental Impact Report Coral Mountain
Date:Wednesday, July 7, 2021 at 10:18:14 PM Pacific Daylight Time
From:Agnes Collins
To:consulIngplanner@laquintaca.gov
Dear Mayor and Council, and
Ms. Nicole Sauviat Criste, ConsulIng Planner
City of La Quinta
We, the La Quinta Residents for Responsible Development, are sending this leSer to express our concerns regarding
the Dra$ EIR that was released for Coral Mountain Resort.
At the outset, we wish to say that this document is beyond comprehension for the average resident of La Quinta.
The DRAFT EIR (DEIR) is not in keeping with the 2021 CEQA Statute and Guidelines
hSps://www.califaep.org/docs/CEQA_Handbook_2021.pdf, parIcularly those laid out in ArIcle 10. ConsideraIons in
Preparing EIRs and NegaIve DeclaraIons, as laid out here:
15140. WRITING
EIRs shall be wriSen in plain language and may use appropriate graphics so that decision makers and the public can
rapidly understand the documents.
This document is replete with redundancy - paragraphs and statements, obviously boilerplate, are inserted and re-
inserted throughout the document into various categories, where not necessary or where summaries might have
been acceptable.
We do see the summary of Environmental Impacts and MiIgaIon Measures TABLE 1-3. While this summary is useful,
the background informaIon regarding each secIon MUST be presented in a manner that a reader can understand.
The DEIR fails in this regard.
15141. PAGE LIMITS
The text of dra$ EIRs should normally be less than150 pages and for proposals of unusual scope or complexity should
normally be less than 300 pages
This statement speaks for itself.page1image56365184 page1image56450752 page1image56444800
The DRAFT EIR is well over 700 pages, not including Appendices.
This document is unnecessarily LARGE, primarily as a result of of the way it is wriSen - we refer you back to 15140
above.
15145. SPECULATION
If, a$er thorough invesIgaIon, a Lead Agency finds that a parIcular impact is too speculaIve for evaluaIon, the
agency should note its conclusion and terminate discussion of the impact.
The intrusiveness on the surrounding residenIal communiIes with, by way of example but not limited to, the:
Lights (including mulIple 80-foot towers and commercial glare from buildings and parking lots)
Page 2 of 3
Noise (during operaIon, and that associated with Special Events), and
AestheIcs (impacts on the views of Coral Mountain)
as presented in the DEIR with the pretext of supporIve “scienIfic studies/analysis”, is difficult to even read let alone
understand, and therefore to allow for our interpretaIon.
We are of the opinion that the declared “negaIve” impacts of the above in parIcular are essenIally speculaIve and
should be acknowledged as such.
The failure to do this greatly concerns us and many residents that we have talked with regarding the DEIR. The phrase
that comes to mind, no disrespect intended, is “smoke and mirrors”. This speaks to our concern
about the credibility of the some of the informaIon presented in the document.
15146. DEGREE OF SPECIFICITY
The degree of specificity required in an EIR will correspond to the degree of specificity involved in the underlying
acIvity which is described in the EIR.
An EIR on a project such as the adopIon or amendment of a comprehensive zoning ordinance or a local general plan
should focus on the secondary effects that can be expected to follow from the adopIon or amendment, but the EIR
need not be as detailed as an EIR on the specific construcIon projects that might follow.
We are of the opinion that the “details” of the DEIR obscure the focus on the secondary effects of the Project - in
other words, we as the readers, cannot see the “forest for the trees” and therefore have trouble understanding
exactly what it is that the DEIR is trying to say.
Every aSempt should have been made in the DRAFT EIR to ensure, going back to 15140 above, to ensure that the
informaIon contained is “rapidly understood” by the reader.
We would have liked to stand back upon receipt of the EIR and, a$er reading, say “WE MAY NOT AGREE... BUT WE DO
UNDERSTAND THE SECONDARY EFFECTS”.
As the EIR stands now, we are making it known to you that we are unable to do this.
15147. TECHNICAL DETAIL
The informaIon contained in an EIR shall include summarized technical data, maps, plot plans, diagrams, and similar
relevant informaIon sufficient to permit full assessment of significant environmental impacts by reviewing agencies
and members of the public.
Placement of highly technical and specialized analysis and data in the body of an EIR should be avoided through
inclusion of supporIng informaIon and analyses as appendices to the main body of the EIR.
Again, to our points noted. The technical data presented in the body of the DEIR is not summarized or organized in
such a manner as to allow for the understanding of the general reader.
In summary, from the CEQA Guidelines ...”The DEIR serves as a public disclosure document explaining the effects of
the proposed project on the environment, alternaIves to the Project, and ways to minimize adverse effects and to
increase beneficial effects”.
This is the framework that we looked forward to and expected to receive when the DEIR was released, nearly two
weeks ago.
Page 3 of 3
In essence, the proclamaIon of “no negaIve effects “ is evident throughout the document, but the informaIon that
is provided within the document to support those conclusions regarding the DEIR categories is virtually
undecipherable to us.
This is not fair. There is a Imed “Process” underway and we are the residents who will be impacted by this Project.
We require transparency please.
We require a complete understanding of exactly what is impacIng us and how. Any miIgaIon measures presented
must make sense.
If we, the general public, cannot understand the DEIR, how can we possibly respond accordingly in the manner
required of us? Conjecture and opinions will carry no weight.
We respecmully request that this DRAFT EIR be retracted and replaced.
The replacement document should be created with the following in mind - it should be reasonable in length, with
clear and concise language, and without unnecessary repeIIon. This would allow for “rapid” understanding by
readers, and thus it would be in alignment with the CEQA guidelines.
Thank you for your consideraIon of our request.
THE LA QUINTA RESIDENTS FOR RESPONSIBLE DEVELOPMENT
Agnes Hilsen Collins