2021-08-02 StrattonDear Ms Sauviat Criste, Planning Consultant
RE: Coral Mountain Resort DEIR
1.2.1 Proposed Project
“Meanwhile, the project area west of Madison Street, is the subject of the General Plan Amendment, Zone Change,
new Specific Plan, Tentative Tract Map, Site Development Permit, and Development Agreement proposed
for the project and discussed in greater detail below.”
There are six major changes proposed. Why did this project make it this far through planning and the
City Council? Where is the explanation of when and how this first proposed to amend the City’s General
Plan? What was the justification to proceed further?
The city council should provide its residents with a written and public justification of its intent, so there
can be no misunderstanding of facts, history and responsibilities. In addition the city council should
certify that THEY PERSONALLY have studied this report and responses from residents.
“Existing residential communities occur to the north, south, and east. Avenue 58 and residential properties define
the project’s northern boundary; Madison Street and the Andalusia community define the eastern boundary;
Coral Mountain defines the property’s southwestern boundary; and vacant land and residential properties
define the southern and western boundaries.”
The residential properties mentioned are not only Andalusia, but Trilogy to the Southeast, PGA West
Weiskopf to the Northeast, The Quarry to the West, Santerra to the North, Coral Mountain Estates to
the North. These existing communities house a significant population and conform to the current LQ
General Plan. All of the residents of these communities along with the SFR on Avenue 60 should have
been advised by mail in 2019 of their opportunity to comment at that time.
“Development Agreement (DA 2021‐0002)
would vest the applicant’s right to develop the Coral Mountain Resort Specific Plan area pursuant to the
entitlements described above, address short‐term
rentals within all planning areas of the project, ensure that the project has a net positive fiscal impact on the City
despite the lack of property tax revenue to the City through 2035, and ensure the timely completion of
infrastructure to serve the project and surrounding area, and ensure that the project design features and
mitigation measures identified in this EIR are enforceable by the City as project requirements. “
STVR’s will increase the traffic, noise and population. The City will not receive tax revenue through
2035! While approving STVR’s which are being curtailed in the rest of the City, this is insane that it
would be allowed with NO TAX REVENUE! What exactly is a “net positive fiscal impact” without
revenue? This needs further explanation.
”Zone Change
(ZC 2019‐0004)
will revise the existing zoning from Neighborhood Commercial, Low Density Residential, and Golf Course, to
Neighborhood Commercial (CN), Low Density Residential (RL), Parks and Recreation (PR), and Tourist
Commercial (CT). “
La Quinta Zoning Code Section 9.240.010 states the following required findings shall be made by the City
Council prior to approval of any specific plan or specific plan amendment:
1. Consistency with the General Plan – IT IS NOT
2. Public Welfare – The noise, traffic, light pollution is detrimental to the general welfare. “Significant
and Unavoidable” as shown on EIR
3. Land Use Compatibility – IT IS NOT compatible with surrounding low density adjacent communities.
4. Property Sustainability – The existing specific plan for this property is sustainable. It is unknown if a
Wave Basin will survive. All of Kelly Slater’s recent Surf Ranch proposals have not come to fruition. He
has not exhibited that his business model will survive, much less open. Why should the City of LQ be the
test case? What will happen to a dry, abandoned wave pool community?
PR and CT zoning is completely inconsistent with the neighborhood. This is nothing more than a
glorified amusement park.
“The Coral Mountain Resort Specific Plan (SP 2020‐
0002) will establish a new master plan governing the allowable land uses, design guidelines, and development
standards to allow creation of a boutique resort and master‐
planned community. The Specific Plan includes four Planning Areas which are coterminous to the General Plan and
Zoning designation boundaries described above.”
This is anything but a BOUTIQUE RESORT AND MASTER-PLANNED COMMUNITY! It is not private! It
cannot be private and generate enough attendance to justify the cost of this wave pool. It is clearly
open to the public who reserve a room at the hotel or rent one or two days at the STVR’s. Master
Planned Communities do not invite 2500 people to attend events, four times a year.
“Planning Area I (PA I) –
Neighborhood Commercial is located on 7.7 acres at the southwest corner of Avenue 58 and Madison Street, and
allows for the construction of 60,000 square feet of publicly accessible neighborhood commercial building
space with affiliated circulation and infrastructure improvements.”
The opposite corner of Avenue 58 and Madison has been available for commercial development for the
11 years I have lived in Trilogy. For most of that time it was posted with a sign to attract c ommercial
tenants. Nothing was ever developed. Meriwether must also find commercial tenants in order to build
commercial space. It seems unlikely.
“PA III‐
G – Back of House: The Back of House subarea contains approximately 26.5 acres that will be graded as level,
largely open land south of the Wave Basin. This subarea will provide unprogrammed gathering and staging
space for temporary equipment such as port‐a‐
potties, shade structures, tenting for inclement weather, and catering equipment that might be used during
events.”
This area will cause significant traffic on Avenue 60. Andalusia and Trilogy have spent and continue to
spend significant funds to landscape and maintain the beauty of this street between our communities.
It will be a direct conduit for trucks hauling everything for these events. That is unacceptable. The
developer is directed to map out a route for all of the construction traffic. Given that Trilogy has not
been considered in any evaluation, the route will likely go along 60th from Monroe to the site.
“PA III‐
B – The Wave: The Wave subarea contains approximately 31.2 acres containing an artificial surf Wave Basin
and associated infrastructure.
PA III‐
C – Wave Club: The Wave Club subarea contains approximately 3.2 acres fronting the Wave Basin and will fu
nction as a private clubhouse with amenities for exclusive use by the Coral Mountain community.”
“1.4 Areas of Controversy
; the potential for a significant change in the visual character of the area from a single‐
story residential and golf environment to a hotel and Wave Basin facility; and the potential impacts of proposed 80‐
foot light standards surrounding the Wave Basin on the night sky, light and glare. Visual simulations, line‐of‐
sight analyses and photometric analyses were conducted for the project.
4.1 AESTHETICS
Table 1-3 Summary of Environmental Impacts and Mitigation states the level of Significance and
Mitigation clearly is “Significant and Unavoidable”.
Page 136 of 738 includes the line of sight analysis.
LINE OF SIGHT SECTION ‘E’ FROM AVENUE 60
The viewpoint does not include views from Trilogy. It was taken west of the intersection of 60th and
Madison at street level. Many houses along 60th (Barrel Cactus Rd) are elevated above 60th.
Detail “A” Wave Basin/Light. The line of sight on Exhibit 4.1-12 shows that the tops of the 80 foot light
poles will be above the line of sight from street level. That does not take into consideration any of the
homes in Trilogy which are higher in elevation.
To state they will only be on from dusk to 10 pm is absurd! That is not a mitigation. The poles will be
visible 24 hours a day.
I personally live in Trilogy and my backyard on the golf course faces the southwest corner of this
community where the wave basin and lights are located. C urrently I enjoy every morning and evening
looking directly at Coral Mountain and enjoy the change in colors. No six foot fence is going to cure
anything. I already can look over the fences surrounding Andalusia. (Photos attached)
In conclusion the Line of Sight Analysis is inadequate as it does not take into consideration the line of
sight from the northern and western boundaries of Trilogy. The City needs an independent analysis.
Coral Mountain Coral Mountain partially lies within the southwest corner of the project property. Coral Mountain extends over
400 feet above sea level and provides a scenic resource for the surrounding area. The Mountain is currently viewed without
significant obstructions from the public roadways, Avenue 58 to the north, and Madison Street to the east.
This section of the EIR gives no consideration to views from Trilogy. We have over 1200 homes many of
which have excellent views of Coral Mountain. To give our community no consideration is irresponsible.
Views from the streets alone is not a thorough analysis. A drive-by view from the street is inadequate.
Many views are from homes on the golf course inside the community.
The citizens of Trilogy deserve adequate consideration and an accurate analysis of the views and
noise.
4.11 Noise
The sounds from the waves, wave riding vehicles which accompany the surfers, competition
broadcasts/music and the public cheering will all be very disturbing. Viewing platforms on top of the
hotel will be visible and add to the light pollution. The sounds will bounce off Coral Mountain. I can
hear a car drive along 60th, stop at the Madison corner, turn right and continue to a stop at 58th. You
cannot tell me that the sounds created by all of the traffic and venue will not be noise pollution.
LAND USE
• Land use compatibility throughout the City. A WAVE BASIN IS NOT COMPATIBLE.
•Changes and variations from the Zoning Ordinance in a Specific Plan will be offset by high quality design, amenities and mix
of land uses. A WAVE BASIN AMUSEMENT AND STVR’S DOES NOT JUSTIFY THE CHANGE.
• A broad range of housing types and choices for all residents of the City. THE RANGE OF HOUSING TYPES DOES NOT BENEFIT
THE RESIDENTS OF THE CITY. A FEW HIGH PRICED LOTS FOR SFR’S – THERE ARE PLENTY ALREADY IN LA QUINTA.
• Consider changes in market demand in residential product type to meet the needs of current and future residents. THERE IS
NO DEMAND FOR A TOURIST RESORT FOR NON-RESIDENTS.
•A balanced and varied economic base which provides a broad range of goods and services to the City’s residents and the regio
n. A SMALL COMMERCIAL DEVELOPMENT AT THE CORNER OF 58 AND MADISON DOES NOT SATISFY THIS POLICY.
•Maintain commercial development standards in the Zoning Ordinance including setbacks, height, pad elevations and other
design and performance standards that assure a high quality of development. 17-80 FOOT LIGHT POLES CREATE LIGHT
POLLUTION AND ARE NOT CONSISTENT WITH THE ZONING ORDINANCE.
• Support and encourage the expansion of the resort industry as a key component of the City’s economic base.
SILVERROCK RESORT HAS BEEN IN PLANNING AND CONSTRUCTION FOR MANY YEARS AND IS SUFFICIENT TO SATISFY
“EXPANSION”.
LIVABLE COMMUNITY
A community that provides the best possible quality of life for all its residents. THIS DEVELOPMENT WILL NEGATIVELY IMPACT
SEVERAL COMMUNITIES WITH THOUSANDS OF RESIDENTS.
ECONOMIC DEVELOPMENT
The Land Use Element shall maintain a balance of land use designations to address economic needs, meet market demand,
and assure a wide range of development opportunities. WHERE IS THE MARKET DEMAND FOR A WAVE BASIN FOR SURFERS IN
THE DESERT.
The continued growth of the tourism and resort industries in the City. THIS IS THE WRONG LOCATION FOR A PUBLIC RESORT.
HOUSING
Provide housing opportunities that meet the diverse needs of the City’s existing and projected population. Identify adequate
sites to accommodate a range of product types, densities, and prices to address the housing needs of all household types,
lifestyles, and income levels. Conserve and improve the quality of existing La Quinta neighborhoods and
individual properties. MILLION DOLLAR LOTS FOR SFR’S ARE READILY AVAILABLE IN LQ. STVR’S ARE
ALREADY OPPOSED BY THE CITY. THERE IS NO LOW INCOME HOUSING PROPOSED.
WATER RESOURCES
The project promotes water conservation through the use of drought tolerant plant materials and water efficient irrigatio
n techniques. The project will comply with all City and Coachella Valley Water District (CVWD) regulations and building code
s for water conservation. Additionally, recycled water will be used for common area irrigation for landscaping. The Wave
Basin provides a recreational amenity to support the proposed resort and residential uses, and does so with substantially less
water demand than required for alternatives amenities, such as an 18‐hole golf course.
DROUGHT TOLERANT PLANTS AND IRRIGATION ARE ALREADY USED ALL OVER LA QUINTA. THIS IS NOT
A MOTIVATION TO APPROVE THIS PROJECT. RECYCLED WATER FOR IRRIGATION vs THE FRESH WATER
TO FILL A WAVE BASIN IS NOT A JUSTIFICATION. MOST GOLF COURSES ALREADY USE RECLAIMED
WATER NOT FRESH WATER.
One cannot ignore the daily headlines from e-news, TV reports, newspapers and magazine articles
declaring a state-of-emergency with the reservoirs servicing the western states all reporting historic
lower than normal levels. Drought monitoring maps show most of Riverside County is in the severe
drought category but is edging closer to the extreme drought classification which is thought to be
inevitable. Whether this summer or next spring, a full state drought declaration could be ordered and
restrictions enacted.
How will wave pools or lagoons operate then? How will these wave basins and oasis lagoons be
replenished factoring in the enormous daily evaporation rates and the heavy winds inherent in our
valley? Answer: by drawing ever more potable water from the aquifers of course. Just last year in
2020, the entire Coachella Valley endured 140 confirmed days of 100 degree plus temperatures.
Additionally, IID has recently published warnings that rolling brownouts for this summer are likely to
occur which will affect homes, businesses, and wave pools/lagoons equally. However, downtime for surf
parks and lagoons is lost revenue.
”In order to assure that everyone in the region has sufficient water, it is important that La Quinta, as one
of the stewards of the local water supply, manages and conserves this important resource” (quote from
Water Resources III -57).
”The City’s goals, policies and programs relating to water resource management are important to the
District’s continued ability to provide domestic water to new and existing
developments in the City and the Sphere of Influence”. (quote from Water Resources III-57).
”Continued growth in the City and the region has resulted in an increased demand for domestic water.
As a result, CVWD extracts more water from the Lower Thermal sub-area than is naturally recharged
into it every year – a condition known as overdraft. "(quote from Water Resources III-58)."
An ”effective manner to reduce overdraft in the aquifer is through water conservation. The City and
CVWD have implemented a number of conservation programs in recent years which have reduced
consumption of domestic water. It is critical that these programs continue and expand, as possible,
through build out of the General Plan”. (quote from Water Resources III-60
Just because a deemed water usage may have been acceptable in the past, it does not mean that
responsible changes need not be made going forward as new environmentally challeng ing conditions
might dictate.
It's unacceptable that the residents of La Quinta be required to conserve water with respect to their
personal use (which we would willingly comply with in the interest of being good citizens and stewards of
our water resources), while a commercial venture such as this wave/surf park continues to draw
extraordinarily on our aquifers and power supply for an essentially private recreational outlet.
The developer has repeatedly stated that the Coral Mountain Project will use less water than a golf
course. It is common knowledge that golf courses, both existing and new, have many water conservation
options and measures available, wave pools and lagoons have no such alternatives. Wave Pools must
use clean, fresh drinking water from the two sub-basins servicing our valley. These sub-basins rely on
replenishment from the Colorado River but La Quinta cannot count on that source for our aquifers
anymore, especially in a historic drought.
NOISE
Why was there no noise receiver location in Trilogy? Trilogy is closer to the wave basin than those
residents on 58th.
In conclusion I firmly believe that the draft EIR is slighted heavily in favor of the developer and has not
considered the residents of Trilogy who are closer to the wave basin are and associated structures than
any of the communities on 58th. The city council should provide its residents with a written and public
justification of its intent, so there can be no misunderstanding of facts, history and responsibilities. In
addition the city council should certify that THEY PERSONALLY have studied this report and responses
from residents.
Unlike many politicians who vote without reading a word of a bill, I trust that our City Council will do
its duty and study the draft EIR and all responses from the citizens of La Quinta before voting.
Regards,
Sandra Stratton
81302 Barrel Cactus Rd.
La Quinta, CA 92253
sstratton@dc.rr.com