2020-08-13 DESIGN REVIEW LETTER-TRAFFIC STUDY
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August 13, 2020
Mark Rogers
TRG Land
898 Production Pl
Newport Beach, CA 92663
mrogers@trgland.com
SUBJECT: 4th DESIGN REVIEW – TRAFFIC STUDY
TRAVERTINE SPECIFIC PLAN PROJECT—GENERAL PLAN AMENDMENT
2017-0002, ZONE CHANGE 2017-0002, SPECIFIC PLAN AMENDMENT
2017-0004, TENTATIVE TRACT MAP 2017-0008, ENVIRONMENTAL
ASSESSMENT 2017-0008
Dear Mr. Rogers:
On May 18, 2020, staff received the revised traffic study based on comments issued in
April 2020. Since then, staff have been engaged with you in several discussions regarding
both on- and off-site roadway cross-sections for the project. Please see comments below
on the revised study which consider these discussions. Comments are numbered to
correspond with Urban Crossroads’ response to comments that was provided with the
revised traffic study.
1. General Comments:
a. The comment regarding combining the single-phase TIA (April 2018) and
phased TIA (May 2020) documents still stands. The scope for the April 2018
TIA was approved; however, according to our records, the City’s Traffic
Engineer returned comments in July of 2018, to which we have no response.
Please provide the Traffic Engineer’s approval from 2018.
b. The table in Section 7 includes the requested summary of mitigation. Two
issues remain which are directly related to CEQA, which requires that
mitigation measures be feasible and implementable. This has been
successfully argued by project opponents in multiple cases. First, it is not
sufficient to determine that the CIP will be used to fund improvements. It
must also be clear that the CIP has funds available for these improvements.
That analysis needs to be included in the study, or the traffic impacts will
need to be declared significant and unavoidable. Similarly, a number of
“TBD” notations are included in the table, referencing the Indio General Plan.
The Indio General Plan was adopted, and the EIR certified, in the fall of last
year. Please include that information. The same issue must be addressed:
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does the City of Indio have the improvements included in their CIP and
funded? This applies to areas within County of Riverside jurisdiction as well.
2. Please change the title of Table 7-2 to “Summary of Phased Intersection Mitigation
Measures”.
3. Please discuss with the traffic consultant the status of roadway cross-sections. The
issue is that as written, the traffic study appears to say that the interim sections
will be permanent. Please revise the report as follows:
a. Describe what the ultimate sections will be; and
b. Describe that the analysis was done on the interim sections, which will have
less capacity than the final roadways, and since the analysis shows that the
interim section generates acceptable levels of service, the build out of the full
roadways will also generate acceptable levels of service.
4. BLM may not grant a permit by the current Phase 2 build year. Please modify the
analysis to show how the circulation system works without Jefferson in place by
Phase 2.
5. The traffic study should explain why the analysis is inconsistent with the NOP.
Alternatively, the CEQA consultant can add it to the EIR. Either option is acceptable,
but one option must be implemented.
6. The project will require a VMT analysis based on the City’s policy, adopted in June
2020. A copy of the policy is attached for your use in revising the VMT analysis.
7. See comment #5 above.
8. Changes noted.
9. See comment #3 above.
10.Changes noted.
11.See comment #5 above.
12.See comment #3 above.
13.Changes are noted but need augmentation. Inclusion in the General Plan is not
sufficient. See comment #1.b. above.
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14.See comment #1.b. above.
15.See comment #1.b. above.
16.See comment #1.b. above.
17.See comment #3 above.
18.See comment #1.b. above.
19.Thru 23. Changes are noted.
24.See comment #6 above.
25.Assuming that analysis under the City’s VMT policy results in similar conclusions,
the impacts associated with VMT will need to be declared significant and
unavoidable.
26.Changes noted.
27.See comment #25 above.
28.See comment #1.b. above.
If you have any questions, please contact me at (760) 777-7067.
Sincerely,
Cheri L. Flores
Planning Manager
Design and Development Department
cc. Lou Miramontes, Hofmann Land Development
Danny Castro, Design and Development Director
Bryan McKinney, Public Works Director/City Engineer