2021-04-02 RebrynaFriday, April 2, 2021 at 11:03:13 Pacific Daylight Time
Page 1 of 1
Subject:DIANE REBRYNA SUBMISSION APRIL 2, 2021 Project: Coral Mountain Resort
Date:Friday, April 2, 2021 at 9:50:35 AM Pacific Daylight Time
From:Diane Rebryna
To:ConsulOng Planner
AAachments:REBRYNA SUBMISSION .pdf
April 2, 2021 / 10:51 AM MST
Ms. Nicole Sauviat Criste
ConsulOng Planner, City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
BY EMAIL: consulOngplanner@laquintaca.gov
RE: Applicant Meriweather Developments request for a zoning change in South La Quinta from “Low Density ResidenMal w/golf
course” to” Tourist Commercial”.
MY OPPOSITION, as a South La Quinta resident.
Ms. Sauviat Criste,
Please accept the following PDF document a\ached which includes comments and quesOons to be considered for the preparaOon of the
DRAFT EIR.
I realize that this is a long and comprehensive document, therefore I have tried to categorize my comments in keeping with those in the
NoOce of PreparaOon.
I hope that this will be helpful to you.
I would appreciate acknowledgment of receipt.
Thank you for your consideraOon.
Kind regards,
Diane Rebryna
60149 Honeysuckle Street
La Quinta, CA
92253
1 403 287 8417
RE: 3.2 PROJECT DESCRIPTION, listed in the ORIGINAL N of P, on page 10.
The N of P document states the following, on Page 10
“Low Density Residen/al Land” uses will occupy approximately 232 acres - a maximum of 496 dwelling units....
Tourist Commercial Land …@ 120.8 acres and, “General Commercial land uses will occupy approximately 7.7 acres (
out of 386 ) with up to 60,000 square feet of retail commercial uses available to the general public” (This data is
also referred to in 3.3 Planning Areas chart of the N of P page 16)
QuesIon :
What exactly will be available to the general public in terms of “commercial space”. There is men<on of
restaurants. What other commercial ventures are being considered? Are firm arrangements with the Developer
in place at this <me ? (there are concerns about “ pot shops, liquor stores, or the like“ - although legal, these
could poten<ally contribute to a“rowdiness” factor by virtue of easy access by consumers during day to day
opera<ons as well as during Special Events )
_____________________________________________________________________________________________
The N of P document states the following, on Page 10
... that Open Space RecreaIon land uses will occur on 23.6 acres in the SW por/on of the site
QuesIons are:
Will this “recrea<onal space” be open to the public ? - or only to guests and residents of the Project.
It is likely that the public is currently using this space now for recrea<on, so in other words, is it possible that the
recrea<onal space that has been available up to now to the residents of La Quinta will be “usurped” for exclusive
use by the guests and residents of this PRIVATE resort ...
Comments are made in the N of P there will be hiking, biking and ropes courses - again ONLY for residents and
guests ?
Will there be rock climbing on Coral Mountain ?
_____________________________________________________________________________________________
The N of P document speaks to ConstrucIon and Vacant Land, on Page 11 re: SUB-PHASES ACCORDING TO
MARKET CONDITIONS
... According to the Coral Mountain Specific Plan, project construcIon will occur in eight (8) primary development
areas with buildout anIcipated to occur in three primary phases over approximately 4 to 6 years.
Each primary development area may be broken into sub-phases in response to market condi/ons and consumer
demand. For example, the hotel of up to 150 keys may be constructed in mul/ple sub-phases.
The Conceptual Development Plan ... reflects the an/cipated construc/on sequence and may be non-sequen/al
and adjusted subject to market condi/ons.
Phasing is conceptual and subject to refinement with final engineering design and changes in sequence in response
to market condi/ons.
Comments and QuesIons are:
My interpreta<on of this is that - “market condi<ons and consumer demand” are essen<ally what drives this
en<re Project.
There could be a possibility that land could remain vacant for years and years to come - “all depends”...
It appears that the Developer receives all of the “benefits and breaks” to make “any and all encompassing
decisions” without any firm <me commitment, and the residents of South La Quinta are provided no assurance
as to when and how this Project will be developed out.
Where is the accountability here and commitment in keeping with the Project Objec<ves that were outlined in
the N of P? Especially the “motherhood and apple pie” statement that a Project Objec<ve is to “implement a
plan that recognizes and responds to the natural and aesthe<c character of the property”. It won’t be aesthe<c
if parts of the Development sit vacant/undeveloped for years and years.
N of P says... “project construc<on will occur in eight (8) primary development areas with buildout an<cipated to
occur in three primary phases over approximately 4- to 6-years. Each primary development area MAY be broken
into sub-phases … ( again) IN RESPONSE to MARKET CONDITIONS and CONSUMER DEMAND.” The residents in
surrounding communi<es will be at the mercy of the Developer with no end in sight to the construc<on.
Addi<onally the Developer apparently will have the right to keep asking and asking for changes to the original
plan. I take no comfort with the word “MAY”.
_____________________________________________________________________________________________
In the same vein, as a result of the Developer’s proposal to finish the Project in phases, there will likely be …
ONGOING “UNFINISHED CONSTRUCTION RELATED ISSUES” FOR YEARS TO COME.
For your ease of reference to this par<cular topic , I am addressing these here rather than in EIR Category:
Transporta<on.
Comments and QuesIons are:
1.The construc<on of a 380-acre major development is no easy task, nor does is it come without impacts to
the surrounding community - especially when there is no commitment to finish it by a certain <me.
2.There will be likely be constant and increased flow of vehicle traffic on our roadways for several years which
will cause noise, diesel fumes, disrup<on to local traffic, increase in poten<al accidents/injuries, airborne
dust, pollu<on, smog, loud-speaker noise from construc<on ac<vi<es and overall general construc<on noise.
3.There are long term effects of construc<on to consider - especially in an “open ended” project that is
proposed to be developed over a long period of <me, perhaps with several stops and starts ( depending on
“market condiIons and consumer demand “…). These include dust , soil transport and storage issues,
including its transport by tandem trucks which can cause significant road damage, and also poten<al damage
by road sweepers that will be necessary.
4.Construc<on traffic poten<ally for several years is also a concern. What is the planned truck route(s) for
construc<on ? Where is the dumpsite going to be situated ? Where will construc<on vehicles be parked ?
Will the City require all parking for all construc<on vehicles must be maintained on the development site and
not outside the construc<on fence line?
5.It is a given that road damage will occur. In all cases when major developments damage roadways, Ci<es
have a typical solu<on by requiring the developer to put a Roadway Bond in place. Is this what the City plans
to do with this Developer?
6.Where will the construc<on entrance be ? Does the developer intend to use the main roadway and entrance
into the development as the main thoroughfare for construc<on vehicles and equipment, resul<ng in
disrup<on to the local residents and traffic pamerns throughout the area?
7.How will the main roadway areas coming into the undeveloped vacant land be designed for ingress and
egress from the developed por<on of the property? To mi<gate the traffic quagmire within the development,
will a new service entrance be required on 58th Avenue to detour trades, construc<on vehicles, supply
deliveries and heavy equipment in and out of the development? Could this put pressure on the traffic
pamern along this highly traveled roadway?
8.Increased construc<on traffic and resultant road damage will occur at Ave 58, Madison and Ave 60.
In summary, the above 1 - 8 are ques<ons please about how will this ”open ended construc<on project” and
how increased construc<on will impact the residen<al communi<es around it.
_____________________________________________________________________________________________
ONGOING UNFINISHED “VACANT LAND ISSUES” FOR YEARS TO COME
The “Plan” shows approximately half of the parcel of land being developed, leaving approximately 190 acres of
land as future residen<al development, again vacant and developed over <me. There will be vacant land issues
ongoing for years, as a result of the Developer’s proposal to finish the Project in phases that are “open ended”.
Comments and QuesIons are:
1.How will the proposed VACANT land be handled by the Developer ? How long will the land be lep vacant by
the Developer?
2.Vacant land ( proximal to construc <on) is subject to becoming a dust bowl. How will the Developer mi<gate
this ?
3.How will the Developer handle future construc<on of the vacant parcel of property, should this development
be approved. What will the impact of ongoing construc<on on the vacant land be to the success of the
development ? How will it impact residents, guests, visitors and the community at large, all who will be
subjected to repeated construc<on impacts again and again ?
4.Will the vacant land become a “staging area” for ongoing construc<on for years and years - in other words an
eyesore ?
5.How will the developer control natural water run-off, erosion, drainage, ponding and flooding and
construc<on waste while the parcel of property remains dormant? Will there be standing water that will be
a host for mosquito infesta<on, rodents, odours, etc and therefore nega<vely impact the surrounding
communi<es ?
6.Will the Developer be required to install a finished wall and landscape the en<re perimeter prior to
construc<on on the Project ?
_____________________________________________________________________________________________
The N of P document states the following, on Page 12 re: SPECIAL EVENTS
... The project applicant an/cipates the poten/al occurrence of special events involving a_endance of up to 2,500
guests per day for up to 4 days (up to 4 events per year), and
AND
on Page 28 re: (Temporary Use Permits) TUPs for Special Events
... are required by the City to accommodate special, unique, or limited dura/on ac/vi/es that might otherwise be
outside the provisions of normal zoning. Temporary uses are an/cipated and allowed by the Specific Plan.TUPs are
reviewed administra/vely by the Design and Development Director and do not require a public hearing.
Comments and QuesIons are:
Special Events will impact the surrounding residen<al communi<es mostly with respect to the NOISE and
TRAFFIC / TRANSPORTATION categories as per the EIR.
The holding of “Special Event”s means more people - up to 2500 - in a given loca<on at given <mes. It is a given
that there will be NOISE ISSUES that will affect the proximal residen<al communi<es . I will address some of the
NOISE concerns and ques<ons regarding Special Events later in the EIR component of this document, however I
will provide some other comments and ques<ons here:
1.How do we know that there will not be an applica<on by the Developer to hold events more than 4 days per
year ? Would the en<tlement that is being considered permit an uncontrolled number of special events,
without any public consulta<on ? … because they are an<cipated and allowed by the Specific Plan ?
2.Immediate concerns raised are increased traffic, parking issues and the an<cipated resultant conges<on not
only for the Special Events themselves but for “set up and take down <me” - a few days before and a few
days aper .
3.With Special Events, increased Tra ffic will occur and there will be resul<ng conges<on issues:
During Surfing and/or Special Events, all the roadways converging to this parcel of land, surrounded by
beau<ful, serene residen<al communi<es and golf courses will be backed-up with cars coming from
Interstate 10, Highway 111, Jefferson Street, Madison Street, Monroe Street, 58th Street, 60th Street
and alternate roads snaking through and avoiding the traffic jam.
There will police vehicles and flashing light everywhere, amemp<ng to control traffic with barricades
and traffic police. Who is going to pay for all these services? Does the City of La Quinta realize that
this could be “real” problem and have a plan on how this will be handled ?
Our neighborhoods already experience challenges with Ironman, numerous running and cycling events,
Coachella / Stagecoach Fes<vals etc. and the coming of SilverRock and Pendry hotels along with their
intended events.
Has the number of events already in play for this area taken into account the stressors on the
environment ?
There will likely be parking jams with bomlenecks and effects of conges<on in the area. We open see
this with PGA Special events - typically held only once a year - what about 4 or more addi<onal Special
Events added to this mix ?
6. With Special events, there will be Parking / Pedestrian safety concerns
There have been references made to off-site parking and a shumle service that will be transpor<ng
spectators to and from the parking lot to the event. What is the Developer’s plan to provide all the
necessary parking stalls for the permanent residents, temporary residents, hotel guests, hotel and event
staff, surfing professionals/ par<cipants, security personnel, media personnel, etc. required for Special
Events ?
If off-site parking is approved by the City, where will this parking lot be located? If it is off site, there
will also be safety concerns for the pedestrian amendees - as they try to exit the area and walk down the
exis<ng roadways. Mayhem could result with emergency police and EMT vehicles amemp<ng to deal
with the impacts of conges<on with people and vehicles.
This will significantly impact our community and will require addi<onal safety security and police
resources. Has the impact of these demands been considered ?
7. Will all of these Special events be open to the Public ?
If not, what is the benefit of PRIVATE Special Events to the residents of the City of La Quinta ?
I am concerned because there appears to be no straight answer as to who can amend these
proposed Special Events. So, I pose the ques<on, will these Special Events be closed or open to the
Public ?
We’ve heard the argument that as La Quinta residents, we are well aware of the addi<onal demands
placed on our community infrastructure by events like Coachella, Stagecoach and even the Triathlon,
and these Special Events will be no different.
However, and I feel this is the big difference, these events above are only a few weeks a year and these
events benefit commerce in all of La Quinta enormously.
Special Events at this Surf Park , if Private, will ONLY benefit its residents and guests.
I wonder if it is highly likely that the target market for these Special Events will be tourists so that they
can come and stay and partake in the ac<vi<es in the Private Resort and of course increase the
Developer’s revenue, and not benefit the en<re City of La Quinta’s residents and merchants.
RE: 3.7 PROJECT IMPLEMENTATION , listed in the ORIGINAL N of P, on page 28
RE: a General Plan Amendment & 2. RE: the Zone Change:
... both for which approval is sought by the Applicant ...and both require hearings before the Commission and
Council
... reques/ng approval of a General Plan Amendment to change the Land Use Map for the project area to General
Commercial, Low Density Residen/al, Tourist Commercial, and Open Space Recrea/on;
... a Zone Change to revise the City’s Zoning Map to Neighborhood Commercial, Low Density Residen/al, Parks and
Recrea/on, and Tourist Commercial;
Comments and QuesIons are:
The Project simply does not fit with the character of the “neighbourhood”. It would be a “theme park like”
environment essen<ally “inserted” right into the middle of mul<ple quiet residen<al communi<es.
Rezoning will create a “slippery-slope” with no end in sight. Once this parcel of property is rezoned to T/C, the
surrounding vacant parcels of land would likely be vulnerable to other commercial developments that will either
support the Surf Park or amempt to compliment it with other developments that will adversely affect the en<re
character of this region.
Re-zoning is the crux of the issues that are concerning. Rezoning will allow for the Developer’s “foot in the door “
and then possibly for changes to the original plan. At one point, the management of this proposed project
represented that they planned this to be a high end residen<al community compa<ble with surrounding
residen<al areas, but with more informa<on, it now appears to be morphing into a short term vaca<on rental
property with a strong commercial “theme park” character.
“Sub phases” have been referred to previously as the build out starts only on part of the parcel. This allows the
Developer the la<tude discussed earlier. There are concerns that the Developer will ask the City of La Quinta for
variances to add addi<onal Wave Pools, more commercial structures, stadiums for music concerts and another
hotel to the remaining vacant 200 acres. It is understood that this is being done at Kelly Slater Surf Ranch,
Lemoore, Calif. I am concerned that this will be easy for the Developer, should they get the requested zoning
change to Tourist / Commercial.
On the issue of the proposed Tourist Commercial Zone Change and STVRs :
In La Quinta, in the case of Tourist Commercial zoning, there are 345 acres currently zoned T/C of which 138
acres are not developed (40% not developed). It has been argued that we need more T/C zoning to support
tourism and help deal with the short term rental problem.
It has been proposed that, from an environmental perspec<ve, rather than expanding the acreage under T/C,
there should be a drive to get the current acreage developed. There is no need for addi<onal TC zones if what we
have is not being used. In our par<cular area of South La Quinta, there are three T/C zoning areas rela<vely near
to us already.
Another interes<ng fact to note is that the highest vacancy rate in La Quinta is office space - 26%. It is given that
the City is concerned about STVR and assuring enough supply as the City curtails STVR permits. Developers and
the City are looking at ways to convert unused office space for rentals. For example some of the offices above
Old Town could be rental units. All without major new zoning.
The City does not need to rezone the Meriwether property to T/C to add to supply of short term rental, it can
work with developers to convert some of the vacant commercial proper<es to rental. They are located in the
right place, like Old Town, not in amongst quiet communi<es. Again this resort will be PRIVATE, so it will offer no
benefit to offset the shortage of STVR issues that the City faces.
In summary, we do not need addi<onal T/C zones in our residen<al neighbourhood. There are other solu<ons
that that the City should consider.
RE: a TENTATIVE TRACT MAP, which approval is asked for by the Applicant - The N of P document states the
following, on Page 28
“... future TTMs MAY* be filed with each phase of development as necessary to implement the balance of the
project” ( *my underline and embolden)
Ques<on:
What exactly does the word “MAY ” imply - “change aper change aper change” with delays interjected ?
Again, how can our residen<al communi<es have a comfort level with the word “MAY ” ?
_____________________________________________________________________________________________
RE: 4.0 Environmental Impact Report ( EIR) listed in the ORIGINAL N of P, on page 30 It is acknowledged that
... The EIR will
•evaluate the environmental effects of the project in accordance with the latest
regulatory requirements,
•determine whether significant impacts will occur,
•idenIfy feasible miIgaIon measures to minimize or avoid any potenIally significant environmental
effects of the proposed project, and
•evaluate a reasonable range of alternaIves to the proposed project.
A.EIR - AestheIcs, on page 31
The following is stated in the N of P
... The proposed uses and structures would have a poten/al effect on aesthe/c resources.
... The proposed project’s impact on exis/ng scenic vistas as well as the scenic quality in the area will be
evaluated in the EIR. This evalua/on will analyze the proposed features, such as the Wave basin, associated
structure heights, building character, mass and heights, and project landscaping.
... Historic structures occur on the project site, as does the significant rock outcropping that is Coral Mountain.
Therefore, the project’s impact to scenic resources, including but not limited to, trees, rock outcroppings, and
historic buildings within a state scenic highway will also be analyzed in the EIR.
...The project will introduce light and glare associated with commercial, residen/al and resort development to a
site that is currently vacant and does not emit any light or glare. The project proposes a recrea/onal Wave
basin, including 80-foot light poles, to illuminate the Wave basin in the evenings. Therefore, poten/al light and
glare impacts to day/me and nighkme views in the area as a result of project development will be analyzed in
the EIR.
Comments and QuesIons are:
This Project proposes a PRIVATE mixed use community that essen<ally centres around a Surf Resort that, in
essence, is equivalent to a theme park environment.
This Project does not “fit” here - it will challenge, obliterate and take away from how the scenic vistas of this
area will appear in the future.
It is incompa<ble with the surrounding environment and will forever challenge the peaceful ambience in an area
that is revered for both recrea<onal opportuni<es and its serenity for both La Quinta residents and visitors alike.
People are in awe when they come to visit this area, as the Coral Mountain area with its access to Lake Cahuilla
and the Coral Mountain Park has been described as some of the best scenery in the world. This is the
“quintessen<al rocky desert” - with the added benefit of containing and being surrounded by incredible features
of historical, paleontological and archeological significance.
Why is it even being considered that a “a fossilized reef from an ancient coastline” form a backdrop to a surf
resort ? The Developer makes reference to this in one of its many promo<onal “youtube videos” - there is one
is en<tled “Coral Mountain on Loca<on” … (I would encourage a look at this - sorry, link will not copy and paste ! )
From this promo<onal video … “The Coral Mountains will soon become the backdrop to the world’s most
consistent and perfectly designed Surfing Wave “.
As of this <me, the Developer has already placed signage indica<ng this is private property - par<cularly
ominous in light of what is being proposed.
Regarding the N of P acknowledged “light and poten<al glare” concerns - 80 foot (essenIally 8 stories !)
illuminated towers will “pepper” the day skies because of their visibility over the 6 foot fence ( imagine cell
towers like this everywhere … ) and forever challenge La Quinta’s beau<ful desert night skies.
B. EIR - Air Quality and Greenhouse Gas Emissions, on page 32
The following is stated in the N of P...
... The project has the poten/al to generate criteria emissions and greenhouse gas emissions in excess of SCAQMD
(South Coast Air Quality Management District) standards.
Comments and QuesIons are:
It is assumed that, because of proprietary concerns, that Kelly Slater et al is reluctant to make public any
informa<on regarding general and required chemical maintenance of the wave basin and its water contained
therein. Therefore the impacts are not known at this <me with respect to the applicable air quality plan.
It is not known whether sensi<ve receptors will be exposed to substan<al pollutant concentra<ons.
It is not known if there will be any associated lingering pollutants or odors that will impact the environment or
impact the people or the biology of the area, and what could be an issue with dispersion as a result of the
prevailing winds that this area is known for.
I look forward to the results of the EIR analyses including a “stand alone air quality study “ and a “green gas
house study” .
It is concerning, however, that there are no other wave pool parks situated in a comparable desert environment
that allow for comparison regarding ambient air condi<ons and wind condi<ons - so how will these studies will
be conducted. Will there be a comparison of “apples” to “apples”?
C. EIR - Biological Resources , on page 33 The following is stated in the N of P...
... The project is NOT an/cipated to have a substan/al adverse effect on any riparian habitat or other sensi/ve
natural communi/es, since there are no jurisdic/onal waters and no lakes, rivers, or stream beds onsite.
Comments and QuesIons are:
I am looking forward to the results of the “biological survey and records search” regarding sensi<ve or special
status animal species located within the boundaries of the Project and hope that this category will be addressed
in the EIR in a fulsome manner.
There are species that could be significantly adversely effected by this Project. Big Horn Sheep are known to
frequent this area. What will the effects of the Wave Park be on their popula<on? Desert mountain sheep are on
the endangered list. Coral Mountain (and its surrounding areas) is their habitat. It is known that human ac<vity
is not good for them.
The following comments are of note from 2.24 CVCC LaQ Barrier FEIR Final 4.10.19 : “Bighorn sheep popula<ons
fluctuate over <me, and although the local bighorn sheep popula<on may increase over short periods, it is clear
that bighorn sheep do not benefit in the long-run from access to urbanized areas... The hills and mountains of
the La Quinta region provide suitable habitat for PBS, with numerous natural water sources and a variety of
forage occurring at different <mes and at different loca<ons. PBS have occupied the region con<nuously for
thousands of years. The amrac<on of PBS to urban lands ... for forage and water has made them vulnerable to
hazards including ... oleander poisoning, vehicles, and the spread of disease. While bighorn sheep popula<ons
will fluctuate, condi<ons that are found in urban areas are detrimental to the long-term health of the local herd
and the species”.
This Project as proposed will be built out as the “ul<mate” urban area - which is obviously of concern.
Addi<onally, a local tour guide advised me that the biological effects to flora and fauna of this Project on this
area will be “horrible”. Reference was also made to a desert thrush /warbler bird that lives here and is
protected. Although this person may not be viewed as an expert , nor someone who can speak with authority,
this comment is very concerning to me.
D. EIR - Cultural and Tribal Cultural Resources
... In addi/on to the project-specific Geotechnical Inves/ga/on, a project specific Paleontological Resources
Assessment will be included in the EIR to iden/fy any significant, non-renewable paleontological resources that may
exist within or adjacent to the project site ( see also F below under Geology and Soils )
Comments and QuesIons are:
I am looking forward to informa<on in the EIR that will address whether the Project will cause a substan<al
adverse change in the significance of an historical resource, cause a substan<al adverse change in the
significance of an archaeological resource or disturb any human remains, including those interred outside of
formal cemeteries.
Addi<onally, there is substan<al interest in whether the the Project, DURING CONSTRUCTION and
OPERATIONALLY, will cause an adverse change in the significance of a tribal cultural resource ... in that it would
affect a site, feature, place, or cultural landscape, sacred place, or object with cultural value...
How will the archeological, tribal and paleontological artefacts located in the area of the Project be protected?
What will the impact of the Project’s proposed adjunc<ve private recrea<onal ac<vi<es (beyond the surfing
experience) be on the historical artefacts, features and landmarks of Coral Mountain and surrounding areas ?
How will residents and visitors who currently enjoy access to these cultural and historical ameni<es be restricted
from con<nuing to access and enjoy these artefacts, features and landmarks, once this Project is built out? There
are discussions that these areas will be closed and private, accessible only to the private residents and guests of
the Project. Again, the Developer has already posted signage that indicates that this is Private Property.
E. EIR Category - Energy Resources
Comments and QuesIons are:
It is hoped that there will be a fulsome EIR report with respect to this Category including the analysis of Project
related impacts to the energy resources during both construc<on ac<vi<es AND opera<on.
What about the impacts of off-sight improvements that will be necessary ?
It is also hoped that there will be details provided as to where the energy for this project will come from - no<ng
that the N of P states the following: "The project site, located at the southwest corner of Avenue 58 and Madison
Street, lies within the service area boundaries of Imperial Irriga<on District (IID) for electricity and Southern
California Gas Company for natural gas”. Will the Wave Pool require natural gas to heat it in the winter ?
On the mamer of energy, desert residents are rou<nely asked to conserve energy. There have been rolling
blackouts periodically in So Cal to accommodate extreme energy requirements. What kind of energy load will
this Project - both during construc<on and opera<onally - put on So. La Quinta residents ? It is extremely difficult
to find this informa<on out due likely to proprietary constraints.
In other words, it is known that the exis<ng infrastructure is capable of suppor<ng the addi<onal loads?
Who will pay for the upgrades iden<fied in the N of P stated here: “... the project will be required to install an
off-site transformer bank at an exis<ng IID substa<on located at 81600 Avenue 58 as part of proposed upgrades.
Construc<on for the conduits and line extension would occur in the exis<ng right-of-way.” .
F. EIR Category - Geology and Soils
The following is stated in the N of P...
... A site-specific Geotechnical Inves/ga/on is required for the project property, to inves/gate the geotechnical and
soil condi/ons at the site.
... The project site is not located within an Alquist-Priolo fault zone. However, seismic ac/vity that may occur on
either the San Andreas fault zone (approximately 7.75 miles northeast of the project site), or San Jacinto fault zone
(approximately 14 miles southwest of the project site) could result in severe ground shaking
as PER: Excerpts From the Zoom Scoping Mee/ng of March 30, 2021 …
It is common prac/ce that a geotechnical inves/ga/on is performed by a Professional Engineer prior to
development plans proceeding for a project. The purpose of the geotechnical inves/ga/on is to determine the
nature and condi/on of the exis/ng subsoils and to determine if they are suitable for the proposed development. It
is surprising that we are speaking of a project significantly progressed in its planning stage without having a
geotechnical inves/ga/on performed to determine if the site is even suitable from a soils perspec/ve for the
proposed use.
The city’s own La Quinta 35 Document provides informa/on that indicates that the proposed development will be
situated on compara/vely young Alluvial soils that have a moderate to high liquefac/on poten/al. The document
also states that liquefac/on can occur during seismic events or from ground vibra/ons of rela/vely long dura/on
with an intensity over 0.2g.” h_ps://www.laquintaca.gov/home/showpublisheddocument?id=33565
This document also states that this site will be adversely affected by liquefac/on by a seismic event on the San
Andreas or San Jacinto fault line. Addi/onally, there are two currently inac/ve rock faults adjacent to the proposed
wave park’s loca/on which may also come into play. Has there been any considera/on given to the energy induced
in the ground by repe//ve wave ac/on and vibra/on from the wave genera/on equipment ?
The alluvial soils in the Coachella Valley have a long history of subsidence as they are a rela/vely young deposits,
par/cularly near the base of mountains where fluvial deposits may also exist. The wave park may trigger localized
subsidence of these weak deposits by the constant energy release from the waves.
What steps will be taken to ensure that the wave park does not permit seepage of water into the ground? Any loss
of water into the ground will create a perched groundwater condi/ons which will only exacerbate the liquefac/on
poten/al of the soil and may induce localized se_lements or subsidence.
If there is water seepage into the ground, an assessment of the impact the seepage may have on the subsidence of
adjacent structures and communi/es is necessary.
The US Forest Service has published a document en/tled “Don’t bust the biological soil crust: Preserving and
restoring an important desert resource”. This document describes the vital importance of the biological soil crust in
arid areas in preven/ng soil erosion and crea/ng an ecosystem for the desert flora and fauna to establish. What
impact will the development have on the soil crust and was steps will the Developer take to prevent irreversible
damage to this vital ecosystem?
What is most concerning to me is the phrase from the above - “It is surprising that we are speaking of a project
significantly progressed in its planning stage without having a geotechnical inves/ga/on performed to determine if
the site is even suitable from a soils perspec/ve for the proposed use”. The Developer purchased this property -
was this an aperthought that a Surf Resort with a Wave Pool be placed here ? Perhaps like what happened in
Florida ? hmps://www.floridatoday.com/story/news/local/2019/05/31/plans-sink-wsls-kelly-slater-designed-
wave-pool-florida-surfers/1298225001/
I look forward to the results of the site-specific Geotechnical Inves<ga<on.
G. EIR Category - Hazards and Hazardous Materials
The following is stated in the N of P...
... “Implementa/on of the project would facilitate new growth and development throughout the project area.
Resort, commercial, residen/al, and recrea/onal developments would result in an increased popula/on of residents
and non-residents that would have both the potenIal to be suscepIble to hazards, and to uIlize hazardous
materials”
Comments and QuesIons are:
It is expected that a fulsome EIR analysis will be performed regarding the Project-related impacts to the
transport, use, or disposal of hazardous materials, and the release of hazardous materials into the environment
that can impact the environment, people and wildlife, both during construc<on and opera<on.
It has not been made public what hazardous materials WILL be used in the opera<onal aspect of the Project. For
example, what chemicals will be used to keep the water clean in the wave pool ?
Will a workplace Hazard Assessment(s) as per OSHA be performed and the results made public ? … The
gentleman who spoke at the Scoping mee<ng indicated that there will be a review of poten<al safety concerns
for construc<on workers with respect to hazardous materials, amongst other concerns, at the Project workplace.
Addi<onally, will poten<al biological hazards to the public be addressed and assessed for ? hmps://people.com/
health/man-dies-brain-ea<ng-parasite-swimming-wave-pool/
Will there be informa<on in the EIR regarding the implementa<on of an emergency response or evacua<on plan
due to inadvertent hazardous material release.?
H. EIR Category - Hydrology and Water Quality
The following is stated in the N of P...
... The EIR analysis will consider how the flood protec/on solu/ons will be incorporated into the site design, storm
drain infrastructure, and water quality management prac/ces in rela/on to the applicable regulatory standards
that apply during construc/on and opera/on of the proposed development.
... The EIR will analyze the project’s site design measures to prevent interference with exis/ng groundwater
recharge facili/es located south of the project.
Comments and QuesIons are
To make sure that my comments were reasonable in the context of an EIR, I am using this defini<on of
“Hydrology” from Wikipedia. … is the scien/fic study of the movement, distribu/on, and management of water on
Earth… and other planets, including the water cycle, water resources, and environmental watershed sustainability”
While I will not amempt to address all details that relate to Hydrology (which I understand could include Water
Conserva/on Measures; you will remember that I made a presenta/on at the Scoping Mee/ng on this topic), I
would like to ask this ques<on please…
Since the Developer conInually asserts that the “Project will use less water than a golf course”….
Can the EIR please address this statement and its ramifica<ons please ?
Based on informa<on received regarding water evapora<on at the Kelly Slater Surf Park in LeMoore
California, I and other residents are concerned that the water consump<on for
this new Wave pool has been significantly underes<mated by the Coachella Valley Water District.
This is of great concern during a California Drought, considering the Coachella Valley is in the process of
approving four Surf Parks and has relied on the same informa<on.
AS PER: Excerpts From the Zoom Scoping Mee/ng of March 30, 2021 …The majority of the drinking water
consumed by the residents of the Coachella Valley is from the underground aquifer. Water for irriga/on primarily
comes from the Colorado River. The aquifer is recharged by a canal bringing water from the north and then
introducing it into the aquifer just to the south of the site’s proposed loca/on… How will the aquifer be impacted
considering as well that the N of P states that” the source of the water for the project is from two wells
proposed for the site”. Can the EIR please address the impact of TWO wells.
Can the EIR please comment on the environmental effects on the residen<al communi<es surrounding it, in the
event of a flooding of the contents of the Wave Basin due to seismic ac<vity ?… considering the following
informa<on below in small font :
With respect to a potenIal flooding event from the Wave Pool in the event of seismic acIvity, there are possible insurance issues
to all residenIal communiIes’ residents… If there was an earthquake and a flood resulted from this Project, I have been provided the
following informa/on ... “Earthquake policy would cover only earthquake damage. In the scenario where there is an earthquake
followed by a flood you would need flood coverage as well. The standard NFIP flood policy provides 250k for the dwelling and
100k for contents.. the cost around $500 annually. There could be liability on the water park and City of La Q if water escaped
from there and damaged neighbouring homes... “ .
Where would the discarded water from the water basin go ? - is it of a quality that it could be “recycled” for use
elsewhere ?
I. EIR Category - Land Use Planning
The following is stated in the N of P...
... the N of P states The surrounding developments are gated and operate separately from each other. The proposed
project occurs on vacant land, and will not impact operaIon of surrounding residenIal projects, currently or in
the future, and development of the proposed project will not divide an established community.
QuesIons and Comments are as follow:
While an EIR assessment of this par<cular category “Land Use Planning” may not be planned for, I wish to be on
record that I strongly object to this broad statement above in the N of P which is highlighted in yellow.
There are indeed many environmental impacts as a result of this Project - related to both construc<on and the
opera<on - on the surrounding residen<al communi<es asa result of zoning changes that are ALL outlined with
in this document including aesthe<cs, noise, circula<on / traffic, drain emergency services and public u<li<es etc.
Also, just because an established community is “not divided”, does not meant that there is no impact to the
surrounding residen<al projects - now or in the future.
J. EIR Category - Noise
The following is stated in the N of P...
... “The proposed project is consistent with the City’s residen/al and residen/al and resort character.” , and that
... A project-specific noise impact analysis will be prepared.
... Poten/al impacts of noise associated with project construc/on and opera/on will be analyzed and addressed in
the EIR ... Addi/onally, project-generated groundborne vibra/on and groundborne noise levels will also be analyzed
in the EIR
Comments and QuesIons are:
NOISE is one of my and my fellow residents’ greatest concerns and its impact on the residen<al neighbourhoods
that surround the proposed Project MUST please be considered in a fulsome manner in the EIR.
With respect, I fail to understand the comment highlighted above from the N of P as to how this Project is
“consistent with the City’s residen<al and resort character” …
How has that determina<on been made ?
There are no other opera<onal surf/wave parks to compare it to and I seriously doubt that this
can be compared to say, for instance, the “La Quinta Resort “both in terms of the ambient air noise and
noise that is generated by the people and the ac<vi<es that take place there. hmps://
www.laquintaresort.com
Interes<ngly, and perhaps as an aside, when one goes online to view wave pool videos, there is never any
opera<onal sound, only visuals. That seems consistent with a lot of noise being generated by the waves and
possible vibra<on - so that the speakers are essen<ally drowned out.
I am very concerned about how a noise analysis will accurately capture the sound of the actual wave basin itself.
Even if one was to visit another surf/wave complex, this Project purports to be different - “bigger and bemer”.
The noise generated could be unique to this loca<on in that many experts feel that Coral Mountain acts to
amplify noise. For example, local residents who are not even that close by, report hearing hikers speaking. What
impact will the mountains have on direc<ng the opera<onal noise back towards the exis<ng communi<es ? Will
the mountains act like a “bandshell” and exacerbate this ?
Compound this with all of the addi<onal noise that will come from a theme-park seung like this; noise will be
generated by the guests and those who partake in the other ac<vi<es being offered up.
The “noise categories” as per the analysis for the EIR and their impact on the surrounding residen<al
communi<es must please include reference to the following:
1.The construc<on noise associated with the actual construc<on of the wave basin itself. This will not be your
average residen<al development - where houses and a golf club will be built. This is a massive construc<on
project.
2.The noise from “Special Events” : As addressed prior, at least 4 are proposed - perhaps there may be more?
These Special Events will include por<ons that will likely be broadcast on major networks or filmed. What
will be required for filming or broadcas<ng ; for example, will there be helicopters circling the area with
nega<ve impacts on the residen<al communi<es that surround the Project ?
3. The day to day opera<onal noise: In addi<on to the waves “crashing(?) ” at the Project, there will /could be:
Surface water crap used in the day to day opera<on of the wave pool - jet skis constantly in use.
Loudspeaker systems used to announce the waves - “EVERY THREE MINUTES - ALL DAY EVERY DAY” ...
when the wave pool is ac<ve - which will be be from 7 AM - 10 PM.
Music playing con<nuously ?
Noise from a Jumbotron? It’s been said that that a Jumbotron will be installed. If so, will its picture be
accompanied by commentary? How loud with this commentary be? During what hours ?
Various numbers and types of sound genera <ng equipment will be used to generate the waves i.e. noise
from the Hydrofoils as per the following which copied off the Lemoore Wave Park website: “The 100
ton hydrofoils run down a track with the help of more than 150 truck <res at around 18 miles per
hour” . This wave pool is BIGGER than that at Lemoore. What will the impact of this be?
Noise from other recrea<onal ac<vi<es ? - what would this be ?
To summarize …
Will there be a CUMULATIVE noise analysis performed that will look at all of the above, par<cularly the impact
of those point in (3. above, and 2. and 3 above) , that is,
When Opera<onal (3.), and
When both Opera<onal AND when Special Events (2.and 3.) are taking place.
In other words, how will all of the noise together in the worst case scenarios impact the surrounding residen<al
areas? - par<cularly when there is the poten<al to echo off of Coral Mountain.
It is also hoped that opera<onal aspects during both day and evening hours will be considered as part of a
comprehensive noise study.
In addi<on to the noise that will be generated when Opera<onal, the proposed Project sub phase development
is another important considera<on. Residents of surrounding communi<es could be subject to construc<on
noise over the course of many years, should this Project be approved as proposed. If sub phase development is
approved, there will be <mes that we will be required to endure BOTH construc<on and opera<onal noise.
We wish to state empha<cally in conclusion that the NOISE impacts will be considerable and nega<ve in terms of
impact to the residen<al communi<es that surround it.
FYI, The City of La Quinta has published a document en<tled “La Quinta 2035 General Plan Environmental
Hazards” and includes NOISE in that category. This document states the following:… ”Careful considera/on of
each future project will be required to assure that compa/bility is maintained. The City’s ongoing efforts to preserve
the quality of life for all its residents, present and future, must include the protec/on of a quiet noise environment”
K. EIR Category - PopulaIon and Housing
For the record, and acknowledging that PopulaIon and Housing will not be considered in the EIR...
The following two statements are made in the N of P ... and I believe that they contradict each other:
Under PUBLIC SERVICES (CATEGORY FOLLOWS NEXT ) it says the following “ImplementaIon of the proposed
project WILL increase the permanent populaIon which could have an impact on the City’s public services”;
YET IN THIS POPULATION AND HOUSING SECTION, it says: “The project is not anIcipated to result in an indirect
growth inducing impact because the exisIng infrastructure has been sized to accommodate long term growth”
I believe that there is some merit to addressing this inconsistency for the purpose of ongoing accurate
communica<ons.
L. EIR Category - Public Services
Comments and QuesIons are:
Will this Category in the EIR address required burdens due to the following which are necessary:
Law enforcement and emergency response personnel
Vehicles and supplies
Infrastructure, including buildings
Will the budget be studied - now or later?
Are the local medical emergency facili<es prepared to poten<al increased usage and associated types of
common injuries
M. EIR Category - RecreaIon
For the record, and acknowledging that RecreaIon will not be considered in the EIR …
Comments and QuesIons are:
There is a concern here that I wish to register for the record ... as per CEQA checklist (b) and the N of P, this
Project DOES include recrea<onal facili<es which COULD likely have an adverse physical effect on the
environment, ( par<cularly the water in the wave pool / basin ).
Other proposed ac<vi<es include “hiking, biking and ropes courses”. Will these have the poten<al to damage
Coral Mountain and its terrain, as well as its paleontological and archeological ameni<es. For example, could this
Project damage the “Ancient Coral Reef” - either during construc<on or during its opera<on.
Why was the decision made the decision to exclude this EIR Category: RECREATION from the EIR ?
N. EIR Category - TransportaIon ( including traffic )
The following is stated in the N of P...
... the City is ... preparing a traffic impact analysis, vehicle miles traveled analysis, and Hazard Assessment”
... The project will generate trips associated with residen/al, commercial and resort development, which could
impact the City’s circulaIon system.
... In addi/on, the project includes special events at the wave basin facility which would result in increases in trip
generaIon during short periods of Ime.
Comments and QuesIons are:
TRAFFIC is one of my and my fellow residents’ greatest concerns and its impact on the residen<al
neighbourhoods that surround the proposed Project MUST please be considered in a fulsome manner.
Undoubtedly, we will see and be subject to an increase in traffic as would be expected to occur when a
commercial venture is “inserted” into what was originally zoned as a residen<al area.
Some ques<ons and concerns at this <me are listed here and undoubtedly more will present as we receive more
informa<on:
1.Does the developer intend to use the main roadway and entrance into the development as the main
thoroughfare for construc<on vehicles and equipment, resul<ng in disrup<on to the local residents and
traffic pamerns throughout the area ?
2.The main entrance into the Surf Park development is only from the south-bound lanes of Madison,
south of the intersec<on of 58th Street. How does the developer plan to allow vehicles to egress when
there is a landscaped median preven<ng exi<ng in a north-bound direc<on? Will this require vehicles to
perform a U-turn at the intersec<on of Madison and 60th Street? If the developer plans on modifying
the median to allow this turn in the north-bound direc<on, how is this feat accomplished so close to the
intersec<on? Will the 58th Street and Madison intersec<on require a signal system in all direc<ons?
3.We have no public transporta<on in this area ... what is the impact of this on the traffic impact
analysis ?
4.Because of the sub-phase development proposal we will have increased construc<on traffic for YEARS
5.Who will pay for these modifica<ons ?
6.Can the Project provide adequate parking and other needs for all planned ac<vi<es, including Special
events on site; if not, why would this be acceptable ?
O. EIR Category - UIliIes and Service Systems
The following is stated in the N of P...
... The development of the proposed Coral Mountain Resort project would increase the demand for u/li/es in the
City. The service, loca/on, /ming and construc/on of on- and off-site improvements required for all u/li/es will be
included in the EIR analysis.
... The project will require two well sites to adequately serve the site.
The EIR and DRAFT EIR will address the following:
... The City determined that the proposed project requires the prepara/on and approval of a
Water Supply Assessment and Water Supply VerificaIon
... The well sites will be located within the project’s exis/ng footprint and will be analyzed in
the EIR.
... stormwater management ( linked to Hydrology and Water Quality Sec/on of EIR )
... The service, locaIon, Iming and construcIon of on- and off-site improvements required for all uIliIes will be
included in the EIR analysis.
... Project design features and miIgaIon measures during construc/on and opera/on would be iden/fied in the
Drav EIR.
Comments and QuesIons are:
It is hoped that the EIR will be fulsome and address the following:
1.That there is and can be sufficient capacity in the current or expanded u<lity network to accommodate the
addi<onal load placed by this Project - during Construc<on and when Opera<onal - including an<cipated
sub-phase loads.
2.Is it possible or an<cipated that there will be further “incremental” infrastructure required for adequate
u<lity delivery ? In other words, the Developer wants to develop in sub phases - do we need to
incrementally add on to exis<ng u<li<es network. This could be expensive so who will pay for this ?
3.What happens if the resort is not completed or not fully developed and we have bought and paid for all of
this ?
P. EIR Category - Mandatory Findings of Significance
Although this Category is not addressed in the N of P, it is referenced in the CEQA Appendix G Checklist.
I will close my comments and ques<ons with the following: In my opinion, I believe that this PROJECT has
impacts that may be viewed as individually limited, but when one stands back and assesses, these are
cumula<vely considerable.
There is no other Project like this in our desert to currently compare to.
In my opinion, there are many poten<al environmental effects that could adversely affect the residents of the
communi<es around it; many of which I have provided my opinion on in the foregoing document.
I am empha<cally NOT in favour of this Project with its proposed en<tlement changes as well as the poten<al
and iden<fied environmental impacts laid out herein.
Thank you very much for your considera<on of my comments.
Diane Rebryna,
60149 Honeysuckle Street
La Quinta, CA 92253
1 (403) 870 2109