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2021-03-09 SCAQMD SENT VIA E-MAIL: March 9, 2021 consultingplanner@laquintaca.gov Nicole Sauviat Criste, Consulting Planner City of la Quinta, Planner Department 78-495 Calle Tampico La Quinta, California 92253 Notice of Preparation of an Environmental Impact Report for the Coral Mountain Resort (Proposed Project) South Coast Air Quality Management District (South Coast AQMD) staff appreciates the opportunity to comment on the above-mentioned document. Our comments are recommendations on the analysis of potential air quality impacts from the Proposed Project that should be included in the Environmental Impact Report (EIR). Please send a copy of the EIR upon its completion and public release directly to South Coast AQMD as copies of the EIR submitted to the State Clearinghouse are not forwarded. In addition, please send all appendices and technical documents related to the air quality, health risk, and greenhouse gas analyses and electronic versions of all emission calculation spreadsheets, and air quality modeling and health risk assessment input and output files (not PDF files). Any delays in providing all supporting documentation for our review will require additional review time beyond the end of the comment period. CEQA Air Quality Analysis Staff recommends that the Lead Agency use South Coast AQMD’s CEQA Air Quality Handbook and website1 as guidance when preparing the air quality and greenhouse gas analyses. It is also recommended that the Lead Agency use the CalEEMod2 land use emissions software, which can estimate pollutant emissions from typical land use development and is the only software model maintained by the California Air Pollution Control Officers Association. South Coast AQMD has developed both regional and localized significance thresholds. South Coast AQMD staff recommends that the Lead Agency quantify criteria pollutant emissions and compare the emissions to South Coast AQMD’s CEQA regional pollutant emissions significance thresholds 3 and localized significance thresholds (LSTs)4 to determine the Proposed Project’s air quality impacts. The localized analysis can be conducted by either using the LST screening tables or performing dispersion modeling. The Lead Agency should identify any potential adverse air quality impacts that could occur from all phases of the Proposed Project and all air pollutant sources r elated to the Proposed Project. Air quality impacts from both construction (including demolition, if any) and operations should be calculated. Construction-related air quality impacts typically include, but are not limited to, emissions from the use of hea vy-duty equipment from grading, earth-loading/unloading, paving, architectural coatings, off-road 1 South Coast AQMD’s CEQA Handbook and other resources for preparing air quality analyses can be found at: http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality-analysis-handbook. 2 CalEEMod is available free of charge at: www.caleemod.com. 3 South Coast AQMD’s CEQA regional pollutant emissions significance thresholds can be found at: http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air-quality-significance-thresholds.pdf. 4 South Coast AQMD’s guidance for performing a localized air quality analysis can be found at: http://www.aqmd.gov/home/regulations/ceqa/air -quality-analysis-handbook/localized-significance-thresholds. Nicole Sauviat Criste 2 March 9, 2021 mobile sources (e.g., heavy-duty construction equipment) and on-road mobile sources (e.g., construction worker vehicle trips, material transport trips, and ha uling trips). Operation-related air quality impacts may include, but are not limited to, emissions from stationary sources (e.g., boilers and air pollution control devices ), area sources (e.g., solvents and coatings), and vehicular trips (e.g., on- and off-road tailpipe emissions and entrained dust). Air quality impacts from indirect sources, such as sources that generate or attract vehicular trips, should be included in the analysis. Furthermore, emissions from the overlapping construction and operational activities should be combined and compared to South Coast AQMD’s regional air quality CEQA operational thresholds to determine the level of significance. If the Proposed Project generates diesel emissions from long-term construction or attracts diesel-fueled vehicular trips, especially heavy-duty diesel-fueled vehicles, it is recommended that the Lead Agency perform a mobile source health risk assessment 5. In the event that implementation of the Proposed Project requires a permit from South Coast AQMD, South Coast AQMD should be identified as a Responsible Agency for the Proposed Project in the EIR. The assumptions in the air quality analysis in the EIR will be the basis for evaluating the permit under CEQA and imposing permit conditions and limits. Questions on permits should be directed to South Coast AQMD’s Engineering and Permitting staff at (909) 396-3385. Mitigation Measures In the event that the Proposed Project results in significant adverse air quality impacts, CEQA requires that all feasible mitigation measures that go beyond what is required by law be utilized to minimize these impacts. Any impacts resulting from mitigation measures must also be analyzed. Several resources to assist the Lead Agency with identifying potential mitigation measures for the Proposed Project include South Coast AQMD’s CEQA Air Quality Handbook1, South Coast AQMD’s Mitigation Monitoring and Reporting Plan for the 2016 Air Quality Management Plan6, and Southern California Association of Government’s Mitigation Monitoring and Reporting Plan for the 20 20-2045 Regional Transportation Plan/Sustainable Communities Strategy7. South Coast AQMD staff is available to work with the Lead Agency to ensure that air qua lity, greenhouse gas, and health risk impacts from the Proposed Project are accurately evaluated and mitigated where feasible. If you have any questions regarding this letter, please contact me at lsun@aqmd.gov. Sincer ely, Lijin Sun Lijin Sun, J.D. Program Supervisor, CEQA IGR Planning, Rule Development & Area Sources LS RVC210218-02 Control Number 5 South Coast AQMD’s guidance for performing a mobile source health risk assessment can be found at: http://www.aqmd.gov/home/regulations/ceqa/air -quality-analysis-handbook/mobile-source-toxics-analysis. 6 South Coast AQMD’s 2016 Air Quality Management Plan can be found at: http://www.aqmd.gov/docs/default- source/Agendas/Governing-Board/2017/2017-mar3-035.pdf (starting on page 86). 7 Southern California Association of Governments’ 2020-2045 RTP/SCS can be found at: https://www.connectsocal.org/Documents/PEIR/certified/Exhibit -A_ConnectSoCal_PEIR.pdf.