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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