2021-06-22 HarringtonSunday, August 8, 2021 at 08:51:28 Pacific Daylight Time
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Subject:Coral Mountain Resort DEIR objec5ons
Date:Tuesday, June 22, 2021 at 5:25:49 PM Pacific Daylight Time
From:Monica Harrington
To:Consul5ng Planner
1.
2.
Eighty-foot light poles are incompa5ble with City Code under the approved use of the proposed site for the Coral
Mountain Surf Park, which is now zoned as low density residen5al, which is the same zoning that applies to
surrounding proper5es. And yet, in the EIS report, we learn that the illumina5on of outdoor recrea5onal facili5es is
exempt from the requirements of this sec5on and that passage is slipped in as though it's reasonable to think that
the zoning should be easily transformed into Recrea5onal Use, which is the zoning that applies to amphitheaters, ball
parks, etc.
Why doesn't this sec5on just come out and say: "The use of 80-foot light poles is ILLEGAL under the current zoning of
the property, so one way to get around this and to accommodate 80-foot light poles is to quietly change the
designa5on to "Recrea5onal" and thus get the same ligh5ng requirements that might apply to a huge outdoor
stadium or arena. And by the way, by doing this, you can ensure that the outdoor lights can stay on EVERY DAY un5l
10:00."
The authors of this study didn't write it that way because they wanted people to come away thinking that it's
reasonable that 80-foot lights opera5ng un5l 10:00 pm every night in a low density residen5al area is somehow
acceptable. It's not.
Some5mes, people agree to tradeoffs on sound/light because the recrea5onal benefits available to all are perceived
to be worth it. E.g., in some municipali5es, outdoor summer concerts are allowed a few 5mes a year in close
proximity to residen5al users, so long as the concerts end before 10:00. The idea is that for a few nights a year, the
tradeoff in noise and light in an otherwise quiet residen5al area might be worth it to add to the cultural
a_rac5veness of an area.
Here, there is NO benefit to surrounding communi5es of 80-foot-light poles or of an event venue that is ac5ve EVERY
evening un5l 10:00 pm. Surrounding communi5es get all of the light and noise intrusion, all of the 5me, with no
benefit.
Viewed in this way, the conversion of the exis5ng zoning for the property does not sa5sfy the zoning change
requirements embedded in La Quinta Municipal Law:
Required Findings. The following findings shall be made by the city council prior to approval of any zone
map change:
Consistency with General Plan. The zone map change is consistent with the goals,
objectives and policies of the general plan.
Public Welfare. Approval of the zone map change will not create conditions
materially detrimental to the public health, safety and general welfare.
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3.
4.
5.
Land Use Compatibility. The new zoning is compatible with the zoning on adjacent
properties.
Property Suitability. The new zoning is suitable and appropriate for the subject
property.
Change in Circumstances. Approval of the zone map change is warranted because
the situation and the general conditions of the property have substantially changed
since the existing zoning was imposed.
Sincerely,
M.M. Harrington, 58117 Carmona
From the EIS report,
Per Sec5on 9.100.150 of the LQMC, the illumina5on of outdoor recrea5onal facili5es, public and
private, (i.e. the Wave) is exempt from the requirements of this sec5on with the following limita5ons:
the light fixtures for outdoor recrea5onal facili5es shall meet the shielding requirements in the
Municipal Code; and no such outdoor recrea5onal facility shall be illuminated by nonconforming
means aher 10:00 p.m. except to conclude a specific recrea5onal or spor5ng event or any other
ac5vity conducted at a ballpark, outdoor amphitheater, arena, or similar facility in progress prior to
10:00 p.m. Because the opera5on of the project is governed by the Specific Plan rather than the
Municipal Code, and in order to assure that the opera5on of the Wave Basin will conclude at 10:00
p.m., compliant with the recrea5onal opera5onal hours allowed by the City of La Quinta, MiDgaDon
Measure AES-3 has been added. Therefore, with the implementa5on of MiDgaDon Measure AES-3,
impacts will be less than significant.