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2021-01-25 Wave Project VMT Analysis1 From:Nicole Criste <ncriste@terranovaplanning.com> Sent:Monday, January 25, 2021 4:06 PM To:John Kain; Marlie Whiteman; Garrett Simon Cc:Farhad Iranitalab; Steve Libring; Bryan McKinney; Cheri Flores Subject:Wave Project VMT Analysis Attachments:Wave VMT Analysis Revised 1.15.21.pdf; Response to comments (2021.01.23)[1].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. John and Marlie, Please find attached the City Traffic Engineer’s comments on your revised VMT analysis and associated response to comments.I think it would be most productive to have a meeting or call to discuss the remaining issues and come to a consensus on what needs to still be done.Please let me know your availability for either the end of this week or the beginning of next week,and we will put together a Zoom meeting. Thanks, Nicole Nicole Sauviat Criste Consulting Planner City of La Quinta TERRA NOVA PLANNING & RESEARCH, INC.® 42635 Melanie Place, Ste 101 PALM DESERT, CA. 92211 760) 341-4800 FAX#: 760-341-4455 E-Mail: ncriste@terranovaplanning.com 12615 10 VMT Eval.docx January 13,2021 Mr.Garret Simon CM Wave Development,LLC 2440 Junction Place,Suite 200 Boulder,CO 81301 SUBJECT:CORAL MOUNTAIN SPECIFIC PLAN VEHICLE MILES TRAVELED VMT)ANALYSIS Dear Mr.Garret Simon: The following vehicle miles traveled VMT)analysis has been prepared for the proposed Coral Mountain Specific Plan Project)in the City of La Quinta.For VMT analysis purposes,the Project consists of a master planned themed resort comprised of the following land uses LU): The Wave Basin a private facility).Institute of Transportation Engineers ITE)does not have trip rates for a wave pool facility.Therefore,similar use based on SANDAG's recreation park developed)peak hour and daily rates were utilized. ITE LU Code 330 A 150 key hotel with 1,900 square feet bar,1,400 square feet restaurant, 4,200 square feet kitchen,1,100 rooftop bar,1,200 pool bar grill,and 4,200 square feet spa) ITE LU Code 220 104 attached dwelling units ITE LU Code 210 496 detached dwelling units ITE LU Code 820 60,000 square feet of retail ITE LU Code 861 Wave village area with 900 square feet shape studio,1,600 square feet surf shop,3,000 square feet board room,1,800 square feet surf lounge/living room,800 square feet surf classroom,a fitness pavilion,1,400 square feet high performance center,and 5,500 square feet beach club) ITE LU Code 495 The farm area with 2,100 square feet barn,2,500 square feet greenhouse, 1,400 square feet equipment barn,300 square feet tool shed,1,200 square feet family camp, 4,500 square feet gym,2,000 square feet outfitters,and 2,000 square feet locker rooms) In addition,back of house complex consists of 9,500 square feet resort operations,1,500 square feet wave operations,and 1,000 square feet guardhouses.These back of house uses are accounted for in the Project trip rates. Project phasing and long range future traffic conditions with Project land use changes are evaluated in the Coral Mountain Specific Plan Traffic Impact Analysis October 27,2020). Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 2 12615 10 VMT Eval.docx BACKGROUND Changes to California Environmental Quality Act CEQA)Guidelines were adopted in December 2018, which require all lead agencies to adopt VMT as a replacement for automobile delay based level of service LOS)as the new measure for identifying transportation impacts for land use projects.This statewide mandate was implemented on July 1,2020.To aid in this transition,the Governor’s Office of Planning and Research OPR)released a Technical Advisory on Evaluating Transportation Impacts in CEQA December of 2018)Technical Advisory).1) Based on OPR’s Technical Advisory,the City of La Quinta has prepared their Vehicle Miles Traveled Analysis Policy City Guidelines).2)This analysis has been prepared based on the adopted City Guidelines. VMT ANALYSIS METHODOLOGY The Vehicle Miles Traveled Analysis Policy June 2020)La Quinta Guidelines)are consistent with the VMT analysis methodology recommended by OPR.As outlined in the La Quinta Guidelines,a Mixed Use project such as Coral Mountain,which includes both residential and non residential uses has each type of uses analyzed independently,applying the following significance thresholds for each land use component: For Residential Uses,VMT per resident exceeding a level of 1)15 percent below the Citywide per resident VMT OR 2)15 percent below regional VMT per resident,whichever is more stringent For Retail Uses Includes Hotels),a net increase in the total existing VMT for the region. PROJECT SCREENING The La Quinta Guidelines provide details on appropriate screening thresholds”that can be used to identify when a proposed land use project is anticipated to result in a less than significant impact without conducting a more detailed analysis.Screening thresholds are broken into three types: Transit Priority Area TPA)Screening Low VMT Area Screening Project Type Screening A land use project need only to meet one of the above screening thresholds to result in a less than significant impact. For the purposes of this analysis,the initial VMT screening process has been conducted using the Riverside County Transportation Analysis Model RIVTAM). 2 Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 3 12615 10 VMT Eval.docx TPA SCREENING Consistent with guidance identified in the Technical Advisory,projects located within a Transit Priority Area TPA)may be presumed to have a less than significant impact.A TPA is defined as within mile of: 1) an existing major transit stop”containing a rail transit station served by either bus services or rail transit service,or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods)or 2) an existing stop along a high quality transit corridor”a corridor with fixed route bus service with service intervals no longer than 15 minutes during peak commute hours) The Project site is not located within mile of an existing major transit stop,or along a high quality transit corridor. The TPA screening threshold is not met. LOW VMT AREA SCREENING The La Quinta Guidelines also states that,residential and office projects located within a low VMT generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary.In addition,other employment related and mixed use land use projects may qualify for the use of screening if the project can reasonably be expected to generate VMT per resident,per worker,or per service population that is similar to the existing land uses in the low VMT area.”The sub regional Riverside County Transportation Analysis Model RIVTAM)is used to measure VMT performance within individual traffic analysis zones TAZs).An estimate of the VMT in the Project’s physical location was calculated to determine the relevant TAZ’s VMT as compared to the jurisdictional average see Attachment A).The Project is located in TAZ 4742,and would not appear to be within a low VMT generating TAZ.Exhibit 1 shows the Project area RIVTAM traffic analysis zones. The Low VMT Area screening threshold is not met. PROJECT TYPE SCREENING The retail component of the Project is anticipated to serve the local area.The La Quinta Guidelines allow retail projects of less than 50,000 square feet to be screened out if the project is serving the local area. Because the retail component of the Project is more than 50,000 square feet,the retail portion of the Project is not screened out.The La Quinta Guidelines identify projects that are local serving by nature, or that generate fewer than 110 daily vehicle trips be presumed to have a less than significant impact on VMT.Based on the Project’s trip generation,the Project is not considered a local serving or small enough to not warrant assessment,therefore,the Project would not be eligible to screen out based on project type screening. 3 Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 4 12615 10 VMT Eval.docx The Project Type screening threshold is not met. Since none of the project level screening criteria were met,a project level VMT analysis has been prepared. PROJECT VMT ASSESSMENT The VMT projections are based upon an updated version of the Riverside County Transportation Analysis Model RivTAM)which became available in the CVAG region during 2016.RivTAM is consistent with the SCAG draft 2016 RTP for the CVAG Transportation Project Prioritization Study TPPS)2040 project. RIVTAM is a useful tool to estimate VMT as it considers interaction between different land uses based on socio economic data such as population,households,income,and employment.The La Quinta Guidelines identifies RIVTAM as the appropriate tool for conducting VMT analysis for land use projects in Riverside County. Project VMT has been calculated using the most current version of RIVTAM.Adjustments in socio economic data SED)i.e.,employment)have been made to a separate TAZ within the RIVTAM model to reflect the Project’s proposed population and employment uses.Separate TAZs are used to isolate the Project’s VMT. Table 1 summarizes the service population population and employment)estimates for the Project.It should be noted that the employment estimates have been developed from land use to employment generation factors from the Riverside County General Plan but modified for the specific Project characteristics and then confirmed with the Client.The wave basin and ancillary resort land uses are private,for use of residents and resort hotel guests.Although the Project employment is a mix of service and retail employment,the City of La Quinta guidelines are explicit indicating that the hotel land uses are categorized as retail uses for the purposes of VMT analysis. TABLE 1:POPULATION AND EMPLOYMENT ESTIMATES Land Use Estimated Service Population Residential 1,698 Residents Hotel Wave Basin 434 Employees Commercial Retail 240 Employees Hotel 300 Hotel Occupants Total:2,672 Service Population Adjustments to population and employment factors for the Project TAZ were made to the RIVTAM base year model 2012)and the cumulative year model 2040).Each model was then run with the updated SED factors included for the Project TAZ. 4 Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 5 12615 10 VMT Eval.docx PROJECT RESIDENTIAL VMT CALCULATION Consistent with recommendations contained in the La Quinta Guidelines,the residential calculation of VMT is based upon the home based project generated VMT per population.This calculation focuses on the occupants of dwelling units within the Project land uses,whereas hotel occupants,wave basin visitors and retail patrons are evaluated separately using the boundary method discussed below.Table 2 shows the home based VMT associated with the Project for both baseline and cumulative conditions. VMT estimates are provided for both the base year model 2012)and cumulative year model 2040),and linear interpolation was used to determine the Project’s home based baseline 2020)VMT. TABLE 2:BASELINE AND CUMULATIVE PROJECT RESIDENTIAL HOME BASED VMT Project 2012 Project 2040 Project 2020 interpolated) Residents 1,698 1,698 1,698 VMT 19,437 20,642 19,773 VMT Resident 11.45 12.14 11.64 For baseline 2020)conditions,the residential portion of the Project generates 19,773 Home Based VMT. There are an estimated 1,698 Project residents.The result is approximately 11.64 home based VMT Capita for the 2020 Baseline with Project conditions.In addition,the cumulative 2040)Project scenario results in approximately 12.14 VMT SP. For comparison purposes,Citywide home based VMT estimates have been also developed from the with Project”RIVTAM model run for baseline conditions.Once total home based VMT for the area is calculated,total area VMT is then normalized by dividing by the population as shown on Table 3. TABLE 3:BASE YEAR CITYWIDE HOME BASED VMT Category City of La Quinta VMT 544,993 Population 42,000 VMT Resident 12.98 The estimates of baseline residential home based Project VMT Capita are compared to the City of La Quinta VMT of 12.98 home based VMT Capita.The City of La Quinta guidelines indicate that residential VMT exceeding 15 percent below the Citywide VMT per resident 11.03 VMT capita)represents a Project impact.The Project home based VMT Capita of 11.64 is greater than the City VMT Capita threshold,and a potentially significant VMT impact is indicated. 5 Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 6 12615 10 VMT Eval.docx PROJECT EMPLOYMENT IMPACT ON VMT As noted above,the VMT analysis methodology for retail uses including hotels)focuses on the net increase in the total existing VMT for the region.The project consists of approximately 674 employees, including 240 employees associated with the 60,000 square feet of neighborhood shopping center retail uses and 434 employees associated with the hotel and wave basin uses. Travel activity associated with total link level VMT was extracted from the without Project”and with non residential Project”RIVTAM model run for 2012 and 2040 conditions,then interpolated for baseline 2020)conditions.This methodology is commonly referred to as boundary method”and includes the total VMT for all vehicle trips with one or both trip ends within a specific geographic area.The boundary method”VMT per service population for the CVAG subregion is utilized to normalize VMT into a standard unit for comparison purposes,focusing on the total population and employment in the Coachella Valley.Once total VMT for the area is calculated,total area VMT is then normalized by dividing by the respective service population i.e.,population and employment of the Coachella Valley)as shown on Table 4. TABLE 4:BASE YEAR SUB REGIONAL LINK LEVEL VMT Without Project Employment With Project Employment VMT Interacting with CVAG Area 15,173,739 15,166,580 CVAG Area Population 510,550 510,550 CVAG Area Employment 193,090 193,764 VMT Service Population 21.56 21.53 To determine whether or not there is a significant impact using the boundary method,CVAG area VMT with the project employment is compared to without project conditions.The CVAG subregion VMT SP without Project employment is estimated at 21.56,whereas with the Project employment,the CVAG subregion VMT is estimated at 21.53.The project’s effect on VMT for non residential uses)is not considered significant because it results in a cumulative link level boundary CVAG VMT per service population decrease under the plus project condition compared to the no project condition. PROJECT DESIGN FEATURES FOR VMT REDUCTION Transportation demand management TDM)strategies have been evaluated for the purpose of reducing VMT impacts determined to be potentially significant.Quantifying Greenhouse Gas Mitigation Measures CAPCOA,2010)provides information on individual measures for potential reduction in VMT Of the 50 transportation measures presented by CAPCOA,approximately 41 are applicable at a building and site level.The remaining 9 measures are functions of,or depend on,site location and/or actions by local and regional agencies or funders. 6 Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 7 12615 10 VMT Eval.docx On page 58 of the CAPCOA 2010 document,ten percent is referenced as the maximum reduction when combining multiple mitigation strategies for the suburban place type characterized by dispersed,low density,single use,automobile dependent land use patterns)and requires a project to contain a diverse land use mix,workforce housing,and project specific transit.The maximum percent reductions were derived from a limited comparison of aggregate citywide VMT performance rather than based on data comparing the actual performance of VMT reduction strategies in the place type. Even under the most favorable circumstances,projects located within a suburban context,such as the proposed Project evaluated here,can realize a maximum 10 percent reduction in VMT through implementation of feasible TDM measures.The Project incorporates design features and attributes promoting trip reduction.Because these features/attributes are integral to the Project,and/or are regulatory requirements,they are not considered to be mitigation measures.However,the RIVTAM does not incorporate modeling of these features,so they are considered after the VMT data is extracted from the traffic model. Project vehicle miles traveled VMT)are reduced by the following Project design features/attributes, which are anticipated to collectively reduce Project home based VMT by approximately 6%: Having different types of land uses near one another can decrease VMT since trips between land use types are shorter and may be accommodated by non auto modes of transport.For example,when residential areas are in the same neighborhood as commercial and resort land uses,a resident does not need to travel outside of the neighborhood to meet his/her recreational and retail needs.The Project’s mixed use environment could provide for a potential reduction in Project residential VMT of 3%. The project will include improved design elements to enhance walkability and connectivity. Improved street network characteristics within the Project include sidewalk coverage, building setbacks,street widths,pedestrian crossings,presence of street trees,and a host of other physical variables that differentiate pedestrian oriented environments from auto oriented environments.The Project would provide a pedestrian access network that internally links all uses and connects to all existing or planned external streets and pedestrian facilities contiguous with the project site.The Project would minimize barriers to pedestrian access and interconnectivity.The Project includes sidewalk connections,particularly to from the retail areas interacting with residential and resort uses on site.The Project’s implementation of this measure could provide for a potential reduction in Project residential VMT of 2%. The project will implement marketing strategies to optimize on site resort and residential uses.Information sharing and marketing are important components to successful trip reduction strategies.Marketing strategies may include: o Resident member benefits that include use of the resort amenities o Event promotions 7 Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 8 12615 10 VMT Eval.docx o Publications The Project’s implementation of this measure could provide for a potential reduction in Project residential VMT of 1%. In summary,travel demand modeling of VMT for the Project based upon City of La Quinta guidelines indicates a potential impact for residential uses while also indicating the Project’s non residential uses do not exceed VMT thresholds.Project design features taken into account after the modeling process) reduce residential VMT from 11.64 VMT resident to 10.94 VMT per resident,which is less than the City’s VMT residential threshold.The unique mixed use characteristics of the Project,combined with walkability and connectivity design elements,optimize on site interaction and result in a lower VMT than standalone uses. If you have any questions,please contact us at 949)375 2435 for John or 714)585 0574 for Marlie. Respectfully submitted, URBAN CROSSROADS,INC. John Kain,AICP Marlie Whiteman,PE Principal Senior Associate 8 Mr.Garret Simon CM Wave Development,LLC January 13,2021 Page 9 12615 10 VMT Eval.docx REFERENCES 1.Office of Planning and Research.Technical Advisory on Evaluating Transportation Impacts in CEQA. State of California s.n.,December 2018. 2.City of La Quinta.Vehicle Miles Traveled Aanlysis Policy.June 23,2020. 3.County of Riverside.Appendix E:Socioeconomic Build Out Assumptions and Methodology.County of Riverside s.n.,April 2017. 9 4713 4722 4738 4729 4725 4724 4741 4737 4754 47874771 4791 47904776 4753 4775 4774 4788 4773 4769 47514736 4755 4711 4642 4705 4756 4809 4786 4740 4806 4810 4803 4813 48124747 4721 4757 4772 47984783 4743 4764 4792 4801 4777 4692 4767 4781 4766 4731 4758 4709 48044708 4808 47854734 4780 4752 4784 4761 4704 4799 4746 4814 4765 4796 4797 4807 4702 4745 4759 4699 4816 4742 4739 Source: Esri, Maxar, GeoEye, Earthstar Geographics, CNES/Airbus DS, USDA, USGS, AeroGRID, IGN, and the GIS User Community EXHIBIT 1: PROJECT AREA RIVTAM TRAFFIC ANALYSIS ZONES Coral Mountain Specific Plan Vehicle Miles Traveled (VMT) Analysis N 12615 - 01 - TAZ.mxd LEGEND EXAMPLE OF RIVTAM LOW VMT TAZ RiVTAM TAZ ENCOMPASSING CORAL MOUNTAIN PROJECT SEPARATE TAZ ADDED FOR PROJECT REPRESENTATION IN RIVTAM 10 12615 10 VMT Eval.docx ATTACHMENT A LOW VMT AREA SCREENING CALCULATIONS Date:January 13,2021 Subject:Responses to January 5,2021 Coral Mountain Specific Plan VMT Analysis Comments 1st REVIEW CORRECTIONS,VMT ANAYSIS GENERAL PLAN AMENDMENT 2019 0002 ZONE CHANGE 2019 0004 SPECIFIC PLAN 2019 0003 AMENDMENT 5 TO SP 03 067)TENTATIVE TRACT MAP 2019 0005 TTM 37815)MASTER PROJECT 2019 0004 The following responses are provided for the comments/questions from Nicole Sauviat Criste City of La Quinta): General Comments 1. Traffic report project description and phasing should clearly describe the project construction for each phase.Describe the kind of service the following provides;are they traffic generators? A 16K The Farm Recreational Area/Clubhouse ITE Land Use 495) 2.1K Barn Traffic Generator?)1.2K Family Camp Traffic Generator?) 2.5K Greenhouse Traffic Generator?)4.5K Gym Traffic Generator?) 1.4K Equipment Barn Traffic Generator?)2K Outfitter Traffic Generator?) 0.3K Tool Shed Traffic Generator?)2K Locker Room Traffic Generator?) B 15K Wave Village commercial ancillary uses 0.9K Shape Studio 1.6K Surf Shop 3K Board Room 1.8K Surf Lounge/Living Room 0.8K Surf Classroom 1.4K High Performance Center 5.5K Beach Club The above uses are not included in the Trip Generation Table. UXR Response As noted in Section 4 page 39)of the October 27,2020 Coral Mountain Specific Plan Traffic Impact Analysis,the Project consists of the following land uses: The Wave Basin a private facility).Since ITE does not have trip rates for a wave pool facility, similar use based on SANDAG's recreation park developed)peak hour and daily rates are utilized. ITE LU Code 330 A 150 key hotel with 1,900 square feet bar,1,400 square feet restaurant, 4,200 square feet kitchen,1,100 rooftop bar,1,200 pool bar grill,and 4,200 square feet spa) ITE LU Code 220 104 attached dwelling units ITE LU Code 210 496 detached dwelling units ITE LU Code 820 60,000 square feet of retail ITE LU Code 861 Wave village area with 900 square feet shape studio,1,600 square feet surf shop,3,000 square feet board room,1,800 square feet surf lounge/living room,800 square feet surf classroom,a fitness pavilion,1,400 square feet high performance center,and 5,500 square feet beach club), January 13,2021 Page 2 12615 Response to comments 2021.01.13).docx ITE LU Code 495 The farm area with 2,100 square feet barn,2,500 square feet greenhouse, 1,400 square feet equipment barn,300 square feet tool shed,1,200 square feet family camp, 4,500 square feet gym,2,000 square feet outfitters,and 2,000 square feet locker rooms). Footnotes 6 and 9 of Tables 4 1,4 2,and 4 3 of the October 27,2020 Coral Mountain Specific Plan Traffic Impact Analysis,explain how these back of house uses are accounted for: o Footnote 6:Wave Basin Facility trip rates account for pool area and 1.5 tsf of back of house wave operations.” o Footnote 9:The 1 tsf back of house guardhouse use is accounted for in the Project rates.” 2. In general report lacks quantifiable information and sources,more clear references to the source of information is needed. UXR Response Tables 4 1,4 2,and 4 3 of the October 27,2020 Coral Mountain Specific Plan Traffic Impact Analysis, clearly present the categorization and sources of trip generation for each Project phase. 3. The report should include a map showing the City’s TAZs with corresponding RIVTAM numbering see City’s map below). UXR Response The Coral Mountain Specific Plan VMT Analysis has been revised to include a new Exhibit 1 which shows the City’s TAZs with corresponding RIVTAM numbering. 4. The report should provide a summary description of RIVTAM and its relationship with SCAG,CVAG,and WRCOG and its use. UXR Response The Coral Mountain Specific Plan VMT Analysis has been revised to include the following paragraph under PROJECT VMT ASSESSMENT heading: The VMT projections are based upon an updated version of the Riverside County Transportation Analysis Model RIVTAM)which became available in the CVAG region during 2016.RivTAM is consistent with the SCAG draft 2016 RTP for the CVAG Transportation Project Prioritization Study TPPS)2040 project. 5. Baseline methodology options included the regional SCAG model,the RIVTAM model,and 2010 2012 California Household Travel Survey CHTS).A key limitation of the two models is that they exclude the VMT associated with internal to external and external to internal trips.For the SCAG and RIVTAM models,the VMT methodology included internal to internal trips for each of the following variable: Total VMT all vehicles and all trip purposes) Home based VMT per capita automobile only) January 13,2021 Page 3 12615 Response to comments 2021.01.13).docx Home based work VMT per worker automobile only) The exception to this is the RIVTAM Total VMT Regional),which included internal to external and external to internal trips.The model limited all trip length calculations for these trips to facilities within the SCAG region;therefore,the lengths of these trips are not fully accounted for.The report should explain the limitation and how it was overcome. UXR Response The County of Riverside,and almost every City jurisdiction within the County of Riverside,require use of RIVTAM for VMT analysis. Specific Comments TPA Screening The report provides a general definition taken from the LA Quinta Guidelines and OPR.Report should expand and define the terms used in the guidelines i.e.explain what the major transit stop includes)see comments on the report.Major Transit Stop”is a transit transfer center that connect various transit services including Rail,buses and other mass transit.Define inconsistencies with the applicable Sustainable Communities Strategy as determined by the lead agency,with input from the MPO).What does sustainable community mean?This should be described since this report is stand alone and it should have enough information for the reader.see comments in the report.) UXR Response To support achievement of the State’s greenhouse gas GHG)emissions reduction goals,initially set out in California Assembly Bill 32,and followed by Senate Bill 32,California established the Sustainable Communities and Climate Protection Act.SB 375 Chapter 728,Stats.2008)focuses on incentivizing regional and local planning and building in ways that bring people and destinations closer together,with low carbon,alternative and convenient ways to get around.It requires regional metropolitan planning organizations in California to develop Sustainable Communities Strategies SCS),or long range plans,which align transportation,housing,and land use decisions toward achieving GHG emissions reduction targets set by the California Air Resources Board CARB). This technical report is not intended to be a standalone document which describes the background of VMT modeling.It is expressly intended to respond to the City’s VMT guidelines,without duplicating those guidelines.Enough information is provided in the report to efficiently and effectively present the inclusions of a VMT assessment consistent with City of La Quinta guidelines. Low VMT Area Screening The report uses the verbiage from OPR Technical Report and City of La Quinta to describe Low VMT.Report should tailor the description to the specific project at hand.The report should quantify the low VMT for the City and indicate if there is any low VMT TAZ in LA Quinta.Use the City TAZ Map to show the location of the project and a TAZ with low VMT.See RIVTAM example on the page to follow. Attachment B needs to be explained in more detail as to what the terms and values mean and measure.Provide pertinent information on the City’s TAZ map see comments in attachment B). January 13,2021 Page 4 12615 Response to comments 2021.01.13).docx UXR Response The Coral Mountain Specific Plan VMT Analysis has been revised to include a new Exhibit 1 which shows the City’s TAZs with corresponding RIVTAM numbering.Based upon this request,a sample low VMT TAZ away from the Project is also highlighted on Exhibit 1.Other questions regarding Attachment B addressed below. Project Type Screening See comments in the report. UXR Response See VMT Analysis Report Comments”responses below. Project VMT Assessment The report should include an explanation of the limitation in using RIVTAM.Since Riverside County is located at the edge of the SCAG model area,some modifications to the models may be necessary to provide a full accounting of VMT effects as recommended in the OPR Technical Advisory for SB 743 implementation.The specific modifications would be to adjust the lengths of trips entering and exiting the model boundary capture their full travel distance and not just the distance they travel inside the model area.See comments on the report. For the Baseline with Project Conditions the Production/Attraction PA)Method and Origin/Destination OD) Method are considered the most appropriate method for calculating project generated VMT”. For the Cumulative with Project Conditions,the Boundary Method is considered the most appropriate method for calculating project effect on VMT”. Project Residential VMT Calculation Are all the residential units occupied by the owners or there are rented during vacation times?Does the VMT calculation consider the patrons traveling from outside of the region?The report should explain if this would make a difference on VMT calculation or if it has no effect. For the boundary Method,was there any adjustment since Riverside County is located at the edge of the SCAG model area?Some modifications to the models may be necessary to provide a full accounting of VMT effects as recommended in the OPR Technical Advisory for SB 743 implementation.The specific modifications would be to adjust the lengths of trips entering and exiting the model boundary area to capture their full travel distance and not just the distance they travel inside the model area.See comments in the report. What category does the Event traffic fall into and how did the study deal with it? UXR Response As noted above in the UXR response to general comment 5 above the County of Riverside,and almost every City jurisdiction within the County of Riverside,require use of RIVTAM for VMT analysis. As a technical consultant with over 30 years of travel demand expertise,our role is not to examine the limitations in using RIVTAM.The version of RIVTAM utilized in Coachella Valley has been expressly calibrated for conditions in Coachella Valley.Residential occupancy assumptions are geared toward conservative peak season conditions. January 13,2021 Page 5 12615 Response to comments 2021.01.13).docx The October 27,2020 Coral Mountain Specific Plan Traffic Impact Analysis evaluates the potential occurrence of special events at this location involving attendance of not to exceed 2,500 guests per day arriving or departing on Saturdays up to 4 events per year).Weekend special event traffic conditions yield travel demands in study area which are consistent with the full buildout of the Project under weekday typical traffic operations. Project Employment Impact on VMT See comments in the report UXR Response See VMT Analysis Report Comments”responses below. Project Design Features for VMT Reduction The report should explain the 9 mitigation measures reported by CPCOA and provide references to the values used in the report as to the effectiveness of the measure that was used to reduce the VMT.Also see comments in the report. UXR Response See VMT Analysis Report Comments”responses below. VMT Analysis Report Comments 1. Page 1 Clarify and create a more understandable project description and functions.very confusing! See example as written in the Technical Memo. Land use 330)a 150 key hotel with 1,900 square feet bar,1,400 square feet restaurant,4,200 square feet kitchen,1,100 rooftop bar,1,200 pool bar grill,and 4,200 square feet spa)” Land use 220)104 attached dwelling units” Land use 210)496 detached dwelling units” Land use 820)60,000 square feet of retail” Land use 861)wave village area with 900 square feet shape studio,1,600 square feet surf shop,3,000 square feet board room,1,800 square feet surf lounge/living room,800 square feet surf classroom,a fitness pavilion,1,400 square feet high performance center,and 5,500 square feet beach club)” Land use 495)the farm area with 2,100 square feet barn,2,500 square feet greenhouse,1,400 square feet equipment barn,300 square feet tool shed,1,200 square feet family camp,4,500 square feet gym,2,000 square feet outfitters,and 2,000 square feet locker rooms” number of employee involved?In addition,back of house complex consists of 9,500 square feet resort operations,1,500 square feet wave operations,and 1,000 square feet guardhouses UXR Response See response to general comments 1 above. January 13,2021 Page 6 12615 Response to comments 2021.01.13).docx 2. Page 2,Project Screening Section Describe the RIVTAM model and its relation to SCAG and CVAG and WRCOG model. TPA Screening Tailor the definition to the project location!there are no ferry's in La Quinta). o TPA Screening text edits: Consistent with guidance identified in the Technical Advisory,projects located within a Transit Priority Area TPA)may be presumed to have a less than significant impact absent substantial evidence to the contrary.” A TPA is defined as within mile of:”A TPA is defined as within mile of A major Transportation Transfer Center 1) an existing major transit stop”a site containing an existing rail transit station,a ferry terminal served by either a bus services or rail transit service,or the intersection of two or more major bus routes with a frequency of service of 15 minutes or less during the morning and afternoon peak commute periods) UXR Response The Coral Mountain Specific Plan VMT Analysis has been revised to include these edits. 3. Page 3,first 2 bullets: Includes more parking for use by residents,customers,or employees of the project than required by the jurisdiction if the jurisdiction requires the project to supply parking)” More parking than the code require?Does La Quinta have the policy not to require parking?if not,delete Is inconsistent with the applicable Sustainable Communities Strategy as determined by the lead agency,with input from the Metropolitan Planning Organization)” What does this mean?Define UXR Response Proximity to a high quality transit corridor does not automatically grant a project the presumption of less than significant VMT impact.The bullet items being questioned by this comment are provided to illustrate the conditions where the TPA screening may be applied.Because the Project is not located within mile of an existing major transit stop,or along a high quality transit corridor,the bullet items have been removed from the revised Coral Mountain Specific Plan VMT Analysis. 4. Page 3,Low VMT Area Screening The La Quinta Guidelines also states that,residential and office projects located within a low VMT generating area may be presumed to have a less than significant impact absent substantial evidence to the contrary.” What constitute substantial evidence for this project? A low VMT Area is a Traffic Analysis Zone TAZ)with a VMT per capita or per employee or service population that is more than 15%below the City VMT quantify)per capita,employee,or service population.Please identify the City's Low VMT value vs.the project VMT per capita,employee, service population that determine the LOW TAZs.show project VMT on the city's TAZ map,do not January 13,2021 Page 7 12615 Response to comments 2021.01.13).docx quote the La Quinta verbiage,explain what does it mean.This is a new methodology and should be described clearly for non technical policy maker.See attached map Need to describe attachment B and show the result. Provide values calculated for comparison UXR Response The low VMT screening threshold is not met for this Project. The text description in the Coral Mountain Specific Plan VMT Analysis efficiently and effectively defines a low VMT area. 5. Page 3,Project Type Screening The retail component of the Project is anticipated to serve the local area.The La Quinta Guidelines allow retail projects of less than 50,000 square feet to be screened out if the project is serving the local area. Because the retail component of the Project is more than 50,000 square feet,the retail portion of the Project is not screened out.The La Quinta Guidelines identify projects that are local serving by nature,or that generate fewer than 110 daily vehicle trips be presumed to have a less than significant impact on VMT.Based on the Project’s trip generation see Attachment A),the Project is not considered a local serving or small enough to not warrant assessment,therefore,the Project would not be eligible to screen out based on project type screening.” What does this mean local serving by nature”?LIST Is less than 50,000 small enough,Define small enough? UXR Response Local serving”land uses provide a benefit to surrounding homes and businesses by shortening the trips for shopping,recreation,medical,and related activity.Retail projects greater than 50,000 sf are not candidates for being screened out of VMT assessment based upon City of La Quinta guidelines. 6. Page 4,Project VMT Assessment RIVTAM is a useful tool to estimate VMT as it considers interaction between different land uses based on socio economic data such as population,households income and employment.The La Quinta Guidelines identifies RIVTAM as the appropriate tool for conducting VMT analysis for land use projects in Riverside County.” Project VMT has been calculated using the most current version of RIVTAM.Adjustments in socioeconomic data SED)i.e.,employment)have been made to a separate TAZ within the RIVTAM model to reflect the Project’s proposed population and employment uses.Separate TAZs are used to isolate the Project’s VMT.” Include calculation as attachment with explanation of adjustments. Please expand explanation as to what does this mean by adjusting population and employment to a separate TAZ within RIVTAM?show the separate TAZ on City's TAZ map January 13,2021 Page 8 12615 Response to comments 2021.01.13).docx Table 1 summarizes the service population population and employment)estimates for the Project.It should be noted that the employment estimates have been developed from land use to employment generation factors from the Riverside County General Plan but modified for the specific Project characteristics and then confirmed with the Client.The wave basin and ancillary resort land uses are private,for use of residents and resort hotel guests.Although the Project employment is a mix of service and retail employment,the City of La Quinta guidelines are explicit indicating that the hotel land uses are categorized as retail uses for the purposes of VMT analysis.” Clarify?Explain. TABLE 1:POPULATION AND EMPLOYMENT ESTIMATES Land Use Estimated Service Population Residential 1,698 Residents Hotel Wave Basin 434 Employees Commercial Retail 240 Employees Hotel 2 people per room?)300 Hotel Occupants Total:2,672 Service Population 4742? Adjustments to population and employment factors for the Project TAZ were made to the RIVTAM base year model 2012)and the cumulative year model 2040).Each model was then run with the updated SED factors included for the Project TAZ.” Show on the TAZ map!Is project TAZ a subset of RIVTAM TAZ UXR Response The Coral Mountain Specific Plan VMT Analysis has been revised to include the above text edit. The Coral Mountain Specific Plan VMT Analysis has also been revised to include a new Exhibit 1 which also illustrates the separate TAZ created for the Project VMT analysis.As noted above,Table 1 of the Coral Mountain Specific Plan VMT Analysis summarizes the service population population employment)estimates for the Project.The separate project TAZ was added in order to isolate the Project’s VMT using RIVTAM. 7. Page 5,Project Residential VMT Calculation TABLE 2:BASELINE AND CUMULATIVE PROJECT RESIDENTIAL HOME BASED VMT Project 2012 TAZ 4742? Project 2040 TAZ 4742? Project 2020 interpolated) Residents 1,698 1,698 1,698 VMT 19,437 20,642 19,773 VMT Resident 11.45 12.14 11.64 For baseline 2020)conditions,the residential portion of the Project generates 19,773 Home Based VMT. There are an estimated 1,698 Project residents.The result is approximately 11.64 home based VMT Capita for the 2020 Baseline with Project conditions.In addition,the cumulative 2040)Project scenario results in approximately 12.14 VMT SP. January 13,2021 Page 9 12615 Response to comments 2021.01.13).docx Is the nature of residential rental units)make a difference in number of residents Calculation? Residents 1,698 Based on Travel Forecast Model? Per the model run for the TAZ? Or per Capita? UXR Response Table 2 of the Coral Mountain Specific Plan VMT Analysis shows the home based VMT associated with the new Project TAZ Project only,not the entirety of TAZ 4742)for both baseline and cumulative conditions.The nature of residential units)does not make a difference in the number of residents calculation. The Project population data was developed using 2.86 persons per dwelling unit for the detached housing and 2.68 persons per dwelling unit for attached housing.The combined average is 2.83 persons per dwelling unit. The 2.86 for detached dwelling units was from the California Emissions Estimator Model,Appendix D October 2017,page 6).The 2.68 came from the California Department of Finance:E 5 Population and Housing Estimates for Cities,Counties,and the State,2011 2019 with 2010 Census Benchmark by the State of California Department of Finance. For comparison:City’s estimate of household size is 2.79 in 2000 and 2.85 in 2007 Housing Element of LQ GP).Census data is 2.57 for La Quinta. 8. Page 5,Project Employment Impact on VMT As noted above,the VMT analysis methodology for retail uses including hotels)focuses on the net increase in the total existing VMT for the region.The project consists of approximately 674 employees, including 240 employees associated with the 60,000 square feet of neighborhood shopping center retail uses and 434 employees associated with the hotel and wave basin uses.” Retail component of the project:Phase I 10 K retail Phase 2 25 K Retail phase 3 25 K Retail. How about EVENT trips Travel activity associated with total link level VMT was extracted from the without Project”and with non residential Project”RIVTAM model run for 2012 and 2040 conditions,then interpolated for baseline 2020)conditions.This methodology is commonly referred to as boundary method”and includes the total VMT for all vehicle trips with one or both trip ends within a specific geographic area.The boundary method”VMT per service population for the CVAG subregion is utilized to normalize VMT into a standard unit for comparison purposes,focusing on the total population and employment in the Coachella Valley. Once total VMT for the area is calculated,total area VMT is then normalized by dividing by the respective service population i.e.,population and employment of the Coachella Valley)as shown on Table 4.” total link level VMT” o The Boundary Method is the sum of all weekday VMT on a roadway network within a designated boundary.Boundary Method VMT includes all trips,including those trips that do January 13,2021 Page 10 12615 Response to comments 2021.01.13).docx not begin or end in the designated boundary.This is the only VMT method that captures the project effect on VMT’,including how projects may influence VMT generation of nearby zones and cut through and/or displaced traffic.This is evaluated in the cumulative year for land use projects. This methodology is commonly referred to as boundary method”and includes the total VMT for all vehicle trips with one or both trip ends within a specific geographic area.” o Show on the map.Is this TAZ? UXR Response Peak season weekday travel activity generally exceeds the activity associated with weekend special events in the Project area.The October 27,2020 Coral Mountain Specific Plan Traffic Impact Analysis evaluates the potential occurrence of special events at this location involving attendance of not to exceed 2,500 guests per day arriving or departing on Saturdays up to 4 events per year).Weekend special event traffic conditions yield travel demands in study area which are consistent with the full buildout of the Project under weekday typical traffic operations. As noted in the Coral Mountain Specific Plan VMT Analysis,the boundary method”VMT per service population for the CVAG subregion is utilized to normalize VMT into a standard unit for comparison purposes,focusing on the total population and employment in the Coachella Valley.Once total VMT for the area is calculated,total area VMT is then normalized by dividing by the respective service population i.e.,population and employment of the Coachella Valley)as shown on Table 4. 9. Page 6,Project Employment VMT TABLE 4:BASE YEAR SUB REGIONAL LINK LEVEL VMT Without Project Employment With Project Employment VMT Interacting with CVAG Area 15,173,739 15,166,580 CVAG Area Population 510,550 510,550 CVAG Area Employment 193,090 193,764 VMT Service Population 21.56 21.53 VMT interacting with CVAG Area”Reference! 15,166,580 How did this number calculated?what is the explanation for reduced VMT? To determine whether or not there is a significant impact using the boundary method,CVAG area VMT with the project employment is compared to without project conditions.The CVAG subregion VMT SP without Project employment is estimated at 21.56,whereas with the Project employment,the CVAG subregion VMT is estimated at 21.53.The project’s effect on VMT for non residential uses)is not considered significant because it results in a cumulative link level boundary CVAG VMT per service population decrease under the plus project condition compared to the no project condition.” Explain why? January 13,2021 Page 11 12615 Response to comments 2021.01.13).docx UXR Response As noted in the Coral Mountain Specific Plan VMT Analysis,the project’s effect on VMT for non residential uses)is not considered significant because it results in a cumulative link level boundary CVAG VMT per service population decrease under the plus project condition compared to the no project condition. 10. Page 6,Project Design Features for VMT Reduction Transportation demand management TDM)strategies have been evaluated for the purpose of reducing VMT impacts determined to be potentially significant.Quantifying Greenhouse Gas Mitigation Measures,CAPCOA)2010 provides information on individual understand potential reduction in VMT.Of the 50 transportation measures presented by CAPCOA,approximately 41 are applicable at a building and site level.The remaining 9 measures are functions of,or depend on,site location and/or actions by local and regional agencies or funders.” CAPCOA)2010 provides information on individual understand potential reduction in VMT” o What does this mean? 41 are applicable at a building and site level” o Explain does this have anything to do with VMT reduction or overall GHG The remaining 9 measures are functions of,or depend on,site location and/or actions” o List the measures in a table form and explain site location and/or.... CAPCOA indicates that a ten percent is the maximum reduction when combining multiple mitigation strategies for the suburban place type characterized by dispersed,low density,single use,automobile dependent land use patterns)and requires a project to contain a diverse land use mix,workforce housing, and project specific transit.The maximum percent reductions were derived from a limited comparison of aggregate citywide VMT performance rather than based on data comparing the actual performance of VMT reduction strategies in the place type.” CAPCOA indicates that a ten percent”Include reference Section and Page What City what data compared with? Even under the most favorable circumstances,projects located within a suburban context,such as the proposed Project evaluated here,can realize a maximum 10 percent reduction in VMT through implementation of feasible TDM measures.The Project incorporates design features and attributes promoting trip reduction.Because these features/attributes are integral to the Project,and/or are regulatory requirements,they are not considered to be mitigation measures.However,the RIVTAM does not incorporate modeling of these features,so they are considered after the VMT data is extracted from the traffic model.” What are favorable circumstances? can realize a maximum 10 percent reduction in VMT through implementation of feasible TDM measures”Like what?List January 13,2021 Page 12 12615 Response to comments 2021.01.13).docx can realize a maximum 10 percent reduction in VMT through implementation of feasible TDM measures…”Like what?List Expand discussion and explain. UXR Response In the revised Coral Mountain Specific Plan VMT Analysis,the second sentence under PROJECT DESIGN FEATURES FOR VMT REDUCTION”has been corrected as follows: Quantifying Greenhouse Gas Mitigation Measures CAPCOA,2010)provides information on individual measures for potential reduction in VMT.” In the revised Coral Mountain Specific Plan VMT Analysis,the first sentence of the second paragraph under PROJECT DESIGN FEATURES FOR VMT REDUCTION”has been adjusted to include the page number as requested: On page 58 of the CAPCOA 2010 document,ten percent is referenced as the maximum reduction when combining multiple mitigation strategies for the suburban place type characterized by dispersed,low density,single use,automobile dependent land use patterns)and requires a project to contain a diverse land use mix,workforce housing,and project specific transit.” As noted in the Coral Mountain Specific Plan VMT Analysis,41 of the CAPCOA VMT reduction measures relate to building and site level design,and are therefore potentially applicable to any given land development project.The remaining 9 measures are not relevant to this VMT analysis, and therefore a list is not provided. Favorable circumstances”for minimization of per capita VMT focus on high connectivity for pedestrians and bicyclists,high transit service levels,and a balanced mix of resident,jobs,and services in close proximity to one another.Within a suburban context,the ability to mitigate VMT is typically limited because densities are lower than urban settings and travel patterns tend to be focused on the automobile.Therefore,it is not realistic to assume more than a 10 percent reduction in VMT using project level travel demand management measures. 11. Page 7,Project Design Features for VMT Reduction Above the report mention the design features are not considered as mitigation measures!! This project does not present a permanent population.It is a resort with residential units some for permanent living and some for rental travel pattern are different than typical mix use projects! 1st bullet:Having different types of land uses near one another can decrease VMT since trips between land use types are shorter and may be accommodated by non auto modes of transport” o This included in which of the 9 measures? 2nd bullet:The project will include improved design elements to enhance walkability and connectivity.Improved street network characteristics within the Project include sidewalk coverage, building setbacks,street widths,pedestrian crossings,presence of street trees,and a host of other January 13,2021 Page 13 12615 Response to comments 2021.01.13).docx physical variables that differentiate pedestrian oriented environments from auto oriented environments…” o This included in which of the 9 measures? o Would this have been done regardless of VMT? 3rd bullet:The project will implement marketing strategies to optimize on site resort and residential uses…” o This included in which of the 9 measures? In summary,travel demand modeling of VMT for the Project based upon City of La Quinta guidelines indicates a potential impact for residential uses while also indicating the Project’s non residential uses do not exceed VMT thresholds.Project design features taken into account after the modeling process reduce residential VMT from 11.64 VMT resident to 10.94 VMT per resident,which is less than the City’s VMT residential threshold.The unique mixed use characteristics of the Project, combined with walkability and connectivity design elements,optimize on site interaction and result in a lower VMT than standalone uses.” o How about the EVENT traffic? o what process? o “VMT from 11.64 VMT resident to 10.94 VMT per resident”How? UXR Response The Project design features/attributes are all applicable at a building and site level. Weekday travel activity generally exceeds the activity associated with weekend special events in the Project area.The October 27,2020 Coral Mountain Specific Plan Traffic Impact Analysis evaluates the potential occurrence of special events at this location involving attendance of not to exceed 2,500 guests per day arriving or departing on Saturdays up to 4 events per year).Weekend special event traffic conditions yield travel demands in study area which are consistent with the full buildout of the Project under weekday typical traffic operations. Project design features taken into account after the modeling process)reduce residential VMT from 11.64 VMT resident to 10.94 VMT per resident,based upon Project design features/attributes which are anticipated to collectively reduce Project home based VMT by approximately 6%. 12. Attachment A,Table 4 3 Project Trip Generation Land use 861 and Land use 495,NO TRIP Generation? is the retail adjacent to a crosstown Arterial Madison Ave.)or collector?Why consider any pass by trip reduction? Remove Internal to retail/resort credit.Should not take any credit.This reduction is for the retail. January 13,2021 Page 14 12615 Response to comments 2021.01.13).docx Remove all Pass by internal to residential/resort credits.For VMT purposes,there are no trip credit UXR Response Attachment A has been eliminated in the revised Coral Mountain Specific Plan VMT Analysis.Table 4 3 of the October 27,2020 Coral Mountain Specific Plan Traffic Impact Analysis is not utilized in the Project VMT assessment. 13. Attachment B Low VMT Area Screening Calculations See text edits in the tables. Include the City TAZ Map.See attached map and show the Project TAZ with other neighboring TAZ How was total trip length calculated?RIVTAM Run Model? Vehicle Flow PA Method HB 3.How did you arrive at this number and what does it represent? Need description. PA Method VMT HB 72.How did you arrive at this number and what does it represent?Need description. Summary table OD VMT/SP PA HB VMT/Pop UXR Response Attachment B is now referenced as Attachment A in the revised Coral Mountain Specific Plan VMT Analysis.The Attachment A data sets are entirely based upon RIVTAM.The purpose of this attachment is to present the 2012 VMT per service population for RIVTAM TAZ 4742 which is much higher than the City of La Quinta average VMT per service population.This supports the finding that TAZ 4742 is not currently a low VMT generating TAZ. Suggested text edits have been added to the Tables in Attachment A.