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2020-06-11 Coral Mtn Specific Plan 2nd Round Air Quality & GHG CommentsCORAL MOUNTAIN SPECIFIC PLAN REVIEW Air Quality Impact Analysis/Greenhouse Gas Analysis – 2nd Round Comments Urban Crossroads RESPONSE TO COMMENT 1 Comment noted. The analysis has been revised to reflect the 21,920 cubic yards of import. It is our understanding that the import quantity will be hauled from an on-site location. As a conservative measure, this analysis assumes a hauling trip length of 1 mile (the length of the Project site).” City Comment: Response noted and is acceptable. Urban Crossroads RESPONSE TO COMMENT 2 The AQIA analyzes localized construction and operational emissions impacts at the nearest sensitive receptors. It should be noted that no Phasing Plan or detailed information has been provided detailing which Planning Areas will be constructed during each phase of construction. As such, consistent with the Coral Mountain Specific Plan Noise Impact Analysis prepared by Urban Crossroads, Inc., the nearest sensitive receptor used to evaluate construction and operational air quality impacts for emissions of PM10, PM2.5, NO2, and CO is represented is an existing residential home located 37 feet/11 meters from the Project site. It should be noted that the LST Methodology explicitly states that “It is possible that a project may have receptors closer than 25 meters. Projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters (1).” As such, the 25-meter distance will be used to conservatively evaluate construction and operational air quality impacts air quality impacts for emissions of PM10, PM2.5, NO2, and CO.” City Comment: Response noted and agreed. Urban Crossroads RESPONSE TO COMMENT 3 Comment noted. The analysis has been revised to reflect the VMT/trip of 7.91 miles as identified in the Coral Mountain Traffic Impact Analysis report (TIA).” City Comment: The 7.91 VMT/Trip cited in the Project TIA is based on the service population (employees associated with the hotel, wave pool, retail uses etc.) and residents of the residential component (pg. 130, TIA). However, the VMT analysis fails to capture trips associated with the majority of other high- and low- desert cities and out of town patrons of the hotel and wave pool, which arguably would be traveling distances farther than 7.91 miles. (As shown in the screenshot below, 7.91 miles barely reaches Palm Desert) A recently approved project similar in nature (DSRT SURF, 2019) assumed 25 miles per trip to account for out of town traffic associated with these types of land uses (hotel, resort residential and wave pool). The TIA and the AQ/GHG Analysis fail to make a good faith effort in capturing VMTs associated with other desert cities and out of town patrons of the venue (wave pool, hotel, etc.). Urban Crossroads RESPONSE TO COMMENT 4 This is a typo. The SP threshold used in the GHGA analysis is based on the Project’s 2026 buildout year. City Comment: Response noted. RESPONSE TO COMMENT 5 Comment noted. The analysis has been revised to reflect the energy demands for the wave pool use provided by the Project Applicant. City Comment: It is unclear where the wave pool-specific energy demands were accounted for in the CalEEMod outputs and, in fact, there is only one sentence in GHG Analysis that mentions such energy demands in passing without any numerical data. Electricity use for the surf pool was based on information provided by the Project Applicant.” (pg 53). The only changes made to the CalEEMod default energy components are regarding lighting and Title24 measures, and do not appear to account for the increase energy demand for the wave pool machinery/equipment. Please provide the specific energy data provided by the Project Applicant and point out where it was applied in the CalEEMod model. RESPONSE TO COMMENT 6 Project water use is based on information provided in the Water Supply Assessment and Water Supply Verification for the Proposed Coral Mountain Specific Plan by MSA Consulting, Inc. City Comment: Response noted. RESPONSE TO COMMENT 7 The trip purposes in CalEEMod has been adjusted to account for the internal reductions consistent with the TIA. This method is appropriate and ensures that emissions are not understated. City Comment: Response noted. RESPONSE TO COMMENT 8 Comment noted. The analysis has been revised to included air quality and GHG impacts associated with mobile-related emissions from special events. City Comment: Response and analysis noted. However, the VMT analysis for special events uses the same assumption of 7.91 miles per trip, which does not account for VMTs associated with the majority of high- and low- desert cities and out of town patrons of the venue (wave pool, hotel, etc.). New Comments: 1. All default vehicle emission factors have been changed in CalEEMod “per EMFAC 2017” resulting in approximately 45 pages of new values under “1.3 User Entered Comments & Non-Default Data” in the CalEEMod outputs. How were these values uploaded? 2. Phase 3 Operations (Buildout) assumes 9,489 average daily weekday trips. The TIA cites 6,994 daily trips at buildout. This would essentially overstate mobile emissions (however, we still believe the trip length of 7.91 miles is too low, thus understating emissions in that regard).