2021-07-13 RebrynaDiane Rebryna, B.Sc.,D.D.S.
60149 Honeysuckle Street,
La Quinta, CA
92253
Attention: Ms. Nicole Sauviat Criste
Consulting Planner
BY EMAIL:
Good day Ms. Sauviat Criste,
Thank you for your email of this morning, July 13, 2021 with your explanation as to why the
current DEIR (also “the Document”) will not be retracted and reissued, and advising us that
accordingly there would be NO extension beyond the August 6, 2021 date for comments.
Perhaps the City has “carefully and thoroughly reviewed the proposed Project”, but I believe that
you are missing the point of my request.
Please understand that while a complex Project such as this requires analysis from the City’s
perspective, it must also be presented in such a manner to allow for a detailed analysis by
the public and also allow for “rapid understanding”.
I would again like to state that the document in its present format does not provide for this,
mostly due to its length, repetitiveness and redundancy. I will not repeat again the reasoning
behind our initial request of July 2, 2021.
I gather from your email that you feel that the document is “not unduly scientific or complex”.
For reasons that I will not go into, I respectfully disagree; however the purpose of my response
herein is not to argue.
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I do propose a compromise please, particularly with respect to the Sections in Chapter 4.
Environmental Impact Analysis. I would like to see the 5 following items considered :
1.An expanded Table of Contents for Chapter 4.
***These 15 Sections are essentially the “meat and potatoes” of the DRAFT EIR
As the document stands, the Table of Contents for a 700 plus page Document is not at all
helpful.
By way of example, in the Section regarding Aesthetics (4.1) which comprises 73 pages (4.1.1-
4.1.72), I note 6 Subsections. These are:
4.1.1 Introduction,
4.1.2 Existing Conditions,
4.1.3 Regulatory Setting,
4.1.4 Project Impact Analysis
4.1.5 Cumulative Impacts, and
4.1.6 Mitigation Measures
However, when I go to the Table of Contents, I see ONLY “4.1 Aesthetics” referencing the
entire 73 page.
I ask please - why would the Sections relevant to each Chapter not be included ? - please see
2. below
2. Inclusion of the Subsections and Tables in the Table of Contents - with numbers,
letters and bullets as appropriate and appropriately cross referenced to pages in the
Document.
It is the subsections that pose an issue for the average reader such as myself.
For instance, when I proceed to go through Section 4.1.4 Project Impact Analysis, I note
the following “Subsections”
Thresholds of Significance
Methodology
Proposed Project
Character and Development Standards
PA I
PA I I
PA II I
PA IV
Circulation
Design Guidelines
Planning Area I - Neighborhood Commercial
Materials
Planning Area II - Low Density Residential
Materials
Massing and Scale
Architecture
Planning Area III - Tourist Commercial
Materials
Massing and Scale
Architecture
Planning Area III - Tourist Commercial
Offsite Infrastructure
Project Impacts
a. Have a substantial adverse effect on a scenic vista ?
Location “A”
Location”B”
….. all in different fonts, different sizes, some italics, some not, non indented,
etc. ; and these are in only the first 25 pages of the 73 for this Section !
I believe that you can see where I am going with this “illustration” above. This is not an easily
readable document, but in particular it is not an easy document to reference and therefore
understand.
My example refers to just Section 4.1.4 - the layout therein is the same throughout the
entire Document.
From my particular perspective as I conduct my review, I found that I am required create
my own “table of contents” for my ability to cross reference to allow for my
understanding.
Additionally, an expanded Table of Contents might allow me to gather data on a particular item -
for instance, the lighting. In one sub - section, its says that towers are 80 feet high, in another it
says that they will be lit from 7 AM - 10 PM, in another it says that there will be 17 - 80 foot
towers. etc. If this data is NOT provided in one sub- section, then at least a Table of Contents as
requested might be of help going forward.
I can assure you that this is no easy task to begin to gather and assimilate this data - as I
attempt to provide an intelligent response to the Draft EIR. An expanded table of Contents with
corresponding “lists” within the document itself would go a long way to helping me do this.
3. If it is possible, I would like to see this Document re-issued as a “searchable” PDF, with
hyperlinks as required to the Appendices. Modern technology easily allows for this.
4. I would like to see the entire Document proof read with respect to page numbers please.
For instance, I see that Section 4.1 has pages marked 4.1 … whereas 4.2 has pages also
marked 4.1, … - instead of 4.2.X.… Simple proof reading would have caught this error - I’m
asking please that you have someone do this. That way, when I make my own notes to refer to,
I am not going back through the document and unable able to find what I am looking for
because I am dealing with errors in the page numbering system.
5. I would like to see sub-sections entitled CONCLUSIONS limited to ONE per Section,
please. Too many of these have lead to my confusion on the topics therein.
In closing, I wish to say that this Project is very complex and potentially impactful to the
residents around it on so many levels.
There are many aging residents who reside in retirement communities near this proposed
Project. Many have invested their life savings in their forever homes and feel very afraid
because they cannot fully understand what this Project entails. Many can no longer concentrate
to the extent that they once could and are easily overwhelmed. Many are not computer savvy.
Some have told me that they feel inadequate and even “stupid” when they admit that they
cannot “understand” the DEIR when they try to read it.
My reply to them as been that “I feel inadequate as well ” when faced with such a lengthy and
redundant document. You have indicated in your email today that redundancy “is required” for
the completeness of the document. Thank you for this explanation as I now understand and
accept that.
However, and to that I would say … there should be extra attention on the City’s part then to
ensure that as much detail is provided for the benefit of all readers in such a manner as to
allow for complete understanding. The acknowledgement and implementation of my 5
comments above would go a long way to providing for this.
Thank you for your kind consideration of my request.
I look forward to hearing back from you.
Regards,
Dr. Diane Rebryna