2021-01-05 MP2019-0004 TTM VMT & 3rd Review CommentsJanuary 5, 2021
Mr. Garrett Simon
CM Wave Development LLC
2440 Junction Place, Suite 200
Boulder, CO 80301
SUBJECT: 3rd REVIEW CORRECTIONS, TTM & GRADING PLAN
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
Dear Mr. Simon,
On November 25th, 2020, you submitted a revised Tentative Tract Map and Grading Plan for
staff review. That review has been completed. Public Works is satisfied that their comments
have been addressed. The following comments are from the Fire Department and Planning
Division:
1. All 2nd Review Fire Department items addressed. 3rd review revealed the 24-feet
Emergency Access Easement between Lots 1 and 11 to have been partially removed from
the details on both the TTM and Preliminary Grading. This needs to be appropriately
corrected.
2. The Specific Plan document asserts that an 8 foot wide pedestrian path is provided on the
main driveway. However, Sections A1 and A2 on the TTM show a 5 foot pedestrian path.
Please correct both sections to be consistent with the Specific Plan.
On November 18th and December 14th, you submitted the required VMT analysis. The City’s
Traffic Engineer has completed his review of that document, and has the following comments:
General Comments
The VMT analysis has been extensively annotated and is attached. The comments should be
addressed in addition to the following.
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?)
2.5K Greenhouse (Traffic Generator?)
1.4K Equipment Barn (Traffic Generator?)
0.3K Tool Shed (Traffic Generator?)
1.2K Family Camp (Traffic Generator?)
4.5K Gym (Traffic Generator?)
2K Outfitter (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.
2. In general report lacks quantifiable information and sources, more clear references to the
source of information is needed.
3. The report should include a map showing the City’s TAZs with corresponding RIVTAM
numbering (see City’s map below).
4. The report should provide a summary description of RIVTAM and its relationship with SCAG,
CVAG, and WRCOG and its use.
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)
• 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.
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.)
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).
Project Type Screening- See comments in the report.
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?
Project Employment Impact on VMT – See comments in the report
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.
Please make modifications to the TTM, the Grading Plan and the VMT analysis and resubmit them
for review.
Due to current State mandates, I am working remotely. If you have any questions regarding the
process, please contact me at ncriste@terranovaplanning.com, and/or at (760) 341-4800.
Sincerely,
Nicole Sauviat Criste
Consulting Planner
12615‐10 VMT Eval
November 2, 2020
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 a wave basin, 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), 104 attached dwelling units, 496 detached dwelling units, 60,000 square feet of
retail, 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), 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. The wave
basin is a private facility.
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).
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.
Mr. Garret Simon
CM Wave Development, LLC
November 2, 2020
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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).
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 absent substantial evidence to the
contrary. A TPA is defined as within ½ mile of:
1) an existing “major transit stop” (a site containing an existing rail transit station, a ferry terminal
served by either a bus 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)
However, the presumption may not be appropriate if a project:
Has a Floor Area Ratio (FAR) of less than 0.75;
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CM Wave Development, LLC
November 2, 2020
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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);
Is inconsistent with the applicable Sustainable Communities Strategy (as determined by the lead agency,
with input from the Metropolitan Planning Organization); or
Replaces affordable residential units with a smaller number of moderate‐ or high‐income residential units.
The Project site is not located within ½ 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 B). The Project is located in TAZ 4742, and would not appear to be within a low VMT
generating TAZ.
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. 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.
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.
Mr. Garret Simon
CM Wave Development, LLC
November 2, 2020
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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 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.
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.
Mr. Garret Simon
CM Wave Development, LLC
November 2, 2020
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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.
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
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CM Wave Development, LLC
November 2, 2020
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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 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 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.
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.
Mr. Garret Simon
CM Wave Development, LLC
November 2, 2020
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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
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.
Mr. Garret Simon
CM Wave Development, LLC
November 2, 2020
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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
Mr. Garret Simon
CM Wave Development, LLC
November 2, 2020
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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.
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Attachment A
Project Trip Generation
12615‐10 VMT Eval