2021-08-05 RebrynaPage of 1 11
August 5, 2021
Ms. Nicole Sauviat Criste
Consulting Planner,
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
BY EMAIL: ConsultingPlanner@laquintaca.gov
SUBJECT LINE: Coral Mountain Resort DEIR
RE: Comments re: DRAFT EIR for Coral Mountain Resort
Applicant Meriwether Developments request for zoning change in South La Quinta from
“Low Density Residential w/golf course”(LDRw/G) to “Tourist Commercial” (T/C)
Ms. Sauviat Criste,
I am writing today as a concerned Trilogy resident to respond to the Draft Environmental
Report as well as to voice my opposition to the rezoning application above which would allow
for the Coral Mountain Resort development ( “the Project”) in South La Quinta.
PREAMBLE:
The key to the color coding within this response to the DEIR is here:
1. My comments, as the writer, are in BLACK
2. The reader will see comments in RED: These are supportive documentation for that section
and are excerpts from CA Environmental Quality Legislation (w/ writer’s emboldening/
underlining). This legislation drives the CEQA Guidelines which in turn provide the framework
for the Draft Environmental Impact Report.
PUBLIC RESOURCES CODE - Public Resources Code
DIVISION 13. ENVIRONMENTAL QUALITY [21000 - 21189.70.10] ( Division 13 added by
Stats. 1970, Ch. 1433. )
CHAPTER 1. Policy [21000 - 21006] ( Chapter 1 added by Stats. 1970, Ch. 1433. )
3. The reader will see comments in PURPLE: These are excerpts from the 2021 CEQA
Guidelines. https://www.califaep.org/docs CEQA_Handbook_2021.pdf
4. The reader will see comments in BLUE: These are excerpts from the 2035 La Quinta
General Plan (“the Plan”) (w/ writer’s emboldening/underlining)…
https://www.laquintaca.gov/business/design-and-development/planning-division/2035-la-
quinta-general-plan
which is the ”…plan …crafted as the guiding policy document for the City per the vision
expressed by its citizens and established by the City Council.” I-1…The General Plan
includes …“Goals, polices, and programs (that) are all supported by factual data, community
opinion, background information, and detailed maps. Together, these constituent parts paint a
picture of the community’s future development”
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My comments with respect to the DEIR for the Project will be laid out in 3 parts:
A.Those regarding the DRAFT Environmental Impact Report Document
B.Those regarding the Project relevant to the DEIR, and
C.Conclusion
——————————————————————————————————————————-
A. My comments regarding the Draft Environmental Impact Report Document for
Coral Mountain Resort - issued June 22, 2021:
Section 21003 of the Legislation addresses the preparation of Environmental Impact
Reports.
The Legislature finds and declares that it is a policy of the state that…
…(b) Documents prepared pursuant to this division be organized and written in a manner
that will be meaningful and useful to decision makers and to the public.
…(c) Environmental impact reports omit unnecessary descriptions of projects and
emphasize feasible mitigation measures and feasible alternatives to projects.
My concerns with the DEIR document itself are as follow:
I, and many other concerned residents, are of the opinion that this document was not
organized and written in a manner that was meaningful and useful to the public. Whether it will
be useful to the decision makers remains to be seen.
1.In short, the document was not succinct. The sections in the DEIR with respect to the
“technical studies” contained complex language that would have been better placed in
appendices, to allow for “a flow” in the main document and encourage a “rapid
understanding” of the DEIR by the average reader as required by the CEQA guidelines.
2.I have strong objections to the multiple vague statements that appear throughout the
DEIR ( regarding identified factors)…” are not anticipated to”, “would not significantly
impact”,” would not substantially change”, “would not be significant” , “minimally
impacted”, “would be imperceptible”, “are not fully compliant”, etc. These are
SUBJECTIVE comments that are not scientific and neutral. As a reader, comments like
this do not inspire my confidence in the findings.
3.I also have concerns with “elaborate and ornate descriptive language” used in what
should be presented as a neutral “for information” document. Often times such language
was used to describe the Project.
For example, on page 7-57 of the DEIR, the following statement is made: “Develop a high‐
quality private wave basin (The Wave) that provides unique recreational opportunities
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for future residents of the project, and that attracts resort guests and creates a
landmark facility that will enhance the City’s reputation as the “Gem of the Desert”.
Only PLAIN SIMPLE LANGUAGE should be allowed, regardless of the context. Language
like this belongs in a promotional brochure for the Project - not in a DEIR. I compared other
DEIRs for other Projects in the Coachella Valleyand and could n ot see examples of this
type of language in the others.
4.Many of the tables were redundant and confusing in their layout; they should have
been placed in the appendices for easy reference, and not allowed to clutter the document.
5.At 1500 plus pages including appendices, the document was too long as per the CEQA
guidelines ( 300 pages is recommended for a complex project ), and filled with redundant
and repetitive sections that were repeatedly “cut and pasted” throughout the entire
document. In fact, entire sections were literally repeated several times throughout the
document.
6.Then document did not include an organized and detailed Table of Contents to allow for
easy reference by the reader and some of the numbering on the pages was not in
sequence. There were too many sections entitled “Conclusion(s)” throughout the
document, contributing to further confusion for the average reader. There were page
numbering errors in some sections; some intended citations were not cited.
I would like it on record that I, and others, communicated the above concerns to the
Consulting Planner, and her response on July 13, 2021 was the following:
“Although the CEQA Guidelines suggest page limits, the complexity of this project requires that it be analyzed
thoroughly, resulting in a longer document. The language in the document, although technical, is not unduly
scientific or complex. CEQA documents usually are highly detailed and cover many variables. Likewise, the various
environmental impact areas may have some redundancy of analysis, all in an effort to make the document as
complete as possible. The City has completed the EIR to address all currently known aspects of the project, and to
provide decision makers and the public with a comprehensive analysis of the potential direct, indirect and
cumulative impacts associated with its implementation. The City will not be retracting the document or reissuing it.”
Why this DEIR as presented is of concern:
This Project is very complex and its completion would be impactful to the residents around it
on many levels.
There are aged residents who reside near this proposed Project in retirement communities.
Many can no longer can concentrate to the extent that they once could and are easily
overwhelmed. Some said they were intimidated by the DEIR and wondered how to respond
when they could not understand it.
Could a document like this discourage the average reader to persevere and provide a public
response that is meaningful, organized and to the point ? … again, that remains to be seen. It
will be interesting for the city officials to compare the number and nature of responses to the
DEIR to those regarding the Notice of Preparation.
——————————————————————————————————————————
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B. My comments and concerns regarding the Project relative to its presentation in
the DEIR
In order to fully understand the intent and ramifications of a DEIR, I went to the Legislation and
the CEQA 2021 Guidelines, as referred to above.
I sought the definition of the “Environment”… which was defined as follows in 15360 of the
CEQA guidelines:
15360. ENVIRONMENT (NOTE: emboldening is writer’s)
“Environment” means the physical conditions which exist within the area which will be affected by a proposed
project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historical or aesthetic
significance. The area involved shall be the area in which significant effects would occur either directly or
indirectly as a result of the project. The “environment” includes both natural and man-made conditions.
Note: Authority cited: Section 21083, Public Resources Code; Reference: Section 21060.5, Public Resources Code.
(NOTE: emboldening is writer’s)
I find it interesting that the “environment” includes reference to both natural and man-made
conditions. This definition of ENVIRONMENT will form the basis for my comments going
forward.
—————-
The legislative background for the following section of my comments provided as an
Overview, is important:
The Legislature finds and declares as follows in Environmental Quality Section 21000:
(a) The maintenance of a quality environment for the people of this state now and in the future
is a matter of statewide concern.
…(b) It is necessary to provide a high-quality environment that at all times is healthful and
pleasing to the senses and intellect of man
…d) The capacity of the environment is limited, and it is the intent of the Legislature that the
government of the state take immediate steps to identify any critical thresholds for the
health and safety of the people of the state and take all coordinated actions necessary to
prevent such thresholds being reached
The key words in the legislation are “high” and “quality" environment, and “threshold for the
health and safety” of the people.
These statements are similar in concept to the 2035 La Quinta General Plan.
“The long term Quality of Life” for La Quinta residents is emphasized repeatedly, particularly in
the Livable Community Element and Land Use Element of the 2035 La Quinta General
Plan.
Also, I refer the reader specifically to the following goals and policies that are laid out in the
Plan:
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GOAL SC-1:
A community that provides the best possible quality of life for all its residents.
GOAL LU-3 (II-26)
Safe and identifiable neighborhoods that provide a sense of place.
Policy LU-3.1…II-26 Encourage the preservation of neighborhood character and assure
a consistent and compatible land use pattern.
Program LU-3.1.b: Apply the City’s discretionary powers and site development review
process consistently to assure that subdivision and development plans are
compatible with existing residential areas.
GOAL LU-4… (II-26)
Maintenance and protection of existing neighborhoods.
Policy LU-4.1… (II-26) Encourage compatible development adjacent to existing
neighborhoods and infrastructure.
How do I see this Project?
Rezoning from Low Density Residential w/ golf (“LDR w/G”) to Tourist Commercial (“TC”) is
NOT consistent with the City of La Quinta’s own plan and will lead to a “domino effect” that will
negatively and forever impact the existing surrounding residential communities and their
residents.
TC zoning now will open the door to future TC development in SE La Quinta. An entire
quadrant of the City could change forever. Would the possibility of collection of Transient
Occupancy Taxes supersede the City’s responsibility to ensure that “subdivision and
development plans are compatible with the existing residential areas, as per the 2035
Plan?
The salient points follow:
1.The Developers, as stated in the DEIR, are asking for Sub Phase Development based on
“consumer and market demand”. This in itself is one of the most disconcerting aspects of
this whole proposal.
I am overwhelmed as I think of how plans for our lives will be totally predicated on the
fact that the “waves and phases” of construction noise and traffic could go on for years
and years. Residents of the surrounding residential communities may never see the
completion of this Project in our time here. How does this ensure that we the
residents will continue to enjoy the best possible quality of life - particularly with
the uncertainty with respect to the timing of completion of the Project that we
would be facing ? (GOAL SC-1)
2.Rezoning to TC, as stated in the DEIR, will essentially permit the majority (at 600 with a
minimum of one night’s stay) of La Quinta’s Short Term Vacation Rentals allowed for to
be concentrated at THIS Resort.
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As per the City Ordinance No. 591, “no new STVR permits will be issued until further
notice unless the property is located within TC zones"…https://www.laquintaca.gov/
connect/short-term-vacation-rentals.
The large number of STVRs will allow for a constant revolving door of strangers and we,
the residents nearby, will not know our neighbors as we do now. Further, this resort will
be open 24 hours per day, again with strangers entering and exiting and milling about.
We will think twice about those recreational runs, walks, hikes or bike rides outside of our
gated communities, particularly earlier in the morning or later in the day. Also, it is a
known fact that crime increases in communities where there is a significant transient
population.
What will happen to our “safe and identifiable neighbourhoods that provide a sense
of place”? (see GOAL LU-3 {II-26} above). Will these be “sacrificed” for the sake of
TOTS for the City of La Quinta ?
3.Rezoning from LDRw/G to T/C will allow the Developers to apply for Special Events via
Temporary Use Permits.
PAGE 3-35 of DEIR states the following…”Temporary Use Permits are required by the
City accommodate special, unique or limited duration activities that might otherwise be
outside of the provisions of normal zoning … are reviewed administratively by the Design
and Development Director and do not require a public hearing”
What’s to prevent “the 4” that mentioned in the DEIR from turning into 8, or even more,
per year ? One the rezoning takes place, the residents nearby will never have further say
on this matter.
There will likely be major access and egress challenges to emergency management
vehicles around most of the limited roadways of the surrounding communities during
these Special Events ( think of the La Q Festivals). This could impact our safety and well
being, should there be traffic tie ups both during and before and after Special Events for
the “prep and take down days” that will “bookend” the Special Events themselves . The
community of Trilogy, for example, has ONLY two access and egress roads - Madison
and Monroe. That will never change - whether or not this Project proceeds. Why
compromise the “safety” of the local residents with this Project ? We are entitled to
safe neighborhoods and all that this entails.
If one is to stand back and consider the entire concept of Rezoning in this location, it is
easy to see that this Project makes no sense. This is definitely not in keeping very
important component of the 2035 La Quinta General plan - that which speaks to the
“maintenance and protection of existing neighborhoods” and a “consistent and
compatible land use pattern ” (see GOAL LU-3 {II-26} above and policies) (see GOAL LU-4
above{II-26}).
Further, and from a practical perspective, this Project does not and will never benefit the
average La Quinta resident. It is essentially for the rich and it is a private destination for its
residents and guests. An hour of private surfing at Lemoore CA for celebrities runs $10,000.00.
In other words, this recreational outlet is NOT available to and NOT affordable by the average
La Quinta resident, is it?
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We, the residents of the communities around it, would be required to absorb the negative
aspects of this destination resort without any of the benefits. If I lived in Anaheim near
Disneyland, at least I could plan an outing there with my kids and grandkids. Not so here.
Coral Mountain Resort does NOT fit - it is an entirely different concept of life - it will not be
residentially focused - which will basically be “injected” amongst the quiet residential
communities that surround it. This Project will be a “square peg in a round hole” !
——————
Additional Legislative background for the following section is important when considering the
CEQA categories of Noise, Aesthetics (lights) and Hydrology:
The Legislature finds and declares as follows in Environmental Quality Sections …
21000 (b) …it is necessary to provide a high-quality environment that at all times is
healthful and pleasing to the senses and intellect of man.
21001(b) …all action necessary to provide the people of this state with clean air and water,
enjoyment of aesthetic, natural, scenic, and historic environmental qualities, and freedom
from excessive noise.
I would like to provide comments on some of the DEIR categories and the related issues that
present as follow:
1. NOISE
Section 21000(b) of the Legislation speaks to “…freedom from excessive noise”.
From a practical perspective, we the residents of the surrounding communities are faced
with some very tangible aspects of surrounding aberrant noise, despite what the DEIR says.
In Trilogy, we can hear the music, thumping and beats of the festivals Coachella and
Stagecoach. We can hear the racing cars at Thermal. Coral Mountain Resort will be close
by and what we will hear will be much different from ambient noise of quiet residential
communities.
First of all, many of the DEIR studies, such as the operational noise are based on unknown
local conditions. WE know that there is noise from reverberation at Coral Mountain. What
truly will the operational noise of the Project be ?… with its train and tracks, that is the
wave making apparatus, as well as the noise generated by the greatly increased number of
people in attendance ? What about the noise that will occur during operational hours from 7
AM - 10 PM every day, 365 days per year?
What about increased noise from traffic during the regular operation of the Project?
There will be increased noise when Special Events are held. What would a Special Event
be without music and more people in attendance ? More people equates to more traffic.
Additionally, noise ordinances are always lifted for Special Events. These will definitely
impact the quiet residential communities around the Project.
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I should also point out that the construction of a 1/2 mile long concrete wave basin could
take many many months with its use of larger, heavier and ultimately noisier construction
equipment than would be required for Low Density Residential construction. Commercial
development is also included in this category; again, this would be subject to Sub Phase
Development considerations being asked for by the Developer.
Finally, from its own 2035 Plan …”The City’s ongoing efforts to preserve the quality of life for
all its residents, present and future, must include the protection of a quiet noise
environment” (NOISE IV-15)
Regardless of the Developer’s “studies”, there is NO good reason to allow for this kind of
noise in a quiet residential community. There are too many unknowns. The noise issues
raised would only come about as a result of rezoning.
2. LIGHTS
Sections 21000(b) and 21001(b) of the Legislation speak to “healthful and pleasing to the
senses” and "enjoyment of the aesthetic and scenic qualities”
17 (seventeen) 80 foot light towers on until 10 PM and the nighttime glare from the
commercial development - both as a result of the rezoning - are other unknowns that
cannot be studied at this location. Think of the Indian Wells Tennis Gardens at night; then,
please compare to the Cove in La Quinta.
A T/C zoning change, along with the Developer’s request for variances, will also allow for
many other types and heights of lights.
Commercial glare in La Quinta is appropriately saved for Hwy 111 and it muted there due to
lighting ordinances. Again, please compare Hwy 111 and the Cove.
Additionally, there is the matter of light diffusion in the nighttime skies in the presence
of particulate matter. This was not accounted for in the “studies” presented in the DEIR.
We, as residents close by have the beautiful dark desert skies now and we will forever be
deprived of this… and all of the variances being asked for as mitigation measures, including
walls and setbacks, will not change this in any way.
3. HYDROLOGY / WATER
Section 21000(d) of the Legislation states…“The capacity of the environment is limited, and
it is the intent of the Legislature that the government of the state take immediate steps to
identify any critical thresholds for the health and safety of the people of the state and
take all coordinated actions necessary to prevent such thresholds being reached”.
Section 21000 (g) of the Legislation states …”It is the intent of the Legislature that all
agencies of the state government which regulate activities of private individuals,
corporations, and public agencies which are found to affect the quality of the environment,
shall regulate such activities so that major consideration is given to preventing
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environmental damage, while providing a decent home and satisfying living environment
for every Californian”
I am totally perplexed as to how this Project with its enormous water usage with 18
million gallons of water to fill it from our aquifers would even be considered in our
desert environment with its high temperatures, evaporation rate and winds, especially
during a mega-drought.
Additionally, there is the issue of the Reasonable Use of Water - in CA law:
From Professor Gray’s paper entitled The Reasonable Use Doctrine in California Law and Policy (2015 Brian E.
Gray , UC Hastings College of the Law) https://repository.uchastings.edu/faculty_scholarship/987/ … , comes
the following (note: italics and underlining are writer’s)
...”the cardinal principle of California water law is that all water rights, and all uses of water, must be
reasonable“... and that the Doctrine of “reasonable use” is both a policy mandate AND a limitation on water
rights, which applies to
All branches of government,
All levels of government administration of state’s water resources, and
Public and private users of the State’s waters.
...”because all uses of water must be consistent with this interdependent and variable definition of reasonable
use, the law renders all water rights fragile. A water right that was reasonable when first recognized, and
which may have been exercised reasonably for many years, may become unreasonable as hydrologic
conditions change, as California’s economy evolves, as population grows and new demands for water
arise, as ecological needs are better understood, and as the environmental laws that protect the state’s
aquatic ecosystems and native species are applied in ways that limit the impoundment and diversion of
water for consumptive uses”
Further, the City of La Quinta lays out the following in the 2035 Plan, where water
conservation is stressed to protect future resources ; to wit, the following…
Conservation of Natural Resources II-136 …The conservation of natural resources is a
major component of a livable community…
Imported water from the Colorado River and new replenishment programs implemented
by the CVWD have helped alleviate declines, but both rely on outside sources of water.
In 2010, approximately 300,000 acre-feet of water per year have been allocated from the Colorado
River to the eastern Coachella Valley, primarily for agricultural irrigation. Although continued
importation of water will help to replenish the aquifer, a more resourceful alternative is to reduce the
amount of water pumped by the CVWD, which will have a direct impact on overdraft. Conservation
techniques have already been implemented, and new measures are being developed to lower the
amount of water used by each household and business in the City. II-137
Water conservation in La Quinta is essential to reduce the overdraft of local groundwater, and
protect future resources. II-138
Water conservation must include all types of water use – from landscaping to indoor fixtures, and
must include new and existing development. The programs described above provide the foundation
for reducing water demand. This Element can allow the City to expand programs that promote water
conservation now and into the future II-138
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Policy UTL-1.2
The City should encourage the conservation of water. (V-15)
GOAL WR-1: The efficient use and conservation of the City’s water resources. (V-16)
Two additional concerns with respect to Hydrology of this Project must be addressed:
1. As an aside, but still on the topic of water usage for a Project like this in the desert, I
would like the reader to compare this Project to another responsibly developed and
sustainable desert surf park in the world that is located in the United Arab Emerites (WADI).
It has a dedicated 124 mile pipeline built to pipe ocean water to the area which is then
cooled to address high water temperature concerns for humans AND the proliferation of
micro-organisms, both which can cause significant human illness and even death.
https://surfparkcentral.com/wadi-adventure-wave-pool-and-surf-park-in-al-ain-uae/
Please see Appendix A attached to this letter which is a copy of my letter dated July 19,
2021 to the Public Health Officer of Riverside County with questions regarding the filtration,
cleaning and disinfecting regimes, including required documentation regarding the
protocols. Please include this letter in the the public comments part of my response to
the DEIR. Hopefully these questions raised in the letter to Dr. Leung will be clearly
addressed in the Final EIR.
and,
2. The Developer repeatedly argues that a golf course uses more water than the wave basin
will use. I say - leave the existing zoning in place and negotiate with a Developer to
construct alternative recreational outlets for the residents who purchase there. Alternatively,
a responsible developer can construct a golf course that observes contemporary
conservation measures such as extensive xeriscaping (as has been accomplished via
conversion in many California golf courses) and recycled water. This is the “wave” of the
future !.
Supportive legislation for 2. above is as follows:
Section 21002 of the Legislation states…
“The Legislature finds and declares that it is the policy of the state that public agencies
should not approve projects as proposed if there are feasible alternatives or feasible
mitigation measures available which would substantially lessen the significant
environmental effects of such projects,
…and that the procedures required by this division are intended to assist public agencies in
systematically identifying both the significant effects of proposed projects and the feasible
alternatives or feasible mitigation measures which will avoid or substantially lessen such
significant effects”.
Water is a VITAL component to the health and safety of the people. There is no other
“recreational activity’ which would even be considered if there was an equivalent current
and potential future threat to the environment looming in our midst. A development that
uses water in this capacity is an irresponsible development.
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There is a global movement under way to be respectful of our natural resources and to
conserve water; all with good reason, and we must as the City of La Quinta has stressed in its
own plan, protect future resources as we think of our children, their children and all future
generations.
——————————————————————————————————————————
C. Conclusion:
In closing, I would like to refer to the CEQA Guidelines Section 15064, where it is stated (c) In
determining whether an effect will be adverse or beneficial, the Lead Agency shall consider
the views held by members of the public in all areas affected as expressed in the whole
record before the lead agency, and
CEQA Guidelines Section 15065, Mandatory Findings of Significance, (4) where it is stated
that consideration should be given to “The environmental effects of a project … ( and
whether they can ) cause substantial adverse effects on human beings, either directly or
indirectly”…
We, the residents of the communities nearby, are the “human beings” that will be
impacted by all of the aforementioned effects of the proposed rezoning of this parcel of
land to Tourist Commercial.
With respect to the irresponsible use of water, especially during this unpredictable
MEGA drought, it must be recognized that on a global level all “human beings” are
being impacted.
It is acknowledged that change is necessary and often desirable when considering urban
planning issues. It is also understood that a City that is responsive to its residents needs to
look to additional sources of revenue. Please note that the residents who live by this Parcel of
land are not against development, they are against development that is incongruous and
irresponsible with respect to water usage.
As in all things in life, there must be a balance established - pros and cons must carefully be
weighed. The cons outweigh the pros with respect to this Project.
On the basis of what has been presented in the DEIR, please say NO to the rezoning of this
parcel of land to Tourist Commercial.
Thank you for your consideration.
Respectfully submitted,
Diane Rebryna
60149 Honeysuckle Street,
La Quinta, CA
Attachment; Appendix A
Letter to Dr. Geoffrey Leung, July 19, 2021
Riverside County Public Health Officer
Department of Public Health
July 19, 2021
Dr. Geoffrey Leung M.D.
Riverside County Public Health Officer,
Department of Public Health,
Health Administration
4065 County Circle Drive
Riverside, CA
92503
BY REGISTERED MAIL
Dear Dr. Leung:
RE: Coral Mountain Resort Wave/Surf Basin ( the “ Project”)
Questions / Concerns re: proposed water treatment for safety
I am writing to you on behalf of a number concerned residents who reside in La Quinta, CA.
There is a proposed Development called Coral Mountain Resort and its “anchor” is a surf wave
basin that is almost 17 acres in size and filled with 18 million gallons of water from the aquifer -
so in other words, potable water.
The DRAFT Environmental Report was recently released for this Project and public comment
in invited until August 6, 2021.
It is here:
https://www.laquintaca.gov/our-city/city-departments/design-and-development/planning-
division/the-wave-at-coral-mountain
We have questions for Riverside County Department of Public regarding the following please:
1.Background Information
Articles abound online regarding the death of a young man who apparently contracted the “brain
eating ameba” also known as Naegleria fowleri from a surfing experience at Waco TX. The
water in this wave basin had apparently been described as a “pathogen soup”.
https://www.tracksmag.com.au/news/surfer-dies-from-brain-eating-amoeba-513336
https://raisedwaterresearch.com/bsr-covers-up-evidence-in-surfers-death-lawyer-alleges/
The CDC describes Naegleria fowleri “ as a free-living microscopic ameba that can cause a rare
and devastating infection of the brain called primary amebic meningoencephalitis”. https://
www.cdc.gov/parasites/naegleria/index.html. The website also goes on to say that this
microorganism usually infects people when contaminated water enters the body through the
nose.
WEB MD says “Naegleria loves very warm water. It can survive in water as hot as 113 degrees
Fahrenheit”… “most cases of N.fowleri disease occur in Southern or Southwestern states…”The
nose is the pathway of the amoeba, so infection occurs most often from diving, water skiing, or
performing water sports in which water is forced into the nose”. https://www.webmd.com/brain/
brain-eating-amoeba
Given that this young man’s death occurred, ostensibly from an exposure to the parasite while
surfing in an artificial basin, the Developers and operators of surf/wave parks apparently are
“ramping up their efforts” to prevent this from occurring again. Some public health agencies
have also stepped in to ensure that this is the case with enhanced filtration requirements, as
well as the requirements for daily testing with water quality reports, detailing chlorine, pH,
sediment and E. coli levels.
2. The reasons for our letter and for my contacting you are as follow:
A. The desert is HOT (120 days over 100 degrees last year) and the hottest months are
June, July and August. We have been told repeatedly that there are NO plans by the
Developer to cool the surf/wave basin in the summer months.
We have concerns about the increased potential for proliferation of micro-
organisms in the heat of summer in the desert.
The only other desert pool that we know of is in WADI UAE where a 100 plus mile
dedicated pipeline is built to bring desalinated water in that is then cooled onsite for
use at its surf / wave basin.
We have concerns about the health and safety of the people who recreate in this very
hot water.
B. We have reviewed the DRAFT EIR to determine if there is evidence of a detailed cleaning
and disinfection plan in place for the ongoing maintenance of the pool, particularly with
number of hot days that we have here in the desert; there is none.
There is also no information on the presence of a filtration system that swimming pools
require.
From a public safety perspective, we would feel much more reassured about the
operation and maintenance of this surf/wave basin if a detailed maintenance protocol
was made publicly available, given this extraordinarily unusual HOT environment for his
type of recreational outlet.
There is nothing in the DEIR that outlines the required cleaning and maintenance
schedules or whether or not periodic complete pool emptying and refilling is
required.
There seems to be a somewhat perfunctory description of the intended disinfection
regime (4.8.18… Coral Mountain Resort DRAFT EIR) There is a generalized reference
made to Section 65529 (Public Pool Disinfection of Title 22 of the California Code of
Regulations CCR) in that the pool must be “disinfected continuously”.
We see evidence of “materials” that will be used in June July and August (with
particular reference to sodium hypochlorite - NaClO ) as well as halogens, however no
evidence of a plan per se.
How is the contamination of the water with bodily fluids addressed ? … e.g. blood,
urine, feces
C. We also question whether the operator of the wave basin will be able to maintain an
accurate concentration of the required disinfecting agents particularly because of high
rates of water evaporation due to the extraordinary heat, high winds and the wave action itself
in these desert conditions. How will accurate records be kept of the conditions that are
present at the pool? As stated above, the standard of care looks more and more like records
MUST be kept, with frequent assessment and input data for surf/wave basin water.
D. Who will administer the records and data ? Who will ensure compliance ?
E. We are concerned that Kelly Slater et al has essentially stated in the past that “treating and
filtering water pursuant to existing regulations makes a public surf park in California not
viable”, as per a quote from the inertia https://www.theinertia.com/surf/kelly-slater-wave-
company-pool-regulations-surf-pool-wave-basin-california/. Thus our question - if this was
argued before by this surf ranch pool, will this aspect of pool maintenance now be taken
seriously by the operators ? It appears that it wasn’t in WACO, prior to that young man’s death.
——————————————————————————————————————————
Thank you for allowing me to lay out our concerns regarding the maintenance of the surf wave
basin with respect to appropriate cleaning and disinfecting regimes, particularly as related to
the possibility of proliferation of pathogens in water that is not cooled and/or properly
treated in this hot desert environment. Because of the lack of cooling, we are also
concerned about the safety of the people who surf in that type of hot desert environment.
I can be reached at 403 870-2109 should you have any questions.
Kind regards,
Dr. Diane Rebryna B.Sc., D.D.S
60149 Honeysuckle Street
La Quinta, CA
92253
cc:
Kim Saruwatari, MPH, Director
Health Administration Building
4065 County Circle Drive,
Riverside, CA 92503