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2021-07-02 RebrynaCoral Mountain Resort DEIR Diane Rebryna <drebryna@telusplanet.net> Fri 7/2/2021 12:44 PM To: Consulting Planner <ConsultingPlanner@laquintaca.gov> Cc: Linda Evans <Levans@laquintaca.gov>; Robert Radi <Rradi@laquintaca.gov>; Kathleen Fitzpatrick <kfitzpatrick@laquintaca.gov>; John Pena <jpena@laquintaca.gov>; Steve Sanchez <ssanchez@laquintaca.gov>; cdd@la-quinta.org <cdd@la-quinta.org> 1 attachments (64 KB) July 2, 2021 DRAFT EIR CORAL MOUNTAIN RESORT DEIR.pdf; ** EXTERNAL: This message originated outside of the City of La Quinta. Please use proper judgement and caution when opening attachments, clicking links or responding to requests for information. ** Dear Ms. Sauviat Criste, Please see the following email regarding the DEIR for Coral Mountain Resort. A PDF of this letter is also attached for your reference, should the contents of the email distort during transmission. Thank you, The La Quinta Residents for Responsible Development ---------------------------------------------------------------------------------------------------------------------------- July 2, 2021 Attention: Ms. Nicole Sauviat Criste, Consulting Planner, City of La Quinta Dear Ms. Sauviat Criste: RE: Draft EIR Coral Mountain Resort We, the La Quinta Residents for Responsible Development, are sending this letter to express our concerns regarding the Draft EIR that was released for Coral Mountain Resort. At the outset, we wish to say that this document is beyond comprehension for the average resident of La Quinta. The DRAFT EIR (DEIR) is not in keeping with the 2021 CEQA Statute and Guidelines https://www.califaep.org /docs/CEQA_Handbook_2021.pdf, particularly those laid out in Article 10. Considerations in Preparing EIRs and Negative Declarations: The text that follows in black refers to direct excerpts from Article 10. Our concerns are laid out in RED. 15140. WRITING EIRs shall be written in plain language and may use appropriate graphics so that decision makers and the public can rapidly understand the documents. This document is replete with redundancy - paragraphs and statements, obviously boilerplate, are inserted and re-inserted throughout the document into various categories, where not necessary or where summaries might have been acceptable. We do see the summary of Environmental Impacts and Mitigation Measures TABLE 1-3. While this summary is useful, the background information regarding each section MUST be presented in a manner that a reader can understand. The DEIR fails in this regard. Firefox https://outlook.ofﬁce.com/mail/inbox/id/AAMkAGJiMWY1OTY1LTB... 1 of 4 7/2/21, 2:20 PM 15141. PAGE LIMITS The text of draft EIRs should normally be less than150 pages and for proposals of unusual scope or complexity should normally be less than 300 pages This statement speaks for itself. The DRAFT EIR is well over 700 pages, not including Appendices. This document is unnecessarily LARGE, primarily as a result of of the way it is written - we refer you back to 15140 above. 15145. SPECULATION If, after thorough investigation, a Lead Agency ﬁnds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact. The intrusiveness on the surrounding residential communities with, by way of example but not limited to, the: Lights (including multiple 80-foot towers and commercial glare from buildings and parking lots) Noise (during operation, and that associated with Special Events), and Aesthetics (impacts on the views of Coral Mountain) as presented in the DEIR with the pretext of supportive “scientiﬁc studies/analysis”, is difﬁcult to even read let alone understand, and therefore to allow for our interpretation. We are of the opinion that the declared “negative” impacts of the above in particular are essentially speculative and should be acknowledged as such. The failure to do this greatly concerns us and many residents that we have talked with regarding the DEIR. The phrase that comes to mind, no disrespect intended, is “smoke and mirrors”. This speaks to our concerns about the credibility of the some of the information presented in the document. 15146. DEGREE OF SPECIFICITY The degree of speciﬁcity required in an EIR will correspond to the degree of speciﬁcity involved in the underlying activity which is described in the EIR. An EIR on a project such as the adoption or amendment of a comprehensive zoning ordinance or a local general plan should focus on the secondary effects that can be expected to follow from the adoption or amendment, but the EIR need not be as detailed as an EIR on the speciﬁc construction projects that might follow. We are of the opinion that the “details” of the DEIR obscure the focus on the secondary effects of the Project - in other words, we as the readers, cannot see the “forest for the trees” and therefore have trouble understanding exactly what it is that the DEIR is trying to say. Every attempt should have been made in the DRAFT EIR to ensure, going back to 15140 above, to ensure that the information contained is “rapidly understood” by the reader. We would have liked to stand back upon receipt of the EIR and, after reading, say “WE MAY NOT AGREE... BUT WE DO UNDERSTAND THE SECONDARY EFFECTS”. As the EIR stands now, we are making it known to you that we are unable to do this. 15147. TECHNICAL DETAIL Firefox https://outlook.ofﬁce.com/mail/inbox/id/AAMkAGJiMWY1OTY1LTB... 2 of 4 7/2/21, 2:20 PM The information contained in an EIR shall include summarized technical data, maps, plot plans, diagrams, and similar relevant information sufﬁcient to permit full assessment of signiﬁcant environmental impacts by reviewing agencies and members of the public. Placement of highly technical and specialized analysis and data in the body of an EIR should be avoided through inclusion of supporting information and analyses as appendices to the main body of the EIR. Again, to our points noted. The technical data presented in the body of the DEIR is not summarized or organized in such a manner as to allow for the understanding of the general reader. In summary, from the CEQA Guidelines ...”The DEIR serves as a public disclosure document explaining the effects of the proposed project on the environment, alternatives to the Project, and ways to minimize adverse effects and to increase beneﬁcial effects”. This is the framework that we looked forward to and expected to receive when the DEIR was released, nearly two weeks ago. In essence, the proclamation of “no negative effects “ is evident throughout the document, but the information that is provided within the document to support those conclusions regarding the DEIR categories is virtually undecipherable to us. This is not fair. There is a timed “Process” underway and we are the residents who will be impacted by this Project. We require transparency please. We require a complete understanding of exactly what is impacting us and how. Any mitigation measures presented must make sense. If we, the general public, cannot understand the DEIR, how can we possibly respond accordingly in the manner required of us? Conjecture and opinions will carry no weight. We respectfully request that this DRAFT EIR be retracted and replaced. The replacement document should be created with the following in mind - it should be reasonable in length, with clear and concise language, and without unnecessary repetition. This would allow for “rapid” understanding by readers, and thus it would be in alignment with the CEQA guidelines. Thank you for your consideration of our request. THE LA QUINTA RESIDENTS FOR RESPONSIBLE DEVELOPMENT https://www.saynotothewave.com You may direct any questions regarding this communication to: Diane Rebryna, drebryna@telusplanet.net Derek Wong, derekwong745@yahoo.com Ramon Baez, rfbaez7@gmail.com cc: Linda Evans. Mayor E-mail: levans@laquintaca.gov Robert Radi, Mayor Pro Tem E-mail: rradi@laquintaca.gov. Kathleen Fitzpatrick, Council Member E-mail: kﬁtzpatrick@laquintaca.gov Firefox https://outlook.ofﬁce.com/mail/inbox/id/AAMkAGJiMWY1OTY1LTB... 3 of 4 7/2/21, 2:20 PM John Pena, Council Member E-mail: jpena@laquintaca.gov Steve Sanchez, Council Member E-mail: ssanchez@laquintaca.gov Cherri Flores, Planning Manager, E-mail cdd@la-quinta.org Carlos Flores, Senior Planner, E-mail cdd@la-quinta.org Siji Fernandez, Associate Planner, E-mail cdd@la-quinta.org Firefox https://outlook.ofﬁce.com/mail/inbox/id/AAMkAGJiMWY1OTY1LTB... 4 of 4 7/2/21, 2:20 PM July 2, 2021 Attention: Ms. Nicole Sauviat Criste, Consulting Planner City of La Quinta Dear Ms. Sauviat Criste: RE: Draft EIR Coral Mountain Resort We, the La Quinta Residents for Responsible Development, are sending this letter to express our concerns regarding the Draft EIR that was released for Coral Mountain Resort. At the outset, we wish to say that this document is beyond comprehension for the average resident of La Quinta. The DRAFT EIR (DEIR) is not in keeping with the 2021 CEQA Statute and Guidelines https://www.califaep.org/docs/CEQA_Handbook_2021.pdf, particularly those laid out in Article 10. Considerations in Preparing EIRs and Negative Declarations: The text that follows in black refers to direct excerpts from Article 10. Our concerns are laid out in RED. 15140.WRITING EIRs shall be written in plain language and may use appropriate graphics so that decision makers and the public can rapidly understand the documents. This document is replete with redundancy - paragraphs and statements, obviously boilerplate, are inserted and re-inserted throughout the document into various categories, where not necessary or where summaries might have been acceptable. We do see the summary of Environmental Impacts and Mitigation Measures TABLE 1-3. While this summary is useful, the background information regarding each section MUST be presented in a manner that a reader can understand. The DEIR fails in this regard. 15141. PAGE LIMITS The text of draft EIRs should normally be less than150 pages and for proposals of unusual scope or complexity should normally be less than 300 pages This statement speaks for itself. The DRAFT EIR is well over 700 pages, not including Appendices. This document is unnecessarily LARGE, primarily as a result of of the way it is written - we refer you back to 15140 above. 15145. SPECULATION If, after thorough investigation, a Lead Agency ﬁnds that a particular impact is too speculative for evaluation, the agency should note its conclusion and terminate discussion of the impact. The intrusiveness on the surrounding residential communities with, by way of example but not limited to, the: Lights (including multiple 80-foot towers and commercial glare from buildings and parking lots) Noise (during operation, and that associated with Special Events), and Aesthetics (impacts on the views of Coral Mountain) as presented in the DEIR with the pretext of supportive “scientiﬁc studies/analysis”, is difﬁcult to even read let alone understand, and therefore to allow for our interpretation. We are of the opinion that the declared “negative” impacts of the above in particular are essentially speculative and should be acknowledged as such. The failure to do this greatly concerns us and many residents that we have talked with regarding the DEIR. The phrase that comes to mind, no disrespect intended, is “smoke and mirrors”. This speaks to our concerns about the credibility of the some of the information presented in the document. 15146. DEGREE OF SPECIFICITY The degree of speciﬁcity required in an EIR will correspond to the degree of speciﬁcity involved in the underlying activity which is described in the EIR. An EIR on a project such as the adoption or amendment of a comprehensive zoning ordinance or a local general plan should focus on the secondary effects that can be expected to follow from the adoption or amendment, but the EIR need not be as detailed as an EIR on the speciﬁc construction projects that might follow. We are of the opinion that the “details” of the DEIR obscure the focus on the secondary effects of the Project - in other words, we as the readers, cannot see the “forest for the trees” and therefore have trouble understanding exactly what it is that the DEIR is trying to say. Every attempt should have been made in the DRAFT EIR to ensure, going back to 15140 above, to ensure that the information contained is “rapidly understood” by the reader. We would have liked to stand back upon receipt of the EIR and, after reading, say “WE MAY NOT AGREE… BUT WE DO UNDERSTAND THE SECONDARY EFFECTS”. As the EIR stands now, we are making it known to you that we are unable to do this. 15147. TECHNICAL DETAIL The information contained in an EIR shall include summarized technical data, maps, plot plans, diagrams, and similar relevant information sufﬁcient to permit full assessment of signiﬁcant environmental impacts by reviewing agencies and members of the public. Placement of highly technical and specialized analysis and data in the body of an EIR should be avoided through inclusion of supporting information and analyses as appendices to the main body of the EIR. Again, to our points noted. The technical data presented in the body of the DEIR is not summarized or organized in such a manner as to allow for the understanding of the general reader. In summary, from the CEQA Guidelines …”The DEIR serves as a public disclosure document explaining the effects of the proposed project on the environment, alternatives to the Project, and ways to minimize adverse effects and to increase beneﬁcial effects”. This is the framework that we looked forward to and expected to receive when the DEIR was released, nearly two weeks ago. In essence, the proclamation of “no negative effects “ is evident throughout the document, but the information that is provided within the document to support those conclusions regarding the DEIR categories is virtually undecipherable to us. This is not fair. There is a timed “Process” underway and we are the residents who will be impacted by this Project. We require transparency please. We require a complete understanding of exactly what is impacting us and how. Any mitigation measures presented must make sense. If we, the general public, cannot understand the DEIR, how can we possibly respond accordingly in the manner required of us? Conjecture and opinions will carry no weight. We respectfully request that this DRAFT EIR be retracted and replaced. The replacement document should be created with the following in mind - it should be reasonable in length, with clear and concise language, and without unnecessary repetition. This would allow for “rapid” understanding by readers, and thus it would be in alignment with the CEQA guidelines. Thank you for your consideration of our request. THE LA QUINTA RESIDENTS FOR RESPONSIBLE DEVELOPMENT https://www.saynotothewave.com You may direct any questions to: Diane Rebryna drebryna@telusplanet.net Derek Wong derekwong745@yahoo.com Ramon Baez rfbaez7@gmail.com cc: Linda Evans. Mayor E-mail: levans@laquintaca.gov Robert Radi, Mayor Pro Tem E-mail: rradi@laquintaca.gov. Kathleen Fitzpatrick, Council Member E-mail: kﬁtzpatrick@laquintaca.gov John Pena, Council Member E-mail: jpena@laquintaca.gov Steve Sanchez, Council Member E-mail: ssanchez@laquintaca.gov Cherri Flores, Planning Manager, E-mail cdd@la-quinta.org Carlos Flores, Senior Planner, E-mail cdd@la-quinta.org Siji Fernandez, Associate Planner, E-mail cdd@la-quinta.org