Loading...
2021-04-02 DESIGN REVIEW LETTER-TECH STUDIES - RESPONSES 04-14-21 1 April 2, 2021 April 14, 2021 (responses by Applicant) Mark Rogers TRG Land 898 Production Pl Newport Beach, CA 92663 mrogers@trgland.com SUBJECT: 5th DESIGN REVIEW – EA TECHNICAL STUDIES 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: During November through January 2020, we received submittals of technical studies including an Air Quality Impact Analysis, Greenhouse Gas Analysis, Noise Impact Analysis, Addendum to the Supplemental Cultural Resources Technical Report, Supplement to the Addendum to the Supplemental Cultural Resources Technical Report, Supplemental Paleontological Resources Assessment, Hydrology Study, Master Drainage Plan, Traffic Impact Analysis and Vehicle Miles Traveled (VMT) Study. Please note, the Biological Technical Report and Jurisdictional Delineation have not been resubmitted to date. These reports have been reviewed by City staff and peer reviewer and comments are noted in each document, available to download from the eTrakit portal. Some comments are also summarized below. One comment that seems to ripple through all the studies relates to consistency with project descriptions. It will help immensely if you and your team can finalize the project description, review the Specific Plan and Tract Map and assure that all consultants have this information to incorporate into their reports. We have spent a good amount of time reviewing submittals only to find that there have been new changes since the last review. Please coordinate with your team to get this information finalized and consistent throughout all documents. Documents uploaded to EA2017-0008 case: 2 • 6TH REVIEW COMMENTS – AQ 1-6-2021 • 6TH REVIEW COMMENTS – GHG 1-6-2021 • 6TH REVIEW COMMENTS – NOISE 12-28-2020 • 3RD REVIEW COMMENTS - CR ADDEN 11-17-20 (Addendum to the Supplemental Cultural Resources Technical Report) • 3RD REVIEW COMMENTS - CR ADDEN SUPP 12-28-2020 (Supplement to the Addendum to the Supplemental Cultural Resources Technical Report) • 1ST REVIEW COMMENTS – PALEO 11-2020 • 5TH REVIEW COMMENTS – TIA 11-5-2020 • 1ST REVIEW COMMENTS – VMT 11-3-2020 Comment summary: Preliminary Hydrology Study 1. Provide Engineer stamp and signature. No stamp or sign on this doc. Response: Final Report to be stamped and signed. 2. Per Engineering Bulletin 06-16 (attached), the design storm shall be the 100-year storm event that produces the most volume from the 1, 3, 6, or 24hr storms. It looks like hydrology was run for the 10-minute and 60-minute period. Cannot tell which of these or the others represents the highest volume storm. Response: The Rational Method hydrology was prepared using the Riverside County methodology which uses the 10- and 60-minute rainfall intensities to calculate the peak Rational Method flow rates. The time of concentration from the Rational Method was then used to develop the Unit Hydrographs (UH) which are used to determine the runoff volumes. The UHs were prepared for the 3- and 6-hour events as these events typically control for the smaller watershed areas. The larger of the two runoff volumes was identified in the Hydrology Report (Tables 5-4 and 5-5) and used for the design. The hydrology will be expanded to the 1- and 24-hour events to confirm that these events do not control the design. The text will also be updated to clarify the analyses performed. 3. On hydrology exhibit, show 100yr WSEL, basin bottom and top elevations. Basins deeper than 6ft are not permitted in un-gated communities. Max. water depth shall not exceed 19ft deep. See engineering bulletin for requirement on maintenance access ramp and benches around the basin. The referenced exhibit (last page of report) shows drainage basins 30 feet and more in depth. Response: Exhibit will be updated. 3 4. Please show that basins are capable of percolating the entire 100-year storm in less than 48 hours. See engineering bulletin for allowable percolation rate. The intro cites the dike impound where runoff will be retained and percolated into the ground. The syn hydrograph cites a perc (infiltration) rate of 0.269 inches per hour. This is used for all basins. See PDF doc p. 136. Response: New testing is being performed and will be added to the report. 5. Drywell shall be installed in the bottom of basins for nuisance water. No mention is made of drywells in the doc. Response: Drywells shall be included on the plans. 6. Provide emergency overflow route for the basins. It does not look like these have been provided. Response: Emergency overflows from the basin are proposed to be provided and will drain directly to the areas behind Dike No. 4. The location of the overflows will be added to the plans. 7. Provide CVWD preliminary approval for assumption that CVWD will allow discharge of the project's flow to the area behind Dike #4 (page 3). Doc still states that it “assumes” CVWD is OK with discharging overflow into Dike 4 impound. Response: The project team is working with CVWD to obtain a concurrence letter from CVVWD that the volume of the existing condition runoff can be directly discharged to the existing impound areas behind Dike No. 4. 4 Master Drainage Plan 11.10.20 1. Off-site drainage management is a significant challenge for this project. Previous plans required substantial land modification on the west end and elsewhere to accommodate diversion levees and channels. The SP doc shows no plans and the Master Drainage Plan also provides just schematics. The hydrologist sketches are vague design concepts that might work but authors admit they have no way of knowing how management will work without further analysis. Response: The project team understands that the regional drainage is a significant challenge, which is why the Drainage Master Plan was prepared and processed through CVWD for their review and comments. The study provides a comprehensive evaluation of the flood hazards on the site and details an overall plan for regional flood hazard protection and mitigation for project impacts. While final design of the drainage master plan facilities was not prepared, sufficient hydrology and hydraulic modeling was prepared to document that the system can provide the required level of flood protection and to provide estimated flow depths and velocities suitable for use in the development of the Specific Plan and TTM. 2. The hydro report appropriately says that design of the regional (off-site) facilities is to be submitted with the subdivision map; the TTM has been submitted but the technical analysis to support the design has not. With what we know about this difficult site constraint and past attempts to tame the drainages to the west especially, the viability of the SP, much less the TTM, needs to be demonstrated and has not yet. Same with the Guadalupe channel and crossings. We don’t have anything that shows how that crossing and others will be put into effect or what the consequences will be. Response: The Drainage Master Plan provides a detailed analysis of the flood hazards on the project site including an evaluation of the performance of the recommended conceptual flood hazard protection systems. The study includes a detailed evaluation of the peak flow rates and sediment yield tributary to the site (Chapter 4) along with 2-dimensional hydraulic analyses of the existing condition and proposed improvements (Chapter 5). The analysis included an assessment of potential flow path uncertainty on the active alluvial fans and the associated impacts to the project site. The analysis looked at both the Guadalupe Dike and Dike No. 4 and included the impacts associated with the proposed roadway crossings of these facilities. The roadway crossing sections are discussed in Section 5.2.4. While all of the TTM technical analysis has not been completed, the applicant has completed much 5 of the technical work that was used as a basis to design the TTM in addition to the Drainage Master Plan. The results of the technical analyses provide information on the flow depths and velocities along the flood protection systems and the roadway crossings which were used to support the development of the SP and the TTM 3. Section 1.1: Project-related impacts not addressed for key drainage components, including dikes, diversion levees, modified channels and access bridges. Response: The project related impacts to the drainage patterns and conditions along both the Guadalupe Dike and Dike No. 4 are identified and discussed in the report. The figures in Section 5 identify the changes to the flow depths (Fig 5-12) and velocities (Fig 5-19) across the existing drainage courses and floodplains as a result of the proposed improvements. Impacts to the Guadalupe Dike and Dike No. 4 are shown on Figures 5-26 through 5-32 and include the effects of the proposed roadway crossings. 4. Exhibits 5 Series: These exhibits show that high velocity flows would impounding on the west (up to 9-15 fps) and to a lesser extent on the south. With the project, depths along the west boundary are up to 15 feet. Velocities are not shown for the postproject condition. Flows must be shunted north but this is much along the contour without much slope. There is no analysis of ponding or impounding that could occur along the west boundary but if velocities are as great as projected, a berm/levee on the west could be overtopped in a large storm. Response: The composite flow velocities for the post-project condition are shown on Figure 5-18 and identify velocities in the 15 fps range along the west and southern boundaries. A comparison of the change in velocities is shown in Figure 5-19. The 2-dimensional hydraulic models using in the analysis evaluate the ponding on the west bank and show the depths and velocities as runoff is directed north to the Guadalupe Dike. These 2-dimensional hydraulic models are then used to determine the potential run up along the west bank, which along with the freeboard requirements are used to determine the required top of bank elevations. 6 GHG Report 1.6.21 1. Section ES.4: The Project is a Specific Plan. The SP must explicitly identify how water conservation will be affected and what kind of reductions can be made. With adjusted water demand calculated, the energy demand can also be. Consultant should loop back with SP author. This cannot be deferred to “subsequent development proposals”. The SP is the development proposal. o Still unclear if this is requiring a reduction beyond CalGreen, or that CalGreen standards will result in a 20% reduction? Please clarify. If the former, need to cite where that is a requirement (SP?) o Contrary to footnote # 1, there is no meaningful discussion of water conservation beyond use of desert plants in landscaping. Unquantified acres of turf will be developed with golf course. Need another source or documentation in revised SP; current SP draft does not really address this. Response: Additional clarification will be provided in the Specific Plan (SP) on how water conservation/reductions can be made. Additional coordination with the SP author will be done as requested. a. Clarification on the 20% reduction as it relates to CalGreen will be provided and a citation to the SP will be made if applicable. b. Will coordinate with SP preparer on acres of turf – or this statement will be removed if additional information is not available. 2. Section 3.5 Operational Emissions: The emission levels calculated in the new Table 3-3 are more than double the earlier calculation. Doesn’t need to be in doc but can you explain how we got such a large new number? Response: Section 3.5 in the GHG report is not a summary of the Operational Emissions. Section 3.5 refers to Project Construction GHG emissions as does Table 3-3. That said, neither the construction emissions or operational emissions doubled from the earlier calculations. 3. Text has been added regarding recommendations for avoidance, minimization and mitigation and regulatory plan consistency as Sections 3.10 & 3.11. Please see the track changes in word document. Response: Noted, this text will be incorporated into the revised GHG study. 7 Noise Impact Analysis We have a variety of concerns about the completeness of the noise impact analysis and its scope as well. While the analysis of potential construction noise impacts to residences within the project have been added, the intra-project traffic noise has not been analyzed; including the extension and use of Madison Street and its effects within the project. Some of our comments on the report are summarized below, while others are best reviewed in the context of the report. 1. Intra-Project Traffic & Stationary Source Analysis: While intra-project traffic volumes are projected to be relatively low, there will be instances where homes are located in proximity to the main roadways with the highest volumes. This area of potential intraproject post-development traffic noise needs to be analyzed. There should also be at least some discussion of project stationary sources, including HVAC, restaurant air exchanges and other sources for which guidance should be provided. Response: The comment is requesting on-site analysis of traffic noise impacts to the residential land uses adjacent to internal roadways. We can provide additional analysis and/or qualitative discussion demonstrating that the on-site traffic noise levels will be less than significant. In addition, this comment is requesting discussion of the potential operational noise levels associated with HVAC, etc. 2. Project Description Sec 1.2: As recommended for the Urban Crossroads noise and AQ analysis, it is recommended that the AQ project description be used to expand that in the noise report (see note and language in doc). Related to this, the SP land use plan has been or is being revised. Engineer should confer with applicant and get updated land use assignments. Exhibit 1-B of the noise report is now out of date. Response: The Project description will be updated for consistency with the Project Traffic Study. 3. Significance Thresholds and Levels of Analysis: According to OPR (not CEQA) guidelines, two levels of analysis are needed for the subject type of action (General Plan Amendment or Specific Plan Amendment); 1) changes in the ambient noise environment today. These impacts should be significant. 2) The second parameter is to compare the “approved” specific plan impacts against those of the new (revised) SP; this should yield a net reduction in noise compared to the approved SP. Response: The comment is suggesting that if the ambient noise levels already exceed the standards, then any increase would constitute a significant impact since 8 any increase would be in excess of the standards. However, the City does not maintain any significant noise level increase standards, only land use/noise compatibility levels outlined in the General Plan Noise Element. The new CEQA criteria is focused on the significance of the increase in ambient noise levels over existing conditions and brings in the concept of a “noise-level increase standard”. It does not imply an increase is significant if it is excess of a fixed noise level limit or on the increase over a fixed standard such as the land use compatibility guidelines or an ordinance limit. Unfortunately, most jurisdictions have noise level limits and land use guidelines for new development but not standards for what is a substantial temporary or permanent increase in ambient noise levels. We have identified the closest documentation of a “noise-level increase standard” available for transportation sources. The comment also suggests that we perform a plan to plan comparison. However, the plan to plan comparison is not provided in the Project TIA, so we would be introducing a new analysis scenario. 4. Project Buildout & Road Improvements: The discussion is confusing with regard to the if and when of the Jefferson Street extension. While the Madison Street extension and project access is called temporary, the report indicates that it could be as late as 204 that the Jefferson extension gets built. Yet, the noise report does not describe or analyze the traffic and noise effects on Madison Street within the project proper. This analysis needs to be added. Response: The comment is requesting additional on-site traffic analysis associated with the Madison Street and Jefferson extension. 5. Alternative Projects Analysis: While the report references and “analyses” two development options (GPA # 1 and GPA # 2) there is no description of these alternatives. The “Project with or Without Madison” is not a project alternative. The noise engineer must coordinate with the applicant and establish credible, feasible and responsive project alternatives that will be analyzed in all the technical reports and the Draft EIR. Response: The Noise Impact analysis considered all of the Project scenarios outlined in the Project TIA. 9 Cultural Resources Reports Integrated Report: What are the original report and referenced supplemental report? As noted in the reviewed docs and in the addenda, a “front-end” needs to be drafted that summarizes all of the reporting, makes appropriate references to earlier docs and includes those docs as appendices. Response: Multiple technical cultural resources reports have been prepared for the project to reflect the evolving project description and footprint over time. It is standard practice to cumulatively assess changes to a project area rather than restate findings for the entire project area in each study unless the previous efforts were conducted a significant time in the past (typically over 10 years). The original study for this project was in 2006; SWCA therefore conducted an updated assessment of the project area in 2017. Since 2017, the project footprint has changed and SWCA conducted another assessment focused on those changes in 2019-2020. That assessment is the focus of the current technical document under review by the City. SWCA can prepare an executive summary that summarizes the three reporting efforts and include each report as an attachment. SWCA does not recommend combining all of the efforts into a single document; in fact, it is not possible to do so because the 2006 study has already been submitted to the CHRIS system as a stand-alone study, and the 2017 study included a significantly different footprint than currently proposed and includes resources on BLM land that are no longer part of the project, but that still need to be on record with the BLM. Please note that the 2006 and 2017 reports are hundreds of pages long and hundreds of megabytes in size and the final package will be very large. Supplement to the Addendum to the Supplemental Cultural Resources Technical Report (12.28.20) 1. This report addresses only the “off-site” lands that may host wells and an electric sub-station required of the Project. This is a supplement to the addendum to the supplement... This and the preceding CR documents need to be consolidated into a single document with a summary front-end that also effectively directs the reader to the appropriate appendix (previous studies, supplements and addenda). It is unreasonable to expect the City, local Tribes and the state and federal agencies to try and piece this together. Response: SWCA prepared this assessment separately from the Addendum to the Supplemental Cultural Resources Technical Report because the APE for the off-site features has not yet been defined. SWCA will confer with TRG regarding the APE and integrating the assessment of cultural resource impacts for the off-site features into the main technical addendum. As noted in the responses to the Addendum above, SWCA can prepare an executive summary that summarizes the three reporting efforts and include each report as an attachment; however, SWCA will 10 not combine all efforts into a single assessment because of the age and independent nature of the 2006 and 2017 studies. 2. Page 1, Paragraph 3: APE Description: SP calls for a trail meandering through the area removed from the APE. The trail and its potential effects need to be documents and mitigated in this or related reports and included in the above referenced “Summary Report”. The APE should also include the segment of Ave 62 extending east from the project to and along south boundary lines of Section 35 & 36. This will be consistent with the Paleo APE as well. Response: SWCA will confer with TRG regarding the latest project design and features and update as needed. 3. Geoarchaeological Assessment: Cites period of early agriculture. Agriculture in the Valley did not begin in earnest until the beginning of the 20th century and not until the All-American Branch Canal was built near the middle of the century did lands like this go into cultivate. Please correct. Response: SWCA will update this description. 4. Recommendations: The potential for significant impacts is acknowledged but the recommendations do not constitute mitigation? The wells and sub-station are part of the Project. As such, their respective impacts need to be addressed in greater detail and a set of mitigation measures developed that can demonstrably ensure that potential impacts will be managed so they are less than significant. Response: SWCA recommended further study to determine actual impacts and proposed mitigation once the specific locations for the wells and substation have been identified. SWCA did not provide specific resource protection measures at this time because the APE and design for those project features is still under development. SWCA will confer with TRG regarding these project features and will update the assessment accordingly, if possible, based on the current project design status. Addendum to the Supplemental Cultural Resources Technical Report (11.17.20). 1. Integrated Reports: What are the original report and referenced supplemental report? As noted below and in the addenda, a “front-end” need to be drafted that summarizes all of the reporting, makes appropriate references to earlier docs and includes those docs as appendices. 11 Response: See response under “Cultural Resources Reports” 2. Introduction: Is a copy of the referenced 2006 report available? Can it be integrated into the requested CR summary and made an appendix? Please see Track Changes document for other, more minor comments and corrections. Response: See response under “Cultural Resources Reports” 3. “Open Desert Trail” & Revised APE: The revised APE removes most of the S1/2 of Section 4 but the SP proposes an “Open Desert Trail” (SP p.2-4). As noted elsewhere, recent work for the USBR and BLM required trails to be included in our APE. Here too, the SP trail needs to be a part of the APE. Response: SWCA will confer with TRG regarding the latest project design and features and incorporate this as needed. 4. Figure 2: Please add back the federal and tribal ownerships included in an earlier version of this report. Responses: SWCA will add labels as requested to the Figure. 5. Area of Potential Effect (p.5): Only a limited portion of the APE, as currently mapped, is located within areas that are or have been in cultivation, being limited to the vineyard above the CVWD recharge ponds. The balance is essentially undisturbed lands. Please correct. Response: SWCA will update this description. 6. Area of Potential Effect (p.5): The delineated APE may be too small, and grading, excavation, bridge and channel construction could result in work outside this APE. Please consider enlarging to ensure all areas of potential disturbance are covered. Response: SWCA will confer with TRG regarding the latest project design and features and update as needed. 7. Vertical APE (p.5): Based on preliminary assessment of project TTM, drainage plan, major and presumably deep excavations will occur especially along the west edge of the project and within the western portion thereof. Excavations here and elsewhere are shown to be up to 30 feet or more for diversion levees, stormwater detention 12 basons and other improvements. This vertical APE depth needs to be changed. Please confer with the project engineers. Response: SWCA will confer with TRG regarding the latest project design and features and update as needed. Also, to the extent the deeper vertical APE may affect future survey protocol and mitigation, please make the appropriate changes in this regard. Traffic Impact Analysis The following are comments on the November 5, 2020 PDF version of the subject traffic study, which has been used also as a reference document for at least the Urban Crossroads noise study. To the extent the project description as set forth in the noise study has or is changing, the traffic analysis should confer with the applicant and secure a final project description, land use map and TTM. The following summarizes the comments made in the draft 11.5.20 PDF, which should be carefully reviewed by the noise analyst before further revising this report. 1. Sec 1.2 & Exhibit 1-1 Project Description: The SP land use plan has been or is being revised. Engineer should confer with applicant and get updated land use assignments. Exhibit 1-B of the noise report is now out of date. Response: Exhibit 1‐1 has been updated as requested. 2. Executive Summary: Project Access & Phased Road Improvements: The discussion states that the project access is provided by the future Jefferson and Ave 62 extensions. In the interim, it appears that the Madison St extension over the levee, which is not describe at all in the project description, will be at least an EVA route. It also appears that the Madison St extension is part of a project alternative that would have it provide primary access for the project. Response: ‐ 2nd paragraph text under Section 1.2 has been modified as follows: “The Travertine Project is proposed to be served by two access points: 1) t he southerly extension of South Jefferson as a Modified Secondary, south of Avenue 58, and 2) the westerly extension of Avenue 62 as a Modified Secondary, west of Monroe Street. It should be noted that during the initial phase of the Project, a 13 n EVA ( emergency vehicle access) will be provided via Madison Street, south of Avenue 60 to the northerly edge of Project’s Planning Area 18.” 3. Please clarify the if and when of the Jefferson Street extension must be built before Madison becomes a necessity. While the Madison Street extension and project access is called temporary, other technical reports indicate that it could be as late as 2040 before the Jefferson extension gets built. The TIA analysis cites 4,800± ADT on the north end of Jefferson and 6,300 ADT just east of the Dike 4 levee. However, 2040 buildout W/O Madison yields volumes of 8,900± ADT north of the project loop and 8,900 south (east) of the loop. This possible future Madison Street prime access analysis needs to be added. Response: Madison Street it is not required to serve the Project as a full street connection and will only be utilized as an emergency access for Phase 1 conditions. ‐ As mentioned in the report, Jefferson Street extension is anticipated to be built by Phase 2 (conditions) to serve the Project. An optional Phase 2 scenario (Option 2) was also evaluated in response to City of La Quinta’s previous request to modify the analysis without the future Jefferson Street connection from Project boundary to Avenue 58 since BLM may not grant a permit by the current Phase 2 (2029) build year. 4. Project Alternatives: GPA Options 1 & 2 o GPA Option 1: (the termination of Madison Street as a General Plan Roadway south of Avenue 60) o GPA Option 2 (the deletion of Jefferson Street as General Plan roadway south of the hypothetical westerly extension of Avenue 60, and the deletion of Avenue 62 west of the hypothetical southerly extension of Madison Street, in addition to the termination of Madison Street as a General Plan Roadway south of Avenue 60) o GPA Alternatives: Deletion of Segments as General Plan Roadway System (Classification?) These need to be broken out and perhaps bulleted. GPAs, their specifics, and effects need to be clarified throughout this report. Response: ‐ The following text has been added in Section 1.5.6. • General Plan Buildout (Year 2040) With Madison Street Extension (Existing General 14 Plan). This scenario includes the following: 1. Future Madison Street extension, south of Avenue 60 to Avenue 62. 2. Future Jefferson Street connection from Avenue 58 to Avenue 62.  General Plan Buildout (Year 2040) Without Madison Street Extension (GPA Option 1). This scenario includes the following: 1. Termination of Madison Street as a General Plan roadway, south of Avenue 60. 2. Future Jefferson Street connection from Avenue 58 to Avenue 62. 3. Emergency vehicle access (EVA) is provided via Madison Street, from the northerly boundary of the Project’s Planning Area 18 to Avenue 60.  General Plan Buildout (Year 2040) Without Madison Street Extension and With Project Entry Gates (GPA Option 2). This scenario includes the following: 1. Termination of Madison Street as a General Plan roadway, south of the Avenue 60. 2. Future Jefferson Street connection from Avenue 58 to Project boundary. 3. The deletion of Jefferson Street as General Plan roadway south of the hypothetical westerly extension of Avenue 60, and the deletion of Avenue 62 west of the hypothetical southerly extension of Madison Street. 4. On‐site entry gates on Jefferson Street. Jefferson Street is a private roadway within the Project boundary. 5. Emergency vehicle access (EVA) is provided via Madison Street, from the northerly boundary of the Project’s Planning Area 18 to Avenue 60. 5. Table 1-4: Shouldn’t Madison @ 60th be added? There could be a lot of traffic headed that way as long as Madison is an option. Response: ‐ As shown on the Project Trip Distribution Exhibits (4‐1, 5‐1, and 6‐1), the Project is not anticipated to route additional traffic to this intersection since Madison Street, south of Avenue 60 is utilized as an emergency access only. 15 ‐ The intersection of Madison/Avenue 60 is only evaluated as an alternative under 2040 conditions. 6. Also, why does the Existing Plus Project LOS improve (delay goes down) compared to existing? Same question applies to Monroe @ 50th. Response: ‐ Traffic signal LOS calculations are influenced by traffic flows to/from adjacent intersections, and sometimes the average delay slightly decreases in spite of slight volume increases. 7. Exhibit 1-4 On-Site Roadway Cross-Sections: Given the primacy of Madison Street extension and its routing on the development site proper, this exhibit needs a full cross section of this street. Response: ‐ Madison Street is not required to serve the Project as a full street connection. Madison Street, between the Project boundary and Avenue 60 is utilized as an EVA and will be built as a 26 ft. wide roadway (no curb improvements). 8. Section 1.5.3: Does this refer to 2026 "existing" conditions? Or are we still looking at Phase I added to ~2020 background traffic? Why is the analysis of "Existing + Project" even analyzed? Response: ‐ As discussed in Section 4, Phase 1 (2026) includes Existing (2019) volumes, an ambient Growth traffic for 7 years, cumulative development traffic, and Project traffic. ‐ As mentioned in Section 3, the E+P analysis scenario was utilized to determine potentially significant Project impacts associated solely with the development of the proposed Project and the corresponding mitigation measures necessary to mitigate these impacts. Project buildout (phase 3) land use, trip distribution, and trip assignment are discussed in detail in Section 6 of this report. 16 9. Section 1.5.4: References Phase 2 Option 2. As noted above, these GPA options need to be fully spelled out. Also, the distribution of traffic seems to show substantial flows to the east on Ave 62. Rather, one would expect that the greater flows would be north on Madison. Can you explain why the substantial flow due east; where are these trips going that isn’t better reached via Madison? If vetted in the scoping letter, so be it. But it is unclear what will be built to the east that would have project traffic gravitate in that direction. Response: ‐ Only 10% of traffic is oriented to/from Avenue 62, with the remaining 85% of traffic oriented to the north of Madison ‐ The Project may potentially utilize Harrison Street (east of the study area) to head north as an alternative to Monroe and Jackson Street or to connect to Highway 111 and SR‐86. 10. Section 1.5.5: Again, is “existing” 2031 traffic volumes or something else? Response: ‐ As discussed in Section 6, Phase 3 (2031) includes Existing (2019) volumes, an ambient Growth traffic for 12 years, cumulative development traffic, and Project traffic. ‐ Existing conditions is based on previous 2017 traffic counts (utilized in the 2018 TIA) that are adjusted to represent 2019 baseline conditions. 11. Section 1.5.7: This discussion ignores the fact that Madison extended is to serve at least the early phases of development (as late as 2040) and by any reasonable estimation, will be well-used. Given the difficulty and cost associated with Jefferson St extended, isn’t likely that the City would have to allow the Madison St access indefinitely or permanently? Response: ‐ Text has been modified as follows: “The recommended site access improvements and on‐site circulation for the Project are described below and illustrated on Exhibit 8‐1. The Travertine Project is proposed to be served by two main access points to the surrounding area: 1) the southerly extension of South Jefferson as a Modified Secondary, south of Avenue 58, and 2) the westerly extension of Avenue 62 as a Modified Secondary, west of Monroe Street. Off‐site, Jefferson Street is recommended to be constructed from the Project boundary to Avenue 58 as an interim section with 1 lane northbound, 1 lane southbound, bike lanes, and a sidewalk adjacent to the west 17 side of the street. Avenue 62 should be constructed from the Project boundary to Monroe Street as a similar interim street cross‐section with a sidewalk on the north side. For emergency access purposes, an EVA alignment is provided via Madison Street, south of Avenue 60 to the northerly edge of the Project’s Planning Area 18.” 12.If sidewalks and bike lanes are planned for Ave 62 and Jefferson St., what is planned for Madison St? Response: ‐ Madison Street is not required to serve the Project as a full street connection. Madison Street, between the Project boundary and Avenue 60 is utilized as an EVA and will be built as a 26 ft. wide roadway (no curb improvements). 13. Exhibit 4-9: This is the first diagram showing the Madison St and Jefferson St EVA routes. In lieu of all-weather access, Jefferson St is probably not a viable EVA, at least in the near-term. The same stands for Madison, which must cross the Dike 4 levee and impound area. Both require a lot of bridging. Response: ‐ Exhibit 4‐9 has been updated to reflect the updated Madison Street EVA alignment. 14. Exhibit 5-11: Phase 2 Access: EVA and one of the primary access points is Jefferson St extended. That is a very expensive access just for Phase 2. What is the alternative if the Jefferson St extension is not economically or otherwise feasible? Response: ‐ Jefferson Street extension is anticipated to be built by Phase 2 (conditions) to serve the Project. An optional Phase 2 scenario (Option 2 – Without Jefferson Street Connection to Avenue 58) was also evaluated in response to City of La Quinta’s previous request to modify the analysis without the future Jefferson Street connection from Project boundary to Avenue 58 since BLM may not grant a permit by the current Phase 2 (2029) build year. ‐ An EVA alignment is also provided via Madison Street, south of Avenue 60 to the northerly edge of the Project’s Planning Area 18. 18 15. Section 7.0 Year 2040 Buildout: The bases for these scenarios should be explained. The description is vague (are roadways to be removed from the GP master circulation plan? Are just portions? Do gates delineate the private vs. public portions of Jefferson? Please clarify each “alternative” described in this section. This analysis seems especially important if the Jefferson alignment cannot be realized for financial, regulatory or other reason. Response: ‐ Text has been updated to include the following text in each scenario: 7.1 General Plan Buildout (Year 2040) With Madison Street Extension (Existing General Plan). This scenario includes the following alignment: 1. Future Madison Street extension, south of Avenue 60 to Avenue 62. 2. Future Jefferson Street connection from Avenue 58 to Avenue 62. 7.2 General Plan Buildout (Year 2040) Without Madison Street Extension (GPA Option 1). This scenario includes the following alignment: 1. Termination of Madison Street as a General Plan roadway, south of Avenue 60. 2. Future Jefferson Street connection from Avenue 58 to Avenue 62. 3. Emergency vehicle access (EVA) is provided via Madison Street, from the northerly boundary of the Project’s Planning Area 18 to Avenue 60. 7.3 General Plan Buildout (Year 2040) Without Madison Street Extension and With Project Entry Gates (GPA Option 2). This scenario includes the following alignment: 1. Termination of Madison Street as a General Plan roadway, south of the Avenue 60. 2. Future Jefferson Street connection from Avenue 58 to Project boundary. 3. The deletion of Jefferson Street as General Plan roadway south of the hypothetical westerly extension of Avenue 60, and the deletion of Avenue 62 west of the hypothetical southerly extension of Madison Street. 4. On‐site entry gates on Jefferson Street. Jefferson Street is a private roadway within the Project boundary. 5. Emergency vehicle access (EVA) is provided via Madison Street, from the northerly boundary of the Project’s Planning Area 18 to Avenue 60. 19 16. Section 7.3: 2040 GP w/O Madison Ext. & W/Gates: This appears to assume that the segment between the two gates is a private road? Is it also private beyond the gates? Responses: ‐ For GPA Option 2, Jefferson Street within the Project boundary (between the two gates) is a private roadway. 17. Section 7.4 Evac & Access During Floods: This discussion needs to focus on the proposed all-weather facilities, their role in the interim and long-term plan, and when they must be constructed. Response: ‐ With each project phase, all weather facilities (such as Avenue 62) are provided. 18. Project requires two bridges, the one over the Guadalupe drainage being hundreds of feet long. Is this bridging feasible? The TIA states: “The bridge configuration and sizing shall be determined during the final design. The design shall address freeboard and scour calculations as well as impacts to the dikes.” While not necessarily a task for the TIA, much hangs on the feasibility of this road and bridge connection. Since it is programmed to be constructed during Phase 2 buildout, shouldn’t be designed to a level sufficient to evaluate with the US BLM and Army Corps, as well as CVWD et al? Response: ‐ Noted. 19. Also note that the discussion of on-site and adjacent drainage facilities is still being analyzed by the City and CVWD. As noted, these planned management strategies are in an early stage and design specifics may have a significant impact on levee and conveyance design, and on bridge access into the site. Urban Crossroads should further confer with the applicant and secure updated data and info, as well as drainage and bridge design, to the extent relevant to this discussion. What is currently presented is a set of guidelines, not an all-weather access design package, which is what is needed. Response: ‐ With each project phase, all weather facilities (such as Avenue 62) are provided. 20 20.Section 9.1: As with the other reports, the project description, especially phasing is confusing. There is only 12 holes of golf planned, not 12 holes in Phase 1 and another 12 in Phase 2. Please see recommended changes made in Urban Crossroads AQ/GHG report. Response: ‐ Text has been updated as follows to match AQ/GHG report: “At buildout, the proposed mixed‐use Project consists of approximately 758 single family detached residential homes, 442 duplex residential units, a 100room resort hotel and a golf course (12 holes). The Project is anticipated to be constructed in phases with the total development for each phase summarized below:, anticipated to be constructed in phases: • Phase 1 (2026) – 530 single family detached residential homes, 74 duplex residential units, and a golf course (12 holes). Phase 1 of the proposed Project is anticipated to generate a total of 5,836 external trip‐ends per day on a typical weekday with 442 external vehicles per hour (VPH) during the weekday AM peak hour and 590 external VPH during the weekday PM peak hour. • Phase 2 (2029) – additional 143 single family detached residential homes and 163 duplex residential units for a total of 673 single family detached residential homes, 237 duplex residential units, and a golf course (12 holes). Phase 2 of the proposed Project is anticipated to generate a cumulative total of 8,343 external trip‐ends per day on a typical weekday with 620 external vehicles per hour (VPH) during the weekday AM peak hour and 821 external VPH during the weekday PM peak hour. • Phase 3 (2031) – additional 85 single family detached residential homes, 205 duplex residential units and a 100‐room resort hotel. The proposed Project is anticipated to generate a cumulative total of approximately 11,979 trip‐ends per day on a typical weekday with 848 vehicles per hour (VPH) during the weekday AM peak hour and 1,105 VPH during the weekday PM peak hour.” 21.Section 9.2 Project Access: The report states: “Project Phase 1 includes the westerly extension of Avenue 62 as an interim section, west of Monroe Street, with an emergency only access northerly from the Project via one of two potential alignments (to either Avenue 58 or Avenue 60). Project Phases 2 and 3 include the southerly extension of South Jefferson as an interim section, south of Avenue 58.” There is no mention of a Madison St extension even as an EVA, although it could be serving the 21 project for many years. Add a detailed description and discussion of Madison St, including long-term consequences in the event the Jefferson St extension is never built. Response ‐ As an EVA, the Madison Street extension does not serve as a public access for typical daily travel activity. The Jefferson Street extension will be required to be built in order for Phase 2 development to occur. 22.Section 9.2: For Phase 1 conditions, the TIA prescribed the following: “Construct a secondary emergency vehicle access (EVA) connection from the Phase 1 northerly boundary to either Madison Street / Avenue 60 or the existing western terminus of Avenue 58.” We have seen two different Madison EVA connectors, one that hugs the project boundary and another that cuts cross-country across the site and CVWD recharge pongs. Neither of these are shown on the project TTM. To the extent the Madison access, either for prime or EVA, will be very important to this project, it needs to be better described in the TIA and the Specific Plan. Response: ‐ Text has been updated to as follows: “Construct a secondary emergency vehicle access (EVA) connection from the Phase 1 northerly boundary of Planning Area 18 to either Madison Street / Avenue 60 or the existing western terminus of Avenue 58.” 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