Club at Coral Mountain Resort Final EIR SCH# 2021020310 (Feb. 2022)CORAL MOUNTAIN RESORT
FINAL EIR
SCH# 2021020310
Applicant:
THE WAVE DEVELOPMENT, LLC
2440 Junction Place, Suite 200
Boulder, CO 80301
Lead Agency:
CITY OF LA QUINTA
78495 Calle Tampico
La Quinta, CA 92253
Preparer:
MSA CONSULTING INC.
34200 Bob Hope Drive
Rancho Mirage, California 92270
February 2022
L' J
FINAL ENVIRONMENTAL IMPACT REPORT
Coral Mountain Resort, La Quinta CA
DEIR/FEIR Preparers
EIR Preparers
The Draft and Final Environmental Impact Report (EIR) was prepared by the City of La Quinta (City)
with the assistance of MSA Consulting, Incorporated. Report preparers and consultants are identified
as follows, along with agencies, and individuals that provided information used to prepare the Draft
and Final EIR.
Lead Agency
The City of La Quinta
Planning Division
78495 Calle Tampico
La Quinta, CA 92253
Phone: 760-777-7000
Nicole Sauviat Criste, Consulting Planner
City of La Quinta
78495 Calle Tampico
La Quinta, CA 92253
Phone: 760-341-4455
Email: consultingplanner@laquintaca.gov
EIR Preparers
MSA Consulting, Inc.
34200 Bob Hope Drive
Rancho Mirage, CA 92270
Phone: 760-320-9822
Michelle Witherspoon, Director of Environmental Services
Jesus Herrera -Cortez, Senior Environmental Planner, GIS Analyst
Nicole Vann, Planner
Asia Lee, Environmental Planner
Derek Gallerani, Planning CAD Technician
Michael Rowe, Principal Engineer
LSA Associates, Inc.
901 E. Tahquitz Canyon Way, Suite B200
Palm Springs, CA 92262
Phone: 760-416-2075
Coral Mountain Resort Final EIR i-1 February 2022
EIR PREPARERS
Jodi Ross -Borrego, Principal Biologist
Jill Carpenter, Senior Biologist/Bat Specialist
CRM Tech
1016 East Cooley Drive, Suite A/B
Colton, CA 92324
Phone: 909-824-6400
Bai "Tom" Tang, Principal Investigator/Historian
Michael Hogan, Principal Investigator
Deirdre Encarnacion, Archaeologist/Report Writer
Daniel Bal!ester, Archaeologist/Paleontological Surveyor/Field Director
Nina Gallardo, Archaeologist/Native American Liaison
Harry M. Quinn, Geologist/Paleontologist
Ben Kerridge, Paleontological Surveyor/Report Writer
Salvadore Z. Boites, Paleontological Surveyor
Hunter O'Donnell, Paleontological Surveyor
Michael D. Richards, MA, Registered Professional Archaeologist
Sabrina Fajardo, Paleontological Surveyor
Sladden Engineering
45090 Golf Center Parkway, Suite F
Indio, CA 92201
Phone: 760-863-0713
Matthew J. Cohrt, Project Geologist
Brett L. Anderson, Principal Engineer
Urban Crossroads, Inc.
1197 Los Angeles Avenue, Suite C-256
Simi Valley, CA 93065
Phone: 805-426-4477
Haseeb Qureshi, Associate Principal (AQ and GHG Report)
Alyssa Tamase (AQ Report)
John Kain, AICP Principal (Traffic Impact Analysis)
Marlie Whiteman, Principal Engineer (Traffic Impact Analysis)
Janette Cachola (Traffic Impact Analysis)
Bill Lawson, Principal Engineer, INCE (Noise Study)
Coral Mountain Resort Final EIR i-2 February 2022
EIR PREPARERS
Musco Lighting
100 1St Avenue West
P.O. Box 808
Oskaloosa, IA 52577
Phone: 641-673-0411
Additional Agencies and Organizations Consulted
Along with a list of EIR prepares, a list of public agencies, organizations and persons consulted for the
EIR is included below, compliant with CEQA Guidelines Section 15129. The following list includes
agencies that were informally or formally contacted, as well as agencies that responded to the Notice
of Preparation (NOP) or commented on the DEIR (listed in alphabetical order).
- Agua Caliente Band of Cahuilla Indians
- Air Resources Board
- Augustine Band of Cahuilla Indians
- Cabazon Band of Mission Indians
- Cahuilla Band of Indians
- CAL FIRE
- California Department of Fish and Wildlife
- CalTrans District #8
- Coachella Valley Mountain Conservancy
- Colorado River Board
- Fish and Game Region #6
- Imperial Irrigation District
- Los Coyotes Band of Cahuilla and Cupeno Indians
- Morongo Band of Mission Indians
- Native American Heritage Commission (NAHC)
- Public Utilities Commission
- Regional WQCB #7
- Ramona Band of Cahuilla
- Riverside County Airport Land Use Commission (ALUC)
- Riverside County Flood Control and Water Conservation District
- Samuel A. McLeod, Ph.D. (Vertebrate Paleontology)
- Santa Rosa Band of Cahuilla Indians
- Soboba Band of Luiseno Indians
- South Coast Air Quality Management District (SCAQMD)
- Torres -Martinez Desert Cahuilla Indians
- Twenty -Nine Palms Band of Mission Indians
Coral Mountain Resort Final EIR i-3 February 2022
EIR PREPARERS
The following list includes the agencies that commented during the public review period of the Draft
EIR (as listed in Chapter 2.0 of the Final EIR, Table 2-1, Comment Letters Received on the Coral
Mountain Resort Draft EIR).
- Riverside County Airport Land Use Commission (ALUC)
- CALFIRE
- Southern California Association of Governments (SCAG)
- Bighorn Institute
- Riverside County Flood Control (RCFC)
- Imperial Irrigation District (IID)
- Cactus to Clouds
- CVWD
- Center of Biological Diversity
- California Department of Fish and Wildlife (CDFW)
Final EIR Consultants
In addition to consulting with the project's technical report preparers regarding the technical studies,
additional organizations were consulted during the drafting of this Final EIR. The consultants include
ELMT Consulting for the Biological Memo (Appendix D.5 in this Final EIR), Kelly Slater Wave Company
for additional information regarding the Wave Basin (Appendix L.4 and L.5 in this Final EIR), LSA
Associates for their updated studies (Appendix D.3 and D.4 in this Final EIR), Musco Lighting for their
Light Memo (Appendix B.1 and B.2 in this Final EIR), and Urban Crossroads for their Noise Memo
Update (Appendix K.3 in this Final EIR) and Traffic Memo (Appendix L.1 through L.3 in this Final EIR)
(listed in alphabetical order below). The following organizations and individuals provided information
or assistance in the preparation of the Final EIR:
ELMT Consulting
Thomas McGill, Ph.D.
Managing Director, Senior Biologist, Senior Regulatory Specialist
Kelly Slater Wave Company
3300 La Cienega Place
Los Angeles, CA 90016
Phone: 310-804-7092
Harold J. Portillo, VP Wave Project Design
LSA Associates, Inc.
Coral Mountain Resort Final EIR i-4 February 2022
EIR PREPARERS
901 E. Tahquitz Canyon Way, Suite B200
Palm Springs, CA 92262
Phone: 760-416-2075
Jodi Ross -Borrego, Principal Biologist
Jill Carpenter, Senior Biologist/Bat Specialist
Meridian Consultants
706 S. Hill Street, 11th Floor
Los Angeles, CA 90014
Phone: 641-673-0411
Tony Locacciato, AICP
Musco Lighting
100 1st Avenue West
P.O. Box 808
Oskaloosa, IA 52577
Phone: 641-673-0411
Matt Pearson, Non -Sports Engineering Manager
Tim Newendorp, Project Engineer
SZR Law
4590 E. Thousand Oaks Blvd., Suite 100
Westlake Village, CA 91362
Phone: 805-446-1496
James D. Vaughn, Esq.
Urban Crossroads, Inc.
1197 Los Angeles Avenue, Suite C-256
Simi Valley, CA 93065
Phone: 805-426-4477
John Kain, AICP Principal
Marlie Whiteman, Principal Engineer
Coral Mountain Resort Final EIR i-5 February 2022
TABLE OF CONTENTS
Chapters
Chapter 1.0 Introduction 1-1
1.1 Purpose 1-1
1.2 Role of the Lead Agency 1-1
1.3 Organization of the Final EIR 1-1
1.4 Draft EIR Public Review Period 1-3
1.5 Certification of the EIR and Project Selection Process 1-3
1.6 Consideration of Recirculation 1-3
Chapter 2.0 Comment Letters and Response to Comments 2-1
2.1 Purpose 2-1
2.2 Frequent Topics of Concern 2-4
2.2.1 Light and Glare 2-5
2.2.2 Biological Resources 2-11
2.2.3 Water Resources 2-17
2.2.4 Noise 2-28
2.2.5 Traffic 2-32
2.2.6 Length of Draft EIR 2-36
2.2.7 Ability to Comprehend Draft EIR 2-36
2.3 Public Agencies & Area Residents Comment Letters & Responses 2-37
Public Agencies
1. Comment Letter No. 1: Airport Land Use Commission 2-38
2. Comment Letter No. 2: Airport Land Use Commission 2-39
3. Comment Letter No. 3: CALFIRE 2-40
4. Comment Letter No. 4: Southern California Association of Governments2-41
5. Comment Letter No. 5: CALFIRE 2-42
6. Comment Letter No. 6: Riverside County Flood Control 2-43
7. Comment Letter No. 7: Imperial Irrigation District 2-45
8. Comment Letter No. 8: CactusToClouds 2-46
9. Comment Letter No. 9: CALFIRE 2-50
10. Comment Letter No. 10: Coachella Valley Water District 2-52
11. Comment Letter No. 11: Center of Biological Diversity 2-54
12. Comment Letter No. 12: California Department of Fish and Wildlife 2-67
13. Comment Letter No. 13: California Department of Fish and Wildlife 2-69
14. Comment Letter No. 14: Bighorn Institute 2-98
Area Residents
15. Comment Letter No. 15: Anne and Ron Smith 2-101
16. Comment Letter No. 16: Dina Stuart 2-104
Coral Mountain Resort Final EIR i February 2022
TABLE OF CONTENTS
17. Comment Letter
18. Comment Letter
19. Comment Letter
20. Comment Letter
21. Comment Letter
22. Comment Letter
23. Comment Letter
24. Comment Letter
25. Comment Letter
26. Comment Letter
27. Comment Letter
28. Comment Letter
29. Comment Letter
30. Comment Letter
31. Comment Letter
32. Comment Letter
33. Comment Letter
34. Comment Letter
35. Comment Letter
36. Comment Letter
37. Comment Letter
38. Comment Letter
39. Comment Letter
40. Comment Letter
41. Comment Letter
42. Comment Letter
43. Comment Letter
44. Comment Letter
45. Comment Letter
46. Comment Letter
47. Comment Letter
48. Comment Letter
49. Comment Letter
50. Comment Letter
51. Comment Letter
52. Comment Letter
53. Comment Letter
54. Comment Letter
o. 17: Monica Harrington 2-105
o. 18: Connie Glavin 2-108
o. 19: Sarah Zappas 2-109
o. 20: Kristina Dailey 2-112
o. 21: Diane Rebryna 2-114
o. 22: Derek Wong/Brdgette & Phil
o. 23: Bobbie Fleury
o. 24: Agnes Collins
o. 25: Maggie Hamilton
o. 26: Ilona Sala
o. 27: Judy Carey
o. 28: Kelly Welton
o. 29: Mike Charles
o. 30: Dorothy Dupree
o. 31: Kenneth Jones
o. 32: Brenda Vatland
o. 33: Dave Wiezel
o. 34: Diane Rebryna (2)
o. 35: George Koenig
o. 36: Sandra Stratton
Novak 2-119
2-126
2-128
2-132
2-133
2-134
2-135
2-137
2-138
2-139
2-141
2-142
2-143
2-148
2-151
2-155
2-156
2-157
2-158
2-163
2-167
2-174
2-175
2-176
2-178
2-179
2-180
2-183
2-186
2-189
2-197
2-213
2-217
No. 37: Connie Glavin
No. 38: Dan Rendino
No. 39: JoAnne Thompson
No. 40: Carol & Richard Strop
No. 41: Alena Callimanis
No. 42: Lisa Castro
No. 43: Catherine Giles
No. 44: Richard Holub
No. 45: Rob Michiels
No. 46: Rob Michiels
No. 47: Eva Parker
No. 48: Robert Stowe
No. 49: Sheila Warren
No. 50: Carolyn Winnor
No. 51: July 20th City Council Meeting
No. 52: Robert Michiels
No. 53: Dan Rendino
No. 54: Carol Welty &Art Stephens
Coral Mountain Resort Final EIR ii February 2022
TABLE OF CONTENTS
55. Comment Letter
56. Comment Letter
57. Comment Letter
58. Comment Letter
59. Comment Letter
60. Comment Letter
61. Comment Letter
62. Comment Letter
63. Comment Letter
64. Comment Letter
65. Comment Letter
66. Comment Letter
67. Comment Letter
68. Comment Letter
69. Comment Letter
70. Comment Letter
71. Comment Letter
72. Comment Letter
73. Comment Letter
74. Comment Letter
75. Comment Letter
76. Comment Letter
77. Comment Letter
78. Comment Letter
79. Comment Letter
80. Comment Letter
81. Comment Letter
82. Comment Letter
83. Comment Letter
84. Comment Letter
85. Comment Letter
86. Comment Letter
87. Comment Letter
88. Comment Letter
89. Comment Letter
90. Comment Letter
91. Comment Letter
92. Comment Letter
No. 55: Fredrick Roth 2-219
No. 56: Derek Wong 2-220
No. 57: Agnes Collins 2-221
No. 58: Duncan Woodfin 2-223
No. 59: Martin Brewer 2-225
No. 60: Bridgette Novak 2-229
No. 61: Bridgette Novak 2-231
No. 62: Philip Novak 2-236
No. 63: Sandra Stratton 2-241
No. 64: Terje Berger 2-254
No. 65: Alena Callimanis 2-255
No. 66: Wendy Clarke 2-259
No. 67: Diane Rebryna & Anast Demitt 2-262
No. 68: Dan Stiel 2-268
No. 69: Thomas Swope Jr. 2-270
No. 70: Jan Wm. Talbott 2-271
No. 71: Kathy Weiss 2-272
No. 72: August 3rd City Council Meeting 2-277
No. 73: Lisa Jeffery 2-292
No. 74: Rosette Kivel 2-293
No. 75: Natilie Maupin 2-294
No. 76: Liz Ervin 2-295
No. 77: Diane Rebryna 2-297
No. 78: Harvey Reed 2-316
No. 79: Mitchell Tsai 2-318
No. 80: Sally Arroyo 2-352
No. 81: Fritz E. Bachli 2-356
No. 82: Ramon Baez 2-363
No. 83: Bruce Bauer 2-366
No. 84: Alena Callimanis 2-401
No. 85: Alena Callimanis 2-403
No. 86: Alena Callimanis 2-405
No. 87: Alena Callimanis 2-408
No. 88: Alena Callimanis 2-410
No. 89: Alena Callimanis 2-412
No. 90: Anast Demitt 2-413
No. 91: Mary Greening 2-420
No. 92: Carol Jensen 2-424
Coral Mountain Resort Final EIR iii February 2022
TABLE OF CONTENTS
Chapter 3.0
3.1
93. Comment Letter No. 93: Suzanne Kahn 2-426
94. Comment Letter No. 94: Francine Roy 2-427
95. Comment Letter No. 95: Carolyn Winnor 2-430
96. Comment Letter No. 96: Brian and Gale Levy 2-435
97. Comment Letter No. 97: Nancy Bruce 2-439
98. Comment Letter No. 98: Dennis and Jackie Miller 2-446
Revisions to the Draft EIR 3-1
Purpose 3-1
3.2 No Significant New Information Requiring Recirculation 3-26
Chapter 4.0
4.1
4.2
4.3
4.4
Mitigation Monitoring and Reporting Program 4-1
Introduction 4-1
Monitoring Authority 4-1
Enforcement Responsibility 4-2
Mitigation Monitoring Table 4-2
List of Tables
Chapter 2.0
2-1
2.0-3
Chapter 3.0
4.1-1
4.1-7
4.10-8
4.13-13
Chapter 4.0
4-1
Comment Letters and Response to Comments
Comment Letters Received on the Coral Mountain Resort Draft EIR 2-1
Outdoor Water Demand 2-17
Revisions to the Draft EIR
Development Standards Planning Area I 3-3
PA I Development Standards Comparison 3-4
SCAG Connect SoCal Goals Consistency Analysis 3-16
Project Buildout (2026) 3-23
Mitigation Monitoring and Reporting Program
Coral Mountain Resort Mitigation Monitoring and Reporting Program 4-3
List of Exhibits
Chapter 2.0
2-1
2-2
2-3
Comment Letters and Response to Comments
Surf Lighting — Cross Sections 2-8
Surf Lighting Distance 2-10
Conceptual PBS Barrier Plan 2-16
Coral Mountain Resort Final EIR iv February 2022
TABLE OF CONTENTS
ES -6 Model Inflows and Outflows by Scenario 2-26
ES -8 Cumulative Change in Storage for Future Scenarios 2-27
Chapter 3.0 Revisions to the Draft EIR
3-11 & 4.15-1 Conceptual Water Plan 3-25
List of Appendices
B.1 Lighting Memo, Musco Lighting
B.2 Lighting Test Memo, Musco Lighting
D.3 Update Focused Bat Survey, LSA Associates
D.4 Update Biological Report, LSA Associates
D.5 Biological Resources Assessment (McGill Memo), Dr. McGill, ELMT Consulting
K.3 Noise Memo, Urban Crossroads, Inc.
L.1 Traffic Impact Analysis, Urban Crossroads, Inc.
L.2 VMT Evaluation (Revised), Urban Crossroads, Inc.
L.3 Traffic Memo, Urban Crossroads, Inc.
L.4 Average Surfer Population, Kelly Slater Wave Co.
M.1 Wave Basin Areas, Kelly Slater Wave Co.
M.2 Geotechnical Memo, Kelly Slater Wave Co.
P Trail Easement Letter of Agreement, Desert Recreation District
Coral Mountain Resort Final EIR v February 2022
FINAL ENVIRONMENTAL IMPACT REPORT
Coral Mountain Resort, La Quinta CA
1.0 Introduction
Chapter 1.0 Introduction
1.1 Purpose
The City of La Quinta is the "Lead Agency" under California Environmental Quality Act (CEQA)
(California Public Resources Code, Section 21000, et seq.) and the CEQA Guidelines (California Code
of Regulations, Title 14, Section 15000, et seq.) is responsible for preparing the Draft Environmental
Impact Report (Draft EIR) and Final Environmental Impact Report (Final EIR) for the proposed Coral
Mountain Resort project ("project").
The Final EIR includes the Draft EIR, written comments received during the public comment period,
responses to those comments, and changes or errata to the Draft EIR. The City of La Quinta prepared
this EIR to evaluate the potential environmental impacts associated with the construction and
operation of the proposed Coral Mountain Resort project.
1.2 Role of Lead Agency
Under CEQA and the CEQA Guidelines, "Lead Agency" means the public agency that has the principal
responsibility for carrying out or approving a proposed project. Pursuant to Section 15051(b) of the
CEQA Guidelines, a city normally serves as the lead agency for private development projects within
its boundaries. The CEQA Guidelines provides that a lead agency is responsible for preparing the
environmental documents for a project, including an environmental impact report.
The CEQA Guidelines further provide that a lead agency must consult with responsible agencies as
part of the lead agency's efforts to prepare the environmental document. CEQA and the CEQA
Guidelines state that a "Responsible Agency" means a public agency other than the lead agency that
has responsibility for carrying out or approving the project. Section 15063(g) of the CEQA Guidelines
also provides that in addition to consulting with responsible agencies, lead agencies must also solicit
consultation and comments from trustee agencies. Under CEQA, a "Trustee Agency" means a state
agency with "jurisdiction by law" over natural resources affected by a project that are "held in trust
for the people of the State of California," though the agency need not have any approval authority
over the project.
1.3 Organization of Final EIR
The Final EIR have been prepared in conformance with CEQA, the CEQA Guidelines, and the City of La
Quinta CEQA Guidelines to evaluate the potential environmental impacts associated with the
implementation of the proposed Project, that is anticipated to begin development in 2021. The CEQA
Coral Mountain Resort Final EIR
1-1 February 2022
1.0 INTRODUCTION
Guidelines require the City to prepare an EIR for any project that includes a request for approval of
discretionary actions that may result in significant effects on the environment. Upon preliminary
review, the City determined that since the project may have significant effects on the environment,
a Draft EIR was prepared and circulated for public review and inspection in June 2021.
This Final EIR was prepared pursuant to Section 15089 of the CEQA Guidelines and incorporates the
June 2021 Draft EIR by reference; comments on the Draft EIR received during the 45 -day public
comment period; written responses to comments; and corresponding revisions to the text of the Draft
EIR. The Draft EIR included the preparation of technical studies such as Biological Resources, Cultural
Resources, Hydrology, Noise, Traffic, etc.
Pursuant to Section 15132 of the CEQA Guidelines, this Final EIR includes the following components:
Chapter 1.0 Introduction
This Chapter provides an introduction of the environmental process.
Chapter 2.0 Comment Letters and Response to Comments
This Chapter provides a list of persons, organizations, and public agencies that
provided comments on the Draft EIR during the 45 -day public review period.
Comments written to the City, and their responses, are provided in this Chapter
2.0.
Chapter 3.0 Revisions to the Draft EIR
This Chapter provides clarification and makes necessary corrections to certain in
formation in the Final EIR.
Chapter 4.0 Mitigation Monitoring and Reporting Program
This Chapter provides the project's Mitigation Monitoring and Reporting Program
(MMRP), which identifies mitigation measures, timing, responsibility for mitigation
implementation, and levels of significance after mitigation.
The Draft EIR and Final EIR were both made available for public review and inspection at the City of
La Quinta Planning Division, the La Quinta Library, and on the City's website:
City of La Quinta
Planning Division
78495 Calle Tampico
La Quinta, CA 92253
Phone: 760-777-7000
Coral Mountain Resort Final EIR
1-2 February 2022
1.0 INTRODUCTION
Hours: Monday — Thursday 7:30 a.m. to 5:30 p.m. and Friday 8:00 a.m. to 5:00 p.m.
http://www.laquintaca.gov/thewave
La Quinta Library
78275 Calle Tampico
La Quinta, CA 92253
Phone: 760-564-4767
Hours: Monday — Thursday 10 a.m. to 7 p.m.; Friday — Saturday 10 a.m. to 6 p.m.; and
Sunday 12 p.m. to 4 p.m.
1.4 Draft EIR Public Review Period
The Draft EIR was released for public comment on June 22, 2021. The document was sent to the
California State Clearinghouse, public agencies, and individuals who had expressed an interest or
requested to receive the Draft EIR. In addition, a Notice of Completion/Notice of Availability was
published in the Desert Sun. The Notice of Completion/Notice of Availability was also sent to the
Riverside County Clerk. Copies of the Draft EIR were made available at the locations listed above.
The public comment period ended on August 6, 2021. During the public review period, the City
received a total of 98 comments in the form of letters, emails, and verbal presentations.
1.5 Certification of the EIR and Project Selection Process
In order to certify the Final EIR, CEQA Guidelines Section 15090 prescribe that the City must find that:
a) The Final EIR has been completed in compliance with CEQA;
b) The Final EIR was presented to the decision-making body and that the decision-making body
reviewed and considered the information contained in the Final EIR; and
c) The Final EIR reflects the Lead Agency's independent judgement and analysis.
If the Lead Agency certifies the Final EIR, it can then consider approving the project, in whole or in
part.
1.6 Consideration of Recirculation
CEQA Guidelines Section 15088.5 requires a Lead Agency to recirculate a revised EIR only if significant
new information is identified following the release of the Draft EIR. "Significant new information" can
include changes in the project or environmental setting, as well as additional data or other
information, for example, a new significant environmental impact or substantial increase in the
severity of an environmental impact. New information is not considered significant unless the EIR is
Coral Mountain Resort Final EIR
1-3 February 2022
1.0 INTRODUCTION
changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial
adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect that
the proponent has declined to implement.
The City has evaluated the information contained in this Final EIR as well as other information in the
record, and has determined that no significant new information has been added to the EIR after public
notice was given of the availability of the Draft EIR for pubic review. Therefore, CEQA does not require
recirculation of the Draft EIR.
Coral Mountain Resort Final EIR
1-4 February 2022
FINAL ENVIRONMENTAL IMPACT REPORT
Coral Mountain Resort, La Quinta CA
2.0 RESPONSES TO COMMENTS
Chapter 2.0 Responses to Comments
2.1 Purpose
This chapter provides the comments made on the Coral Mountain Resort Draft EIR, and responses to
those comments. This chapter includes copies of the comment letters received by the City of La
Quinta regarding the Draft EIR. Each comment letter is numbered for reference and the individual
comments in each letter are identified by a letter (i.e., "a", "b", etc.). In addition, Section 2.2 of this
chapter also includes thorough "topical responses" concerning particular topics which were raised in
many of the comment letters, including light, biological resources, water resources, noise, and traffic.
These "topical responses" are referenced in some of the individualized comment responses to
minimize redundancy and shorten the overall length of this Final EIR.
The City received a total of 98 comment letters, including 14 from public agencies and other
organizations, and 84 from local area residents. Table 2-1, Comment Letters Received on the Coral
Mountain Resort Draft EIR, provides a list of all comment letters received, from public agencies and
members of the general public, including the ID number assigned to each comment letter, the date it
was received, and commenter's name.
Table 2-1
Comment Letters Received on the Coral Mountain Resort Draft EIR
Public Agencies
Letter ID
Date
Agency
Commenter
1
June 22, 2021
ALUC
Paul Rull
2
June 22, 2021
ALUC
Daniel Zerda
3
June 28, 2021
CALFIRE
Kohl Hetrick
4
June 29, 2021
SCAG
Annaleigh Ekman
5
June 30, 2021
CALFIRE
Kohl Hetrick
6
August 3, 2021
RCFC
Deborah De Chambeau
7
August 4, 2021
IID
Donald Vargas
8
August 6, 2021
Cactus to Cloud
Sendy Barrows
9
August 6, 2021
CALFIRE
Adria Reinertson
10
August 6, 2021
CVWD
William Patterson
11
August 6, 2021
Center of Biological Diversity
Ross Middlemiss
12
August 9, 2021
CDFW
Heather Pert
13
August 13, 2021
CDFW
Heather Pert
14
August 3, 2021
Bighorn Institute
James R. DeForge
Coral Mountain Resort Final EIR
2-1
February 2022
2,0 RESPONSES TO COMMENTS
Area Residents
Letter ID
Date
Commenter
15
June 21, 2021
Anne and Ron Smith
16
June 21, 2021
Dina Stuart
17
June 22, 2021
Monica Harrington
18
June 23, 2021
Connie Glavin
19
July 1, 2021
Sarah Zappas
20
July 1, 2021
Kristina Dailey
21
July 2, 2021
Diane Rebryna
22
July 3, 2021
Derek Wong/Bridgette & Phil Novak
23
July 6, 2021
Bobbie Fleury
24
July 7, 2021
Agnes Collins
25
July 8, 2021
Maggie Hamilton
26
July 8, 2021
Ilona Sala
27
July 9, 2021
Judy Carey
28
July 10, 2021
Kelly Welton
29
July 11, 2021
Mike Charles
30
July 12, 2021
Dorothy Dupree
31
July 12, 2021
Kenneth Jones
32
July 12, 2021
Brenda Vatland
33
July 12, 2021
Dave Wiezel
34
July 13, 2021
Diane Rebryna (2)
35
July 14, 2021
George Koenig
36
July 15, 2021
Sandra Stratton
37
July 16, 2021
Connie Glavin
38
July 18, 2021
Dan Rendino
39
July 18, 2021
JoAnne Thompson
40
July 19, 2021
Carol & Richard Strop
41
July 20, 2021
Alena Callimanis - Re: City Council Meeting
42
July 20, 2021
Lisa Castro City Council Presentation (sent by Alena Callimanis)
43
July 20, 2021
Catherine Giles
44
July 20, 2021
Richard Holub
45
July 20, 2021
Rob Michiels (1)
46
July 20, 2021
Rob Michiels (2)
47
July 20, 2021
Eva Parker
48
July 20, 2021
Robert Stowe
49
July 20, 2021
Sheila Warren (sent by Alena Callimanis)
50
July 20, 2021
Carolyn Winnor (sent by Alena Callimanis)
Coral Mountain Resort Final EIR
2-2
February 2022
2,0 RESPONSES TO COMMENTS
51
July 20, 2021
July 20th City Council Meeting - Transcribed Presentations
52
July 21, 2021
Robert Michiels (3)
53
July 21, 2021
Dan Rendino
54
July 21, 2021
Carol Welty/Art Stephens
55
July 26, 2021
Fredrick Roth
56
July 27, 2021
Derek Wong
57
July 28, 2021
Agnes Collins
58
July 28, 2021
Duncan Woodfin
59
July 29, 2021
Martin Brewer
60
August 2, 2021
Bridgett Novak (1)
61
August 2, 2021
Bridgett Novak (2)
62
August 2, 2021
Philip Novak
63
August 2, 2021
Sandra Stratton
64
August 3, 2021
Terje Berger
65
August 3, 2021
Alena Callimanis - sent for City Council Meeting
66
August 3, 2021
Wendy Clarke
67
August 3, 2021
Diane Rebryna and Anast Demitt City Council
68
August 3, 2021
Dan Stiel
69
August 3, 2021
Thomas Swope Jr.
70
August 3, 2021
Jan Wm. Talbott
71
August 3, 2021
Kathy Weiss
72
August 3, 2021
August 3rd City Council Meeting - Transcribed Presentations
73
August 4, 2021
Lisa Jeffery
74
August 4, 2021
Rosette Kivel
75
August 4, 2021
Natilie Maupin
76
August 5, 2021
Liz Ervin
77
August 5, 2021
Diane Rebryna
78
August 5, 2021
Harvey Reed
79
August 5, 2021
Mitchell Tsai - Attorney
80
August 6, 2021
Sally Arroyo
81
August 6, 2021
Fritz E. Bachli
82
August 6, 2021.
Ramon Baez
83
August 6, 2021
Bruce Bauer - Attorney
84
August 6, 2021
Alena Callimanis 1
85
August 6, 2021
Alena Callimanis 2
86
August 6, 2021
Alena Callimanis 3
87
August 6, 2021
Alena Callimanis 4
88
August 6, 2021
Alena Callimanis 5
89
August 6, 2021
Alena Callimanis 6
Coral Mountain Resort Final EIR
2-3
February 2022
2.0 RESPONSES TO COMMENTS
90
August 6, 2021
Anast Demitt
91
August 6, 2021
Mary Greening
92
August 6, 2021
Carol Jensen
93
August 6, 2021
Suzanne Kahn
94
August 6, 2021
Francine Roy
95
August 6, 2021
Carolyn Winnor
96
August 5, 2021
Brian and Gale Levy
97
August 6, 2021
Nancy Bruce
98
August 5, 2021
Dennis and Jackie Miller
CEQA and the CEQA Guidelines provides that written comments received during the public review
period for a draft EIR must be responded to in writing. Section 15088(b) of the CEQA Guidelines
provides that the written response can be either in a printed copy or in an electronic format. The
responses to comments must provide reasoned, good faith analyses regarding all significant
environmental issues raised in the EIR comments. The level of detail contained in the response,
however, may correspond to the level of detail provided in the comment (i.e., responses to general
comments may be general). Moreover, responses to comments submitted by another public agency
must be provided to the commenting agency at least 10 days before certification of the Final
EIR. When such comments from a sister agency disclose new or conflicting data or opinions that raise
concern that the agency may not have fully evaluated the project and its alternatives, the lead agency
must pay particular care to respond with good faith, reasoned analysis. However, comments that are
only objections to the merits of the project itself may be addressed briefly, as they do not relate to a
specific environmental concern.
In light of the foregoing, the City's responses to the comment letters identified in Table 2.0-1 are
discussed below in two Sections. Section 2.2 discusses the City's general responses to "Frequent
Topics of Concern" raised in the comment letters, whereas Section 2.3 discusses individualized
responses to each comment letter received by the City. As described above, comments which pertain
to "Frequent Topics of Concern" have been addressed via reference to that topical response.
2.2 Frequent Topics of Concern
The comments received during the public review period raised various issues of concern regarding
environmental topics discussed within the Draft EIR. These topics (listed in order of appearance in the
Draft EIR) include project -generated light, impacts to biological resources, water resources, noise, and
traffic.
Therefore, responses to these topics are provided in the subsections below — indicated as Subsections
2.2.1 through 2.2.5. Each subsection provides a thorough, reasoned and good faith analysis of the
concerns raised over the proposed project's potential effects on light, biological resources, water
Coral Mountain Resort Final EIR
2-4 February 2022
2.0 RESPONSES TO COMMENTS
resources, noise, and traffic, and how each have been adequately addressed in the Draft and Final
EIRs.
Additional comments, not associated with the environmental topics discussed within the Draft EIR,
included the length of the Draft EIR, and the complexity of the Draft EIR and supporting documents.
These topics are discussed under Subsection 2.2.6 and 2.2.7. The purpose of each subsection is to
avoid unnecessary duplication and potential confusion over providing individualized responses to
each separate comment submitted in relation to each of the respective issues.
2.2.1 Light and Glare
Comments were received on the lighting proposed for the Wave Basin planned in Planning Area III -B.
These comments requested additional information on the lighting fixtures and given the proposed
80 -foot height of the proposed fixtures, the potential for light and glare from these fixtures to impact
Coral Mountain and other surrounding areas and produce a level of light and glare that would be
inconsistent with City of La Quinta policies and regulations for nighttime lighting, or otherwise cause
significant adverse effects. Comments received also asked if the amount of light and glare associated
with these fixtures would result in substantial change in the character of the area. Comments also
asked if use of light fixtures with a lower height, or other changes to the proposed lighting plan could
reduce any impacts that commenters allege would be potentially significant.
The proposed project includes an artificial Wave Basin in the southwestern portion of the project site.
To illuminate the Wave Basin during evening hours (dusk until 10:00 p.m.), seventeen LED light
fixtures with a height of 80 feet are proposed around the Wave Basin. To determine the potential for
these light fixtures to impact the areas located around the Wave Basin, a Lighting Analysis was
prepared by Musco Lighting, which was included in Appendix B in the Draft EIR. Section 4.1,
Aesthetics, of the Draft EIR incorporated information from this Lighting Analysis to evaluate the
potential for the light from these fixtures to affect the surrounding areas and existing and planned
land uses. Exhibit 4.1-14, Lighting Analysis Light Direction, of the Draft EIR (page 4.1-65), illustrates
the orientation of the lights on the Wave Basin facility, and Exhibits 4.1-15 through 4.1-19 illustrate
that the light and glare are focused on the Wave Basin itself, with no spillage outside the planning
area.
The proposed light fixtures will be located and oriented to efficiently illuminate the Wave Basin, while
avoiding spillage of light onto the surrounding areas, consistent with the City's requirements under
Section 9.100.150 of the La Quinta Municipal Code. Based on the findings of this project -specific
lighting analysis, light from the proposed LED light fixtures will not spillover or substantially increase
light levels in the areas surrounding the Wave Basin. This is due to the directional orientation of the
lights downward and toward the Wave Basin. Additionally, to comply with Section 9.100.150 of the
La Quinta Municipal Code, the illumination of the recreational Wave Basin will meet the shielding
requirements in the Municipal Code, and will conclude at 10:00 p.m. To assure that the operation of
Coral Mountain Resort Final EIR
2-5 February 2022
2.0 RESPONSES TO COMMENTS
the Wave Basin will conclude at 10:00 p.m., compliant with recreational operational hours allowed
by the City of La Quinta (Section 9.100.150(I)(4)(b)), Mitigation Measure AES -3 was included in the
Draft EIR. AES -3 states the following: "The operation of the Wave Basin will be limited to the hours of
7:00 a.m. to 10:00 p.m., and the lighting will only be permitted between dusk and 10:00 p.m. to
ensure compliance with the City's outdoor lighting requirements (LQMC 9.100.150)."
Based on this information, the Draft EIR concluded that operation of the Wave Basin will not have any
significant light and glare impacts because the lighting is oriented directly onto the Wave Basin,
complies with all Municipal Code requirements for lighting, and avoids spillage of light or glare outside
of the planning area. Please consult Section 4.1, Aesthetics, for analysis, exhibits, findings, and
conclusions regarding the Tight fixtures proposed for the Wave Basin.
To respond to the questions and comments on the proposed lighting plan for the Wave Basin,
additional information has been prepared to elaborate and clarify the information provided in the
Draft EIR that supported the conclusion that the proposed lighting will not result in significant impacts
to daytime or nighttime views in the area. Musco Lighting provided a memorandum to further explain
the performance characteristics of the LED light fixtures proposed and the configuration and
orientation of these fixtures. This Lighting Analysis Memorandum ("Lighting Memo") is included as
Appendix B.1 of this Final EIR. The 80 -foot LED light fixtures proposed around the Wave Basin will be
Musco Total Lighting Control (TLC) for LED technology fixtures.
LED lights produce a focused source of light that can be designed to provide adequate light while
avoiding light overspill and minimizing glare. The figure below shows the evolution of lighting design
by the manufacturer of the light fixtures proposed around the Wave Basin. As shown in this figure,
the TLC for LED fixture has 3 LED fixtures at the top of the pole. This is representative of the actual
TLC for LED fixtures proposed for the Wave Basin, which includes a combination of 2 to 6 LED fixtures
per pole (See Draft EIR Appendix B for a full description of the proposed lighting system). As shown,
the TLC for LED fixture focuses the light down in a manner that prevents direct view of the LED lights.
As noted at the bottom of this figure, these are photographs of light fixtures taken 100 feet from the
edge of the field where these fixtures are installed. The lighting level from each fixture in candela is
also identified.
Coral Mountain Resort Final EIR
2-6 February 2022
2.0 RESPONSES TO COMMENTS
Impact on Playability and Glare
Light Control
1977 1989 1989 1989 2005 Today
TLC for LED -
Today
Other LED
102,350 34,800 21,400 13,660 11,858 7
candela candela candela candela candela candela
141,145
candela
High
50000
Marginal
10000
Candela
Low
1000
Candela values {single fixture} reported from photometric reports at 15' above the beam center.
Photographed at F00ft (30 m) from field edge. Used equal parameters for: On -field fight level per pole, Mounting height, Lumlmaim aiming angles, and pole Distance horn aiming point.
None
The proposed TLC for LED light fixtures emit almost no direct light when viewed from 100 feet from
the fixture because the directional LED lighting with visors is able to generate the same or superior
levels of lighting on the Wave Basin as the prior generations of lighting while providing full cut off the
light overspill. Specifically, at a distance of 100 feet from the fixture, 7 candela is emitted, which is a
level barely perceived. LED light is a more focused source of light and for this reason, typical LED
fixtures can generate direct light levels similar to, or more intense, than older metal halide light
fixtures. For example, as illustrated above, lights from 2005 fixtures can emit 11,858 candela when
viewed from 100 feet from the fixture, and the typical 1989 unshielded light fixtures shown emit
21,400 candela when viewed from 100 feet from a fixture.
In addition to the light source technology, another major factor in controlling light is the mounting
height and aiming angles of the light fixtures. Mounting height can help control both coverage of the
area to be lit and cutoff of light from spilling over into adjacent areas by optimizing the angle at which
the light is aimed and cutting off the lighting at a point still within the basin itself. As shown in the
Fixture Lighting Cros-Section Exhibit on the following page, which was prepared by Musco Lighting
and Kelly Slater Wave Company, the proposed lighting system for the Wave Basin aims each light to
a point near the middle of basin and uses a visor to cut-off the light at or before reaching the far side
of the Basin. This exhibit shows the lighting at two cross-sections of the Wave Basin (at poles 7 and
10 in the northwestern endzone of the Basin and at poles 6 and 11 at a narrower portion of the Basin).
As shown in two cross-sections, the light from each pole is aimed down toward the center of the
Coral Mountain Resort Final EIR
2-7 February 2022
FINAL ENVIRONMENTAL IMPACT REPORT
Coral Mountain Resort, La Quinta CA
2.0 RESPONSES TO COMMENTS
REFLECTANCE 01FBO-Ray CF r
VISOR OVERALL WMENSAt0M
THOUGHT'S VERY LOW
PROP. PLANNING
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PROP R' ANMNG AREA UNE
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PROP. PLA NG AREA UNE
133.2'
SECTION 'A'
SCALE- 1"= 40'
17.97
MSA CONSULTING, INC.
PLANNING 3.CIVILENGINEERING LAND SURVEYING
34200 Bob Hope Dth Rancho Mirage, CA 92270
760320.9831 nGsconsulti9ginc.com
SECTION 'B'
SCALE T"= 40'
PROP R' ANNAVG AREA 11NE
SURF LIGHTING - CROSS SECTIONS
DECEMBER 1D, 2021
CORAL MOUNTAIN RESORT
Coral Mountain Resort Final EIR
2-8
February 2022
2.0 RESPONSES TO COMMENTS
Basin, with a visor cut-off near the far side of the Basin, thus preventing light overspill outside of the
Wave Basin and also avoids any light emitting upward above the fixture height. Depending on the
specific pole, the lighting is cut-off between 12 and 22 degrees below a horizontal plane running
through the lowest point of the fixture, which exceeds the "dark skies" requirements of La Quinta
Municipal Code Section 9.100.150. If the pole height of the system were to be reduced, the system
would remain dark skies compliant but the angles used to aim and cut-off the light would need to
extend further across the Basin, which would result in less effective lighting within the Basin, light
overspill outside the Basin, or both.
In response to requests made by City officials, an actual demonstration of the Musco TLC for LED
lights proposed to be used for the Wave Basin was performed on November 17, 2021, from 7:00 p.m.
to 8:00 p.m. Two locations on the Wave Basin portion of the project site were selected for the test,
pole 8 (the pole nearest Coral Mountain) and pole 16 (the pole closest to the nearest adjacent
residences). The test fixtures for pole 8 were able to be staged and the exact location and elevation
proposed for the actual lighting system. The test fixtures for pole 16 were staged approximately 135'
south of the proposed location of pole 16 (closer to the adjacent residences) due to physical access
constraints. Although only two 600 -Watt lighting fixtures are proposed for poles 8 and 16, four 1200 -
Watt fixtures were used on both poles to provide a worst-case demonstration of the proposed lighting
because other poles include four 1200 -Watt fixtures (see DEIR Appendix B, Lighting System
Pole/Fixture Summary).
Light readings were taken before and after the light fixtures were turned on to determine the actual
light from the fixtures at each measurement location. Prior to turning the fixtures on, light levels in
the area were measured consistently at 0.01 foot candles (FC), which represents an imperceptible
light level. Readings were taken at 30 -foot intervals extending out from all sides of each test pole. At
120 -feet behind and to the side of each pole, the light readings were consistently at 0.01 FC, indicating
that these locations were receiving no light from the test light fixtures. The test and results are
summarized in a technical memorandum prepared by Musco and Kelly Slater Wave Company, which
is attached as Appendix B.2 to this Final EIR. Appendix C to that memo provides contours for where
the lighting from the proposed lighting system will drop to 0.5 FC and 0.01 FC, and that exhibit is also
copied below. As shown in the Surf Lighting Distance lighting figure on the following page, the lighting
drops to 0.01 FC very close to the Wave Basin planning area property line and is approximately 375
feet from the nearest part of Coral Mountain. These contours were generated by the Musco computer
modeling and are consistent with the exhibits included with the Draft EIR. In addition, the computer
modeling results were further verified by the actual light readings taken during the lighting
demonstration, as further explained in Appendix B.2.
Coral Mountain Resort Final EIR
2-9 February 2022
2.0 RESPONSES TO COMMENTS
p.
044 PIO
4 , •ri
1:44.1
P6 • Wave Baja
lorif."016'
Legend
0.01 Foot Candle Extents
0.5 Foot Candle Extents
P3 Pole Number / Location
• `‘.
1.131414'
N.T.S.
SURF LIGHTING DISTANCE
MSA CONSULTING I NC.
PLANNING CIVIL ENGINEERING LAND SURVEYING DECEMBER 10,2021
34200 Bob Hope Dan, Rancho Wage. CA 92270
760320000 rrisaconsultinginucorn
CORAL MOUNTAIN RESORT
Coral Mountain Resort Final EIR
2-10
February 2022
2.0 Comment Letters and Response to Comments
The analysis provided in Section 4.1, Aesthetics, of the Draft EIR, which incorporates information from
the Lighting Analysis provided by Musco Lighting (Appendix B in the Draft EIR), and the Lighting Memo
provided by Musco Lighting (Appendix B.1 in this Final EIR) and technical memo summarizing the on-
site lighting demonstration (Appendix B.2 in this Final EIR) which provides additional information that
elaborates on and supports the information and analysis in the Draft EIR, provide substantial evidence
supporting the conclusion that the proposed lighting fixtures for the Wave Basin facility will not result
in significant light or glare impacts.
2.2.2 Biological Resources
The City received multiple comments regarding the potential for the project to result in impacts to
Peninsular Bighorn Sheep (PBS), a federally endangered species and State endangered and California
Fully Protected species.
A Biological Report was conducted for the project site in order to determine the existence or potential
occurrence of special-interest plant and animal species within the study area and in the project
vicinity. A literature review was completed, and a field survey of the project site was conducted. The
Biology Report, provided as Appendix D.1 in the Draft EIR, was prepared in compliance with CEQA,
the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP), and the Federal and
California Endangered Species Acts. The Biology Report determined that the proposed project would
result in less than significant impacts to biological resources with the implementation of mitigation
measures. These mitigation measures are listed as Mitigation Measures BIO -1 through BIO -6 in
Section 4.14, Biological Resources, in the Draft EIR (page 4.3-22). A full discussion and analysis
regarding biological resources is provided in Section 4.3 of the Draft EIR.
Following the comments provided relating to PBS, the City consulted with California Department of
Fish and Wildlife (CDFW) staff to discuss the potential for the project to result in impacts to PBS. In
addition, a focused analysis was prepared by Dr. Tom McGill at ELMT Consulting addressing the
presence of PBS in the area around the site, the suitability of the habitat on the site for PBS, and the
potential for the project to result in impacts to PBS. This study, titled Biological Resources Assessment
of the Coral Mountain Site and Adjacent BLM Lands, is provided in Appendix D.5 of this Final EIR (the
"Dr. McGill Report").
PBS in the San Jacinto and Santa Rosa Mountain ranges is a covered species under the CVMSHCP. PBS
Habitat within these two mountain ranges are part of the Santa Rosa and San Jacinto Mountains
Conservation Area, one of twenty-one Conservation Areas that comprise the Reserve System
identified in the CVMSHCP.
There are 211,070 acres within this Conservation Area, 55,890 of which are considered Essential
Habitat for PBS. PBS are restricted to east -facing slopes, below 4,000 feet, of the Peninsular Ranges.
Above 4,000 feet, the vegetation become denser, decreasing visibility and, therefore, increasing the
risk of predation to PBS. The elevational patterns of vegetative associations, in combination with
Coral Mountain Resort Final EIR
2-11 Februray 2022
2.0 RESPONSES TO COMMENTS
predator avoidance behavior, has resulted in PBS using a narrow band of elevation, from 800 to 3,400
feet, on the lower slopes of the San Jacinto and Santa Rosa Mountains. The population of PBS in the
Peninsular Ranges was listed as endangered in 1998. At the lowest elevation of their range, PBS
movement onto the valley floor is very limited because of the typical hesitancy to venture far from
escape terrain. Their habitat can be visualized as a long, narrow band that runs north to south along
the lower elevations of the San Jacinto and Santa Rosa Mountains.
Dr. McGill completed a site visit that included pedestrian surveys of the Coral Mountain project site
and adjacent portions of Coral Mountain and BLM lands west of the site to evaluate the suitability of
the project site and adjacent land to support PBS.
Based on observations made during the site visit, Dr. McGill determined that the southwestern side
of Coral Mountain and the hills between the southern end of Coral Mountain and the eastern slopes
of the Santa Rosa Mountains areas provide an area for PBS to move from the Santa Rosa Mountains
into this habitat and then over to Coral Mountain. Available radio collar tracking data from CDFW
seems to suggest this. Venturing off Coral Mountain onto the valley floor area on the east side at the
west boundary of the project site would subject PBS to threats including collisions with vehicles,
predation by native predators, coyote and mountain lion, exposure to toxic landscape plants, and
entanglement in wire fences.
Dr. McGill confirmed that the project site does not contain suitable PBS habitat. Coral Mountain,
however, provides limited foraging habitat and limited escape cover. The intervening area between
Coral Mountain and the Santa Rosa Mountains consisting of both hilly and flat terrain owned by the
Bureau of Land Management provides some escape cover but exposes PBS venturing out of the Santa
Rosas to predation by coyotes and other large predators.
The project site is not within or adjacent to the boundaries of the Santa Rosa and San Jacinto
Mountains Conservation Areas. However, habitat modification from development can attract PBS
outside of these Conservation Areas and create threats to PBS, as described above. The project's
location in proximity to occupied PBS territory on Coral Mountain results in an edge effect that has
the potential to impact the species if PBS were to be attracted onto the project site for potential
sources of food or water. As stated on page ES -12 of the CVMSHCP, "[t]he purpose of the Land Use
Adjacency Guidelines is to avoid or minimize indirect effects from development adjacent to or within
the Conservation Areas.'
Accordingly, the City and applicant have agreed that the project will comply with the Adjacency
Guidelines relating to PBS because the sheep are known to travel outside the designated
Conservation Area for sources of forage and water. As explained in the ELMT Consulting report, Dr.
McGill determined that the project, as amended by the addition of the sheep barrier and restricted
landscape palette zone, is consistent with these guidelines which address toxic and other hazardous
plants, drainage, exposure to toxic chemicals and byproducts, lighting, noise, and grading near
conservation areas.
Coral Mountain Resort Final EIR
2-12 February 2022
2.0 RESPONSES TO COMMENTS
A well-designed and maintained barrier/fence along the western edge of the site would eliminate
these potential threats to PBS from site development. A barrier/fence would prevent PBS from exiting
Coral Mountain onto the site, where there is no escape cover and where they would be very
vulnerable to predation and exposure to toxic plants, herbicides and insecticides. PBS would still be
able to transverse the open space on the BLM lands between the Santa Rosas and Coral Mountain
but will not be able to migrate off Coral Mountain onto the valley floor area of the project site.
The proposed Specific Plan has been modified to include a Conceptual P85 Barrier Plan that defines
the location and extent of fencing for the project site (please see Figure 13 of the Specific Plan,
duplicated below, and associated text on pages 35-39 of the Specific Plan).
The Barrier Plan requires an 8 -foot -high fence along the entire western boundary to serve as a
physical barrier to prevent Peninsular bighorn sheep (PBS) from accessing the site. The fence/wall
design will be approved by the City of La Quinta in consultation with the California Department of Fish
and Wildlife (CDFW). It will draw from the prototypical fencing types described in the Coachella Valley
Conservation Commission (CVCC) "PBS Barrier Project" and will be consistent with the Coachella
Valley Multi -Species Habitat Conservation Plan.
The Specific Plan plant palette (Table 3 in Section 4.4.3 of the Specific Plan) will include approved
specimens listed as "Coachella Valley Native Plants Recommended for Landscaping" (CVMSHCP Table
4-112) and will avoid specimens listed as "Prohibited Invasive Ornamental Plants" (MSHCP Table 4-
113) in all areas adjacent to Coral Mountain or other BLM open space, including all properties
adjacent to any portion of the sheep barrier as shown on Figure 13 in the Specific Plan, provided
below (the "Restricted Plant Palette Areas"). In addition, the approved project plant palette will be
referenced in the project CC&Rs and will be enforceable by the property owners' association for the
life of the project.
The project has also been modified to include the mitigation measure requested by CDFW to provide
an education program that will include the preparation of informational materials for distribution to
homeowners and hotel guests on the local environmental setting, including proper interactions with
PBS. Additionally, the project developer will collaborate with the Desert Recreation District (DRD)
regarding the planned public trail connection through the property. The DRD master plan envisions
interpretative materials on the trail and markers intended to educate and inform experiences
regarding the local setting, including desert flora and fauna.
Based on these project features, the project will not result in significant direct or indirect impacts to
PBS or involve the development of suitable habitat that could create an attractive nuisance for PBS.
This conclusion is consistent with the conclusions set forth in the Draft EIR, and is further supported
by the Dr. McGill report, and the Biological Resources Assessment by LSA which has been revised to
reflect the additional bat surveys that were completed following the release of the Draft EIR and
which confirmed the Draft EIR conclusions regarding potential impacts to bats. See Final EIR Appendix
D.4.
Coral Mountain Resort Final EIR
2-13 February 2022
2.0 RESPONSES TO COMMENTS
While the project has been enhanced to include the requested sheep barrier and revised plant
palette, and the Draft EIR has been augmented and clarified to further explain that the project will
not have any significant direct or indirect effects on the Peninsular bighorn sheep, these do not
constitute significant new information as that phrase is defined in CEQA Guidelines Section 15088.5
because none of the information added to the Final EIR "deprives the public of a meaningful
opportunity to comment upon a substantial adverse effect of the project or a feasible way to mitigate
or avoid such an effect," nor does it show any new or significantly more severe environmental effects
than were disclosed in the Draft EIR. Rather, the comments received regarding PBS and the CVMSHCP
requirements demonstrate that the Draft EIR adequately disclosed the project's potential to impact
PBS, and as explained above and in response to the specific comments raised, the project will not
have any significant impacts on this federally endangered and California Fully Protected Species.
The City also received comments on the potential for the proposed Wave Basin lighting system to
affect bats and other wildlife species. An updated bat survey has been provided by the project
biologist to include the follow-up nighttime acoustic and emergence survey performed in June 2021.
The updated document, included as Appendix D.3 in this Final EIR, has been updated to include the
results of the June 2021 surveys and provides more comprehensive recommendations to minimize
potential project -related adverse effects to roosting bats. The Updated Focused Bat Survey found that
although no construction will occur at the rock outcrops at Coral Mountain, where occupied bat
roosts were identified during the April and June 2021 surveys, bats roosting in that area could be
subject to potential adverse effects from an increase in artificial lighting from the proposed project.
Multiple studies indicate that ongoing night lighting, in particular, can be very disruptive to foraging
and roosting behaviors. Stone et al. (2009) found that light pollution can negatively impact bats'
selection of flight routes by limiting the options for flyways, and can even eliminate bats' abilities to
use certain roosts and/or foraging areas. Rydell et al. (2017) and Voigt et al. (2018) note that
maintaining darkness at maternity roosts is particularly important because at these types of roosts,
aggregations of bats are present consistently over a long period of time, individual bats emerge from
predictable locations, and juvenile bats are learning how to fly. Illumination of a maternity roost
renders the colony more vulnerable to opportunistic predators such as raptors and owls, and
predator -avoidance behaviors such as delayed emergence times reduce their foraging opportunities,
thereby lowering juvenile survivorship. Therefore, the consulting biologist updated Mitigation
Measure BIO -4 as follows:
Mitigation Measure BIO -4: To avoid permanent impacts to roosting bats from the installation of new
light fixtures associated with the proposed development, all lighting fixtures shall have light shields
or similar devices (i.e., dark sky compliant lighting) installed to ensure that there is no light trespass
onto Coral Mountain and the surrounding open space. A supplemental light study will be performed
to collect nighttime lighting measurements and confirm that no light trespass onto Coral Mountain is
Coral Mountain Resort Final EIR
2-14 February 2022
2.0 RESPONSES TO COMMENTS
occurring; this will be submitted for City approval prior to issuance of any permit for occupancy or
use of the Wave Basin.
With the implementation of this revised mitigation measure, potential impacts to bats and other
wildlife species are reduced to less than significant levels.
Coral Mountain Resort Final EIR
2-15 February 2022
2.0 RESPONSES TO COMMENTS
CORAL MOUNTAIN RESORT
Legend:
Project Boundary
----
Proposed 6' CMU Community Perimeter Wall
Proposed 8' Sheep Barrier
• •
Alternative BarrierAlignmerrt
Restricted Plant Palette
Additional Restricted Plant Palette
Far Alternative Barrier Alignment
i1
Notes:
information Shown Ai concepfuat onty-
Find alignment may be adusfed to
accommodate ground features and
other design andfor environmental
considerations.
11,1
iA-
Perimeter Waif & Sheep Bcrner as
approved by Cray of !a Quints.
Sheep barter to consist of 8' high fencing
as shown tin approved CVCC 'PBS flamer
Proiieer (see Figure XX) orequ valent
combination at 6' CAW and 2' decorative
wrought iron or tubufer steel' view fence
as appropriate_
See Table 3 of Section 4-4.3 for pion/
restrictions
AVENUE 60
46+
0 el
N.T.S.
Source: MSA Consulting, Inc.
Exhibit Dote: November 30. 2021
MSA
MSACONSU LTINC,INC.COM
CONCEPTUAL PBS BARRIER PLAN
Coral Mountain Resort Final EIR 2-16
February 2022
2.0 RESPONSES TO COMMENTS
2.2.3 Water Resources
Comments were received related to the potential effects of the proposed project on water resources
and the information and analysis in the Draft EIR on this topic. The Draft EIR incorporates information
from the Water Supply Assessment/Water Supply Verification (WSA/WSV), as amended, for the
project approved by the Coachella Valley Water District (CVWD). Comments received on the Draft EIR
questioned whether the method used to estimate the water demand for the Wave Basin was
appropriate given the unique characteristics of the Wave Basin and if, given current and potential
future drought conditions, allocating water for the proposed Wave Basin is appropriate, as well as
whether the water demand associated with the Wave Basin would affect groundwater management
efforts.
CEQA Requirements for Water Supply Analysis
The Draft EIR incorporates information from the Water Supply Assessment/Water Supply Verification
(WSA/WSV) approved by the Coachella Valley Water District (CVWD) as required by Section 15155 of
the CEQA Guidelines. For projects that meet the criteria defined in this section of the CEQA Guidelines
as "water demand projects" the Lead Agency preparing an Environmental Impact Report is required
to request that the governing body of a public water system that will provide water to a proposed
project prepare a WSA. The California Water Code § 10910 requires that a WSA be completed to
ensure that adequate supplies are available to meet the demands of proposed projects. In addition,
the Subdivision Map Act (Government Code § 66473.7) also requires the preparation of a Water
Supply Verification (WSV) for proposed subdivisions.
For this proposed project, the City requested that CVWD prepare and approve a WSA/WSV. CVWD
will be the public water supplier for the project with the source of domestic (potable) water supply
for the project being the Indio Subbasin via CVWD's potable water distribution system. CVWD
approved a WSA/WSV providing an assessment and verification of the availability of sufficient water
supplies during normal, single -dry, and multiple -dry years over a 20 -year projection period to meet
the projected demands of the project, in addition to existing and planned future water demands of
CVWD as required by the Water Code. This WSA/WSV also includes identification of existing water
supply entitlements, water rights, water service contracts, or agreements relevant to the identified
water supply for the project and quantities of water received in prior years pursuant to those
entitlements, rights, contracts, and agreements.
Approved WSA/WSV Wave Basin Water Demand Estimate
CVWD estimates the project's total domestic water demand for indoor and outdoor use will be
approximately 958 acre-feet per year (AFY). The vast majority of this water is for outdoor uses, which
total 801.47 AFY of the total 958 AFY for the project. The project's outdoor water use is calculated
pursuant to the express requirements of CVWD Landscape Ordinance No. 1302.4, and those
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2-17 February 2022
2.0 RESPONSES TO COMMENTS
calculations are shown in Table 2.0-3, Outdoor Water Demand from the Approved WSA/WSV and
copied below:
Table 2.0-3 Outdoor Water Demand
Land use
Hotel
Outdoor Water Demand
Total Max of outdoor Total Outdoor
Acreage Outdoor Landscaped Annual
(AC) Landscaped Area Consumption
Area (07,1 isfl (Ap1f1
Wave Resort - Hotel
Office Building
Open Space - Back of House
Open Space
57 3096 111,993 616
685 10096 298,386 16.41
Open Space - Pop -Up Village 18.77 10096 817,621 44.96
Open Space - Golf (1/4 of 9 holes) 48.00 100% 2,090,880 114.98
Wave Resort - The Wave Perimeter 9.10 10096 396396 21.80
Residential 7
Low Density Residential 17750 6596 6,025,735 27637
Wave Resort - Residential 43.70 6596 1,237,322 68.04
Restaurant
Neighborhood Commercial 2.00 4096 34,848 1.92
Wave Resort - The Farm 2.00 40% 34,848 192
Supermarkets
Neighborhood Supermarket 5.77 40% 100,536 5.53
WVave Pesort - Commercial 6.74 30% 88,078 4,84
open Space 2
Open Space - Pop -Up Village
Lake 2
2794 100% 1,217,066 66.93
Low Density Residential - Lake 657 10096 286.189 38.47
I Wave Resort - The Wave 18.72 10056 815,443 11958
Wave Resort - The Farm Lake 232 10096 D1,059 13.59
Grand Total 384.55 12,655,401.56 801.47
"Residential Rate 7: Estate 1/4 ac Conventional Large SFD,10,000 sf lot, 3595 tot coverage, 6596
outdoor water use
Planning area 111 Resort (2), IV Open Space, and III Resort (6) will combine water usage. The
combined usages total 8138 acres. It is anticipated the water usage for The Wave water body will
be shared among the below areas:
- Planning Area IV - Open space (Pop -Up Villages) -27.01 acres
- Planning Area III Resort (6) - 2655 acres,
- Wave Resort - The Wave Perimeter - 9.10 acres
- Wave Resort - The Wave -18.77 acres
Total of 81.38 acres
The Wave Basin itself is projected to use 119.58 AFY, or approximately 15% of the projected outdoor
water use. The CVWD Landscape Ordinance defines a "Water Feature" as any water applied to the
landscape for non -irrigation, decorative purposes, including fountains, streams, ponds and lakes. The
Wave Basin is considered a water feature under CVWD Landscape Ordinance No. 1302.4. Water
features use more water than efficiently irrigated turf grass and are assigned an evapotranspiration
adjustment factor of 1.1 for a stationary body of water and 1.2 for a moving body of water for this
reason. The proposed Wave Basin is essentially a lake with moving water and, for this reason, CVWD's
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2-18 February 2022
2.0 RESPONSES TO COMMENTS
methodology of applying a 1.2 adjustment factor is appropriate to estimate the amount of water that
will be used by the Wave Basin.
The equation used to estimate the water demand for landscaping and outdoor water under CVWD's
landscape ordinance for a project defines its "Maximum Applied Water Allowance (MAWA)." MAWA
is defined in the CVWD Landscape Ordinance as follows:
"MAXIMUM APPLIED WATER ALLOWANCE (MAWA) — For design purposes, the upper limit of annual
applied water for the established landscape area as specified in Division 2, Title 23, California Code of
Regulations, Chapter 7, Section 702. It is based upon the area's reference evapotranspiration, ET
adjustment factor, and the size of the landscaped area. The estimated applied water use shall not
exceed the Maximum Applied Water Allowance (MAWA)."
The MAWA for the water basin in the Approved WSA/WSV is based on the area's reference
evapotranspiration (Eto), evapotranspiration (ET) adjustment factor, the size of the landscaped area
(LA), and a conversion factor of 0.62 (to gallons per square foot) as shown below:
MAWA = Eto * ET adjustment factor * LA * 0.62
Page 22 in the WSA/WSV WSA identifies the information used to estimate the annual water demand
for the proposed Wave Basin:
• 64.22 inches per year for a reference Eto;
• ET adjustment factor of 1.2 for a moving water body;
• 815,443 square feet of area; and
• a conversion of 0.62 to convert to gallons.
Based on these factors the MAWA for the Wave Basin was determined to be 119.58 AFY calculated
as shown below:
64.22 * 1.2 * 815,443 * 0.62 = 38,961,606 gallons per year; or 38.96 million gallons (MG) per year; or
119.58 AFY.
It should be noted that for purposes of determining the MAWA for the proposed Wave Basin, the
approved WSA/WSV applies the water demand factor to the Wave Basin structure as defined in the
Specific Plan, which at the time the WSA was prepared was conservatively estimated to be 18.72 acres
(815,443 square feet). However, the surface area of the Wave Basin water body will not occupy this
entire area. The water surface area of the proposed Wave Basin will occupy approximately 12.5 acres
(544,500 square feet) of this 18.72 acres (815,443 square foot) area. The remainder of the Wave Basin
area contains the deck and other areas around the Wave Basin. The water demand estimate for the
Wave Basin in the approved WSA/WSV is, therefore, conservative as it applies the water demand
factor to 18.72 acres when the Wave Basin water body will only occupy 12.5 acres of this area.
Adequacy of CVWD Water Supplies to meet project water needs
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2-19 February 2022
2.0 RESPONSES TO COMMENTS
The WSA/WSV also examines the current condition of the Indio Subbasin of the Coachella Valley
Groundwater Basin and concluded that the water supplies available from the Indio Subbasin, the
State Water Project (SWP), the Colorado River, and other sources will be adequate to supply the
project and all other existing and planned uses in accordance with California Water Code Section
10910 et seq.
Information on the groundwater conditions in the Indio Subbasin is provided below in response to
comments regarding the potential effect of the water needed for the Wave Basin on groundwater
conditions and CVWD's groundwater management efforts, taking into account current and potential
future extreme drought periods.
Basin Management
Conditions in the Indio Subbasin are continually being assessed and quantified in management plans
developed and implemented by CVWD.
Management of the Subbasin began in the early 1900s to address increasing water demands from
pumping to meet agricultural, urban, and rural demands, beginning with capture of local stormwater
to supplement the limited natural groundwater replenishment and later by importing water and
source substitution projects. This has been a dynamic process with periods of groundwater depletion
followed by recovery. Groundwater levels and storage reached historical lows in about 2009, but this
overdraft has been stopped by groundwater management efforts and increased groundwater storage
has resulted from active water management planning and projects.
In 2014, the California Legislature enacted the Sustainable Groundwater Management Act (SGMA) to
provide a framework for sustainable groundwater management throughout the state. To meet the
requirements of SGMA in the Indio Subbasin, four local water agencies formed Groundwater
Sustainability Agencies (GSAs): CVWD, Coachella Water Authority (CWA), Desert Water Agency
(DWA), and Indio Water Authority (IWA) to meet the requirements of the SGMA for management of
the Indio Subbasin.
The Indio Subbasin GSAs submitted the 2010 Coachella Valley Water Management Plan (CVWD,
2012a) (2010 CVWMP Update) to the State Department of Water Resources (DWR), accompanied by
a Bridge Document (Indio Subbasin GSAs, 2016) to meet the requirements of SGMA. Updates are
required every 5 years. The 2010 CVWMP meets the requirements as an Alternative Plan to a
Groundwater Sustainability Plan (GSP) as defined by SGMA for the Indio Subbasin. On July 17, 2019,
DWR approved the Alternative Plan with specific recommendations presented in its Indio Subbasin
Alternative Assessment Staff Report and a requirement to submit an Alternative Plan Update by
January 1, 20221. The Indio Subbasin GSAs prepared and released the Draft Indio Subbasin Water
Management Plan Update on September 21, 2021 for public review with comments being accepted
1 The Indio SGMA Update can be accessed here: http://www.indiosubbasinsgma.org/wp-content/uploads/2021/12/Indio-
SGMA-AlternativePlan-voll-Alternative-Plan-FINAL-to-be-Adopted-Nov-2021v3.pdf.
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2-20 February 2022
2.0 RESPONSES TO COMMENTS
through October 29, 2021. The Indio Subbasin Water Management Plan Update will be submitted to
the DWR by January 1, 2022.
Consistent with SGMA, objectives of the Plan Update are to assess and report progress toward
sustainability of the Indio Subbasin, respond to DWR recommendations and, consistent with the goals
of the 2010 CVWMP, make needed updates to ensure that future water demands in the Indio
Subbasin are reliably met in a cost-effective and sustainable manner.
The Indio Subbasin Plan Area currently relies on a combination of local groundwater, Colorado River
water, State Water Project (SWP) exchange water, local surface water, and recycled water to meet
demands for four predominant water user groups: municipal, agriculture, golf, and other (e.g., fish
farms, duck clubs, polo, etc.).
Water flows into the Indio Subbasin from natural infiltration, such as flows from the mountains and
local channels that percolate into the ground; subsurface infiltration between subbasins; artificial
recharge at multiple surface basins, including those immediately south of the project site; wastewater
percolation at treatment plant recharge basins, and percolation from domestic use, agriculture, golf
courses, and other sources. From 2000 to 2019, the return flows from existing uses have represented
the largest source of recharge in the Subbasin, at 402,000 AFY, followed by imported water recharge
at 229,400 and natural watershed runoff and stream channel recharge at 47,800 AFY and subsurface
inflows at 22,800 AFY.
Groundwater pumping, subsurface and drain flows to the Salton Sea, and evapotranspiration are the
three largest sources of water extraction from the Basin. Groundwater pumping, at 674,600 AFY, was
the largest component of outflow from the Indio Subbasin from 2000 to 2019 followed by net drain
flows from agriculture and subsurface outflows of 98,800 AFY. Overall, the storage volume in the
Indio Subbasin was reduced by approximately 110,000 AFY from 2000 to 2009 and increased
approximately 49,100 AFY from 2010 to 2019.
The subbasin was at its minimum storage in 2009, with an estimated loss of storage of approximately
1,890,000 AF from 1970 to 2009, which represents 6 percent of the estimated storage capacity of the
Indio Subbasin. Since 2009, groundwater pumping has decreased by about 25 percent and
replenishment activities have increased, leading to an increase in the amount of groundwater in
storage of approximately 840,000 acre-feet (AFY), or replacement of about 45 percent of the
reduction observed from 1970 to 2009.
Water Demand Projections
The Indio Subbasin Water Management Plan Update addresses a 25 -year planning period from 2020
through 2045. The planning in the Update accounts for uncertainties and changes that could affect
future water demands, including changes in projected growth, the conversion of agricultural land to
urban uses, development on Tribal lands, and the effects of water conservation regulations. Water
demand is projected for four major categories: municipal, agricultural, golf, and other.
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2-21 February 2022
2.0 RESPONSES TO COMMENTS
Total municipal demand for the Indio Subbasin Plan Area is projected to be 235,148 AFY in 2045, an
increase of 71,143 AFY from the 2016 baseline. This municipal demand forecast was developed based
on a variety of information, including customer billing data and a geographic information system (GIS)
database with land use information at the parcel level. A base projection year of 2016 was used based
on the availability of detailed demographic data from the Southern California Association of
Governments. Future water demand projections were based on SCAG growth projections for 2020,
2035, and 2045.
SCAG socioeconomic forecasts for population, households, and employment served as the starting
point for analysis. SCAG GIS local land use planning data was then used to ensure future growth
projections could be accommodated by the vacant land available. GIS mapping was used to identify
vacant and agricultural lands by local jurisdictions available for future development. Additional
information on vacancy rates was used to estimate baseline and projected housing units, including
housing units used by seasonal residents and other part-time uses. Recent development data and
land use were used to allocate future housing units into the single-family and multiple -family
categories. SCAG employment forecasts were used to allocate future commercial, industrial, and
institutional (CII) demands.
This forecast projects an increase in population served by the subbasin from 402,392 in 2016 to
616,048 in 2045, with corresponding increases in residential and landscaping water demand, and
68,149 new jobs by 2045, with associated increases in future commercial, industrial and institutional
(CII) water demands. These forecasts are based on SCAG's regional growth model called "Connect
SoCal," which incorporates General Plan land use assumptions from the cities and counties in
Southern California, including the City of La Quinta. As the project site has been planned for 750
residential units, golf course and other non-residential uses for the past 20 years, the water use
included in CVWD's long-term projections includes the water demands associated with full buildout
of the project site. (See Indio SGMA Alternative Plan, Section 5.3.2). In addition, the project -specific
WSA/WSV confirms CVWD's conclusion that "there will be sufficient water supplies to meet the
demands of the Project, as well as for future demands of the Project plus all forecasted demands in
the next 20 years." (See Draft EIR Appendix M, at p. 58, and CVWD's September 29, 2020 letter
confirming the same with respect to the final total project water demand of 958.63 AFY.
The forecast also accounts for water loss, consisting of water lost from storage tanks and pressurized
water delivery systems and adjustments to account for indoor water conservation that will result
from changes in state and federal water efficiency requirements for plumbing fixtures. Going forward,
codes and standards for fixtures and appliances will continue to reduce indoor water demand through
the replacement of existing fixtures and use of more efficient technologies in new development.
Total agricultural demand is projected to decline from 295,150 AFY in the 2016 baseline to 280,243
AFY in 2045. The forecast assumes that by 2045, 5,973 acres of agricultural land will be converted for
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2-22 February 2022
2.0 RESPONSES TO COMMENTS
urban land uses, and that 950 acres will be converted from idle to active agricultural use in the East
Valley.
Total demand from golf courses is projected to increase from 105,300 AFY in 2020 to 107,625 AFY by
2045 based on the assumption that three future golf courses, each approximately 150 acres in size,
will be developed during the planning period, based on a July 2020 CVWD list of approved Water
Supply Assessments.
Other demand is a category that includes water demands from fish farms and duck clubs, polo/turf
irrigation and water used to mitigate for losses from the Coachella Canal lining. A 5 -year average from
2015 to 2019 of 18,900 AFY, which excludes the temporary use of water to mitigate for the Coachella
Canal lining, was used as the baseline for projecting these other demands through 2045. Water
demand projections for fish farms, duck clubs, and polo/turf irrigation uses are not projected to
increase. Future demand projections include several new recreational lakes and surf parks, along with
water use by the Salton Sea Restoration North Shore pilot project. Specifically, these projections
include four projects CVWD has approved Water Supply Assessments for that include large water
features categorized as lakes, beaches, or surf parks. These four projects water features have a total
projected demand of 500 AFY. The proposed Coral Mountain Resort surf basin, which CVWD
estimates will have an annual water demand of approximately 120 AFY, as discussed above, is one of
the four projects that make up this 500 AFY of additional demand. In addition, the projection for this
category included 2,200 AFY of Coachella Canal water for the Salton Sea Restoration North Shore pilot
project to support wetland habitat. Overall water demand for this category is projected to increase
by 2,700 AFY from 18,893 AFY in 2020 to 21,593 AFY by 2045.
Total water demand projected for 2045 is approximately 644,610 AFY, which is 240,800 AFY lower
than the 885,400 AFY originally projected in the 2010 CVWMP Update. The updated 2045 total
demand reflects reductions in SCAG growth projections based on updates from local jurisdictions
provided to SCAG, along with conservation savings documented by the water providers over the last
decade that are projected to continue into the future.
Water Supply Projections
The Indio Subbasin Planning Area relies on a combination of local groundwater, Colorado River water,
SWP exchange water, surface water, and recycled water to meet water demands as described below.
Colorado River water is only allocated to CVWD, and not to the other water providers in the Basin.
Total available Colorado River deliveries are projected to be 464,000 AFY in 2045 based on CWVD's
entitlements to Colorado River water. Under the 2003 Quantification Settlement, CVWD currently
receives a base entitlement of 330,000 AFY plus an additional 123,000 AFY pursuant to negotiated
water transfer agreements with MWD and IID, of which CVWD received 394,000 AFY in 2020. (See
Indio SGMA Alternative Plan, Section 6.4.1. Importantly, the Indio Subbasin Water Management Plan
Update recognizes that Colorado River supplies face a number of challenges to long-term reliability
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2-23 February 2022
2.0 RESPONSES TO COMMENTS
including the extended Colorado River Basin drought and agreements that require water to be shared
during extended periods of drought, to protect endangered species and habitat protection, and as a
result of climate change.
Since 2007, State Water Project (SWP) deliveries have averaged only 45 percent of the projected
allocations (87,345 AFY out of the 194,100 AFY specified in the SWP Table A allocations). Accordingly,
only 45 percent of the Table A amounts were used in CVWD's water supply calculations for the 2020
— 2045 time period. However, various projects are being undertaken to increase the reliability of
water deliveries from the SWP, including projects by the State Department of Water Resources (DWR)
such as the Delta Conveyance Facility. CVWD and DWA are advancing funding over the next 2 years
to assist DWR with implementing these projects. In addition, MWD, DWR, CVWD and DWA have also
begun planning for the Lake Perris Seepage Recovery Project, which is anticipated to deliver 2,752
AFY to DWA and CVWD starting in 2023. CVWD and DWA have also entered into agreements with the
Sites Reservoir Authority for the purpose of obtaining 10,000 AFY and 6,500 AFY, respectively, from
the Sites Reservoir Project, which will capture stormwater flows from the Sacramento River and add
1.5 million acre-feet of additional storage for the SWP to increase reliability during drier periods.
In addition to SWP reliability improvements, there are eight wastewater treatment plants (WWTPs)
or water reclamation plants (WRPs) within the Plan Area, with a ninth in construction by MSWD.
CVWD and DWA currently deliver recycled water from three WRPs for irrigation of golf courses, large,
landscaped areas, and various other irrigation uses. Forecasted recycled water deliveries from the
three WRPs are anticipated to increase from 13,398 AFY in 2020 to 20,213 AFY in 2045 based on
additional projects currently being planned.
Modeling Results
The Indio Subbasin Water Management Plan Update analyzes several scenarios over the 50 -year
period required by SGMA to address potential future water supply conditions, changes in land use,
and implementation of water management projects including source substitution and new water
supply projects. Climate change conditions were considered in all of these scenarios.
Future climate change was simulated similar to the observed conditions over the last 25 years, a
period marked with recurring drought and below average rainfall. While all scenarios assume 45
percent reliability of SWP supplies, the climate change scenarios assume an additional 1.5 percent
reduction in SWP reliability by year 2045.
To account for the potential effects of future climate change, the projections assume CVWD will
contribute water to California's Lower Basin Drought Contingency Plan allotment for Colorado River
water. Under this plan, CVWD is obligated to contribute approximately 14,000 to 24,500 AFY, which
equals about 7 percent of California's total contribution, to prevent Lake Mead water levels reaching
critically low levels.
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2-24 February 2022
2.0 RESPONSES TO COMMENTS
The modeling of these scenarios shows that implementation of water management projects that are
already planned and CVWD's ongoing management actions can maintain the water balance in the
Indio Subbasin, even with the expected effects of future climate change in the Colorado River Basin
and on the SWP. Figure ES -6, reproduced below, shows the inflows to the basin in the upper portion
of this chart and outflows in the lower portion. As shown in the Figure, projected inflows are greater
than outflows for each of the five scenarios considered. For example, the baseline with climate change
scenario shows inflows to the basin of 379,459 AFY and outflows of 366,959 AFY, indicating outflows
will not exceed inflows.
These scenarios include 5 projection scenarios:
1. a baseline scenario, which is based on hydrologic conditions in the Whitewater River
watershed from 1970 to 2019;
2. a baseline scenario considering the effects of climate change (indicated by "CC");
3. a 5 year scenario reflecting planned and funded water supply projects and actions and the
effects of climate change;
4. a future scenario reflecting additional water supply projects and actions over the full 25 year
planning period and the effects of climate change; and
5. a scenario that considers the expansion of agriculture with the effects of climate change.
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2-25 February 2022
2.0 RESPONSES TO COMMENTS
500.000
400.000
3Oo.00
▪ 200.000
E
U 106000
m 9
▪ -toa0w
g ▪ -200.000
G
.300.060
-400.009
-500.009
Figure ES -6: Model Inflows and Outflows by Scenario
25 Year Average (2020-2045)
408 532
-369,305
379,459 374,975
-366,959
364,069
-347,816
355.274
-331827 -333,137
Baseline
Baseline -CC 5 year - CC
Future - CC Expanded Ag - CC
Thomas E levy GRF • AgriouIwe Return Flow • Pumping
• YVhltewater GRF • Ga Course Return Flow • Drar ns
■ Palm Desert GRF • Municipal R4lurn Flow ■ O ltaw to Salton Sea
EVRA Reuse • Natural Infiltration (leu dIversions) 1.1 EvapoYanspiretion
■ wastewater Subsutace Inflow
The projected change in groundwater storage in the basin for each of these scenarios is shown in the
graph below, which is Figure ES -8 in the Indio Subbasin Water Management Plan Update, as provided
by CVWD in its revised September 27, 2021 Errata document. In the Future Projects with Climate
Change scenario, decreased pumping and similar levels of inflow to the other climate change
scenarios result in an increase in groundwater storage of 1,394,000 AF at the end of the 50 -year
simulation. The Baseline with Climate Change is the only scenario that shows a negative change in
storage after the 50 -year simulation — approximately 542,000 AF is expected to be removed from
storage over the 50 -year period. All scenarios show a net increase in storage at the end of the 25 -year
planning horizon, followed by declining storage through 2069 for the Baseline with Climate Change
scenario only; net stable storage for the 5 -Year Plan with Climate Change projects scenario; and
increasing storage for the Future Projects with Climate Change and Expanded Agriculture with Climate
Change scenarios.
Coral Mountain Resort Final EIR
2-26 February 2022
2.0 RESPONSES TO COMMENTS
Cumulative Change in Storage Rate (Acre-Feet per Year)
3,090 000
Figure ES -8: Cumulative Change in Storage for Future Scenarios
Simulated 2020-2070 Cumulative Change in Storage
2,800,000 -
2,600,000 -
2,400,000 -
2,200,000 -
2,000,000
1,800,000 -
1,600,000 -
1,400,000
1,200, 000
1,000,000
800,000
600,000
400,000 -
200,000 -
0
-200,000 -
-400,000
-600,000
-800.000
-1,000,000
2020
2025 2030 2035 2040 2045 2050 2055 2060 2065 2070
t Baseline Climate Change Cumulative Change in Storage
t Five -Year Plan Climate Change Cumulative Change in Storage
—a.— Future Projects Climate Change Cumulative Change in Storage
— 0— Expanded Agriculture Climate Change Cumulative Change in Storage
Conclusion
Based on both the project -specific WSA/WSV and the Indio Subbasin Water Management Plan
Update, therefore, CVWD has correctly calculated for, and demonstrated that it can supply the water
demand generated by the proposed project, as well as all other existing and projected future
demands.
CVWD and the other GSAs responsible for management of groundwater in the Indio Subbasin are
managing the basin in full compliance with the SGMA. The recently completed Indio Subbasin Water
Management Plan Update considers the anticipated effects of climate change and all planned
groundwater supply and management projects and actions over the next 50 years. This update
demonstrates that the water balance will be maintained in the basin. Of note, the projections in this
update include four projects with water features such as surf parks with a total projected demand of
500 AFY and for which CVWD has approved WSAs, inclusive of the 120 AFY demand for the Wave
Basin in the Coral Mountain project.
Accordingly, this information supports the conclusions in the DEIR that the project (i) will not
substantially decrease groundwater supplies or interfere substantially with groundwater recharge
such that the project may impede sustainable groundwater management of the Indio Subbasin; and
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2-27 February 2022
2.0 RESPONSES TO COMMENTS
(ii) will have sufficient water supplies available to serve the project and reasonably foreseeable future
development during normal, dry, and multiple dry years, and therefore, will not have any significant
adverse effects relating to water use.
2.2.4 Noise
Comments were received related to the potential effects of the proposed project relating to noise
generated by project construction and operations, including questioning whether noise
measurements taken of the existing Wave Basin operations in Lemoore, California are appropriate to
analyze noise impacts at the project site, and questioning whether the proposed special events at the
Wave Basin would have significant noise impacts.
A Noise Impact Analysis ("Noise Study") prepared by Urban Crossroads, Inc. in March 2021, included
as Appendix K.1 in the Draft EIR, analyzed the potential for noise impacts from construction and use
of the project, including the proposed Wave Basin. As discussed in Section 4.11, Noise, of the Draft
EIR, these potential impacts are (1) generation of a substantial temporary or permanent increase in
ambient noise levels in excess of the standards established in the City's General Plan, noise ordinance,
or other applicable standards; and (2) generation of excessive ground -borne vibration or noise levels.
The noise related comments on the Draft EIR focused on the first of these potential impacts, so this
topical response will also focus on the project's potential to generate a substantial increase in noise
in violation of applicable standards.
As analyzed in the Draft EIR, the project will generate short-term construction noise and long-term
increases in traffic noise and operational noise, including from the proposed Wave Basin. The
development of any project on a vacant site increases noise levels. That increase, however, is not
significant if it is within established City standards. To constitute a significant impact, these noise
increases would need to exceed the City's General Plan or Municipal Code standards. The City
General Plan includes land use compatibility standards for new projects (see Table 4.11-1 in the Draft
EIR, at p. 4.11-8), as well as Policy N-1.2, which requires a noise study and appropriate mitigation for
projects along roadways where noise levels exceed 65 dBA CNEL. Section 9.100.210 of the City's
Municipal Code establishes a daytime exterior noise standard of 65 dBA CNEL near sensitive
receptors, including residential communities.
Based on these General Plan and Municipal Coode standards, the City adopted an exterior noise level
of 65 dBA CNEL as the applicable threshold of significance when analyzing noise for any development
project, including the project -specific noise study. (See Draft EIR at p. 4.11-9). As explained in detail
on pages 4.11-17 through 4.11-21, increases in noise caused by the project would also be considered
significant if existing noise levels increase substantially, which is defined to include increases of 1.5
dBA or more where the ambient noise level already exceeds 65 dBA, 3 dBA or more where ambient
noise levels are between 60 and 65 dBA, and increases of 5 dBA or more where ambient noise levels
are less than 60 dBA. This standard is consistent with guidance from both the Federal Interagency
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Committee on Noise (FICON) and the California Department of Health Services and is broadly used in
noise studies under CEQA. For construction noise, which is limited to daytime hours, the City has
established a significance threshold of 85 dBA Leq, consistent with the recommendations of the
National Institute for Occupational Health and Safety. (See Draft EIR at pp. 4.11-18 — 4.11-21).
As summarized on pages 4.11-49 and 4.11-50 of the Draft EIR, the noise study concluded that the
proposed project will not result in significant construction or operational noise increases, taking into
account the proposed configuration of the low density residential, tourist commercial, general
commercial, and open space uses as reflected in the proposed land use plan in the specific plan.
The Noise Study analyzed the potential effects of project -related construction activities and
operational activities. To determine the existing noise environment, hourly noise levels were
measured during typical weekday conditions over a 24-hour period at sensitive receptors (i.e.,
residential uses, schools, libraries, hospitals, and nursing homes) within the vicinity of the project site.
According to these noise measurements, average noise levels between the 7:00 a.m. and 10:00 p.m.
period range from a low of 43.8 dBA Laeq (A -weighted Leq) at the western end of Avenue 60, south
of an existing single-family residential home at 80800 Avenue 60 (Location 8), to a high of 62.5 dBA
Laeq, south of a single-family residential home at 57925 Barristo Circle (Location 2). Between the
hours of 10:00 p.m. and 7:00 a.m., average noise levels ranged from a low of 39.9 dBA Laeq at Location
8, to a high of 60.7 dBA Laeq at Location 2. 24-hour noise levels ranged from a low of 47.3 dBA CNEL
at Location 8 to a high of 67.6 dBA CNEL at Location 2. Please refer to Table 4, 24 -Hour Ambient Noise
Level Measurements, and Figure 4, Noise Monitoring Locations, in the Noise Study for descriptions
and illustrations of the various locations.
Construction activities associated with the project were determined to result in less than significant
impacts with the implementation of mitigation measures, provided in the Draft EIR as NOI-1 through
NOI-4. It was determined that the noise impacts associated with construction of the proposed project
are expected to create temporarily high noise levels at the nearby receiver locations. However, based
on the findings, onsite construction noise will not exceed the standard established by the National
Institute for Occupational Safety & Health (NIOSH) identified by the City in the Draft EIR as the
threshold of significance for noise impacts from construction activities. The highest onsite noise level
during construction is 83.2 dBA at receiver location P7, which is located within the project property,
and the highest offsite construction noise level is 76.5 dBA at receiver location R8, which is located
along the southern boundary of the project on 60th Avenue. Both are below the 85 dBA NIOSH
standard. In addition, these noise levels decrease by approximately 6 dBA at 100 feet and with every
doubling of distance thereafter. Although the project will not result in significant construction noise
impacts, the project will be required to implement Mitigation Measures NOI-1 through NOI-4, as
outlined in Section 4.11, Noise, to further reduce construction noise to the maximum extent feasible.
The Noise Study analyzed operational noise generated by the proposed project, including off-site and
on-site traffic noise generated by project -related increases in vehicular traffic, noise generated by the
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proposed special events, and noise generated by the Wave Basin. Measurements of existing noise
levels at various locations were conducted in proximity to the proposed project. The ten locations
where measurements were collected were chosen to represent noise sensitive areas, such as nearby
residential properties.
Offsite traffic noise levels on streets in the area, with the addition of traffic from the project and
projected increases in traffic volumes from development of other projects, will range from 60.5 to
73.9 dBA CNEL at these ten locations considered in the analysis. The project will generate a noise level
increase of less than 3.0 dBA CNEL in all study area roadway segments except for segment 27 (Avenue
60 west of Madison Street), which will experience and increase of up to 3.2 dBA CNEL, from the
current 57.3 dBA to a projected 60.5 dBA. Based on the thresholds of significance established in the
Draft EIR, the project -related noise level increases are considered less than significant under existing,
plus ambient growth, plus cumulative development in buildout year 2026 (EAC 2026) with project
conditions at the land uses adjacent to roadways conveying project traffic, because all but one
segment experience increases of less than 3.0 dBA CNEL, and because segment 27 does not currently
experience 65 dBA noise levels, and project traffic will not increase levels to 65 dBA. Therefore, offsite
traffic would result in less than significant impacts.
Noise generated by off-site traffic during the proposed special events was also analyzed in the Noise
Study. As stated throughout the Draft EIR, the project applicant anticipates the potential occurrence
of special events at the project site. The Noise Study anticipates that off-site roadway noise levels
during special event conditions will range from 60.5 to 73.9 dBA CNEL and will generate a noise level
increase of up to 3.2 dBA CNEL on the study area roadway segments. Based on the thresholds of
significance established in the Draft EIR, the project -related roadway noise level increases are
considered to be less than significant under the project with special events condition at the land uses
adjacent to roadways conveying project traffic because the project will not increase ambient noise
levels on any of the roadway segments by an amount that exceeds the applicable threshold. In fact,
the projected noise increases range from 0.0 to 1.0 dBA in 25 of the 27 locations and have a maximum
increase of 3.2 dBA on Avenue 60 west of Madison Street. See Table 4.11-8 of Section 4.11 in the
Draft EIR for thresholds utilized in the Noise Study, and Table 4.11-20 of Section 4.11 for the projected
noise levels with and without the project during special events.
In addition to construction noise and off-site traffic noise, the Draft EIR (and the Noise Study and
supplemental Noise Memo prepared by Urban Crossroads attached as Appendix K.1 and K.2 to the
DEIR) analyzed operational noise impacts generated by the proposed project. Operational activities
analyzed included activities associated with use of the Wave Basin, outdoor pool/spa activities,
outdoor activities, and activities at the neighborhood commercial center. Worst-case noise
environments were assumed to generate the most conservative value for analysis. However, these
noise level impacts will likely vary throughout the day and will be limited to the daytime and evening
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hours of 7:00 a.m. to 10:00 p.m. Per Mitigation Measure NOI-6, the operation of the Wave Basin will
conclude at 10:00 p.m.
In order to capture potential noise levels generated by the Wave Basin and associated machinery,
Urban Crossroads collected noise samples at eight different locations at the existing Kelly Slater Surf
Ranch in Lemoore, California. The Wave Basin proposed in the project will use the same technology
and equipment and, for this reason, noise measurements were collected at the Wave Basin in
Lemoore and used in the analysis of the noise levels that would be generated by the Wave Basin
included in the project. These measurements included ten wave events, measured at eight different
locations, over a period of 53 minutes. The reference noise levels indicate that during peak wave
events, the Wave Basin generates noise levels ranging from 62.6 dBA Leq at the end of the Wave
Basin, 73.8 dBA Leq in the lifeguard tower and 75.7 dBA Leq twelve feet from the cable roller system.
To describe the worst-case reference noise level conditions, the highest reference noise level
describing each peak wave noise event of 75.7 dBA Leq at a distance of 12 feet was used in the
analysis. The reference noise level measurements included all sources of noise associated with the
Wave Basin in Lemoore, including loudspeaker announcements, as well as noise generated from the
waves and associated machinery. In addition, further noise level measurements were taken at the
Lemoore facility in August 2021 to evaluate improvements to the Wave machine cable roller system,
and to ensure that the measurements were taken while the waves were being actively used by surfers
with the rescue jet ski in operation. These measurements showed a slight decrease in peak noise
levels from 75.7 dBA to 73.5 dBA at a location 12 feet from the noise source (see Appendix K.3 in this
Final EIR). This reference noise level likely overstates the expected noise levels from the Wave
Basin/wave machine activity at the project since it only reflects noise levels when a wave is being
generated, while noise levels will vary throughout the day, with quieter periods when waves are not
being generated. As shown in Tables 4.11-25 and 4.11-26 of the Draft EIR, the project's operational
noise levels will not exceed 65 dBA at any off-site locations, and will not significantly increase existing
noise levels at any off-site locations.
Concerns regarding the accuracy of comparing noise measurements of the Kelly Slater Surf Ranch in
Lemoore to the proposed project were introduced by the public during the project's scoping meeting
on March 30, 2021. For context, the area surrounding the Kelly Slater Surf Ranch in Lemoore is
characterized by agricultural fields, whereas the proposed project is located on the desert floor and
adjacent to Coral Mountain. The public expressed concerns that sound propagation and attenuation
would vary between the different land types. However, the only noise measurements taken at the
Lemoore facility were taken in the immediate vicinity of the noise source; measurements of noise at
distances comparable to the receptor locations analyzed in the Noise Study were not used to analyze
noise impacts. Rather, these noise levels at the source were input into the noise modelling software
used by Urban Crossroads. Specifically, the Urban Crossroads Noise Study utilized the CadnaA
(Computer Aided Noise Abatement) computer program. CadnaA is a three-dimensional noise model
that analyzes multiple types of noise sources using the spatially accurate project site plan,
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georeferenced Nearmap aerial imagery, topography, buildings, and barriers in its calculations to
predict outdoor noise levels at the selected receptor locations.
Following the completion of the Noise Study, Urban Crossroads provided a supplemental Noise
Memo, dated April 20, 2021 (included as Appendix K.2 in the Draft EIR), to address residents'
concerns regarding the difference between the topography in Lemoore and at the project site. The
Noise Memo states that agricultural fields and desert floors are considered soft surfaces for the
purposes of sound propagation.
On the specific issue of whether significant noise levels will be amplified by bouncing off Coral
Mountain, the noise expert explained that based on Federal Highway Administration studies and
guidance, if all noise striking a hard surface were reflected back to a given receiving point, the
maximum increase in noise would be limited to 3dBA. However, not all acoustical energy is reflected
back to the same point, and accordingly, FHWA measurements show that reflective noise increases
do not exceed 1-2 dBA, which is not perceptible to the human ear (see Urban Crossroads Memo dated
4/20/21, attached as Appendix K.2 to the DIER).
In addition, the worst-case reference noise level conditions were taken during peak wave noise events
at 12 feet, as stated above, whereas Coral Mountain is located approximately 650 feet from the Wave
Basin, separated by desert floor and vegetation that are considered soft surfaces that will absorb
sound. The reference noise level measurements themselves do not include any sound attenuation for
the agricultural fields. Therefore, although the proposed project is located on the desert floor and
adjacent to Coral Mountain, the noise measurements from the Lemoore site provide an accurate
comparison of noise levels to occur at the project site (page 4.11-46 of the Draft EIR).
The Noise Study, Noise Memo, and Draft EIR concluded that noise generated by the operation of the
proposed Wave Basin and associated machines, commercial uses, and outdoor activities would not
result in noise levels that exceed the significance thresholds or result in significant increases in noise
levels. Please refer to pages 4.11-44 to 4.11-49 in the Draft EIR for full analysis of the project
operational noise impacts.
2.2.5 Traffic
During the public review period, area residents expressed concerns with project -generated traffic,
specifically due to the proposed tourist commercial use (including hotel and Wave Basin) and during
the proposed special events. Traffic related to project activities (both construction and operational)
were thoroughly analyzed in the project -specific Traffic Impact Analysis (TIA) and Vehicles Miles
Traveled (VMT) Evaluation prepared by Urban Crossroads, Inc. (included as Appendix L.1 and L.2 in
the Draft EIR). Project -generated traffic is also discussed and analyzed in Section 4.13,
Transportation, of the Draft EIR and mitigation measures are identified to reduce impacts to less than
significant levels.
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The project -specific TIA was based upon an analysis of existing roadway conditions in the project
vicinity, a variety of traffic count sources (including peak hour counts collected by the consulting
traffic engineers), the General Plan Circulation Element, planned roadway improvements, and other
data and information. In addition to the existing traffic conditions, the TIA provides documentation
and analysis of trips generated by the project, distribution of the project trips to roadways outside
the project, and projected future traffic conditions. The TIA was prepared in accordance with the City
of La Quinta's Traffic Study Guidelines (Engineering Bulletin #06-13, dated October 13, 2017) and
Engineering Bulletin #10-01, dated August 9, 2010, the City General Plan, and a traffic study scope
reviewed and approved by City staff during the scoping process.
The project will be gated and private, with the exception of the neighborhood commercial project at
the northeast corner of Avenue 58 and Madison Street, so reasonable assumptions regarding trip
reductions due to internal interactions between these uses are included in the trip generation
calculations. As shown on Table 4-1 through 4-3 of the TIA, the total number of external trips were
adjusted for each land use based on its anticipated interactions with the other internal uses, and
those adjustments are shown on Tables 4-1 through 4-3. For example, of the 41 AM peak hour trips
anticipated to be generated by the resort hotel during Phase 1, 10 of those trips were assumed to be
internal to other areas within the project and 31 were assumed to leave the project site. (See Table
4-1 of TIA, on p. 41).
The Wave Basin facility will be utilized by hotel guests and project residents only, but outside trip
generation was also included for employee trips at the hotel, resort commercial, and Wave Basin.
Area residents and visitors from outside the project will use the commercial retail area located in the
northeast corner of the project, as will project residents and hotel guests. As explained above and
shown on Tables 4-1 through 4-3 of the TIA, the total internal/pass-by trip ends were appropriately
adjusted to ensure that no "double counting" occurs before assigning the project trips to the roadway
network.
As indicated in Table 4.13-13, in the Draft EIR, at project buildout, the site is anticipated to generate
a net total of 6,994 external trip -ends per day on a typical weekday with 447 external vehicles per
hour (VPH) during the weekday AM peak hour and 638 external VPH during the weekday PM peak
hour. Project trips were generated based on the rates published by the Institute of Transportation
Engineers (ITE) Trip Generation Manual, 10th Edition, 2017, with the exception of the Wave Basin,
which was estimated using the SANDAG trip generation estimates for a developed 12 -acre
recreational park because the ITE Manual did not have any applicable trip generation rates for this
unique recreational feature.
Under 2026 project build out conditions, nine study area intersections will operate at unacceptable
Levels of Service (LOS) without the development of the project. The addition of the project will result
in a total of ten impacted intersections under build out ("Phase 3") conditions. Therefore, the project
will reduce the LOS at the intersection of Madison St. and 58th Avenue from an acceptable PM level
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of service C, to an unacceptable level of F without any intersection improvements. Eight of these
impacted intersections are anticipated to require installation of a traffic signal in order to maintain
acceptable level of service (LOS). These intersection improvements are currently included in the City's
Capital Improvement Plan (CIP). As indicated in Table 4.13-23 in the Draft EIR, project and CIP
improvements will result in acceptable LOS for all intersections. For the other two intersections
physical improvements to the lane configurations are necessary to achieve acceptable LOS. With the
installation of these improvements, all ten impacted intersections will operate at LOS D or better at
project build out. Further, all study roadway segments analyzed are anticipated to operate at
acceptable volume -to -capacity ratio of 0.90 or less, and at buildout impacts will not be significant.
Special Events
The project proposes the potential occurrence of up to 4 multi -day special events per year involving
attendance of up to 2.500 guests per day. Events will be restricted to 4 days, with peak trips
anticipated between 10:00 a.m. and 2:00 p.m. on Saturday. (See Table 8-3 of TIA, which shows 274
peak hour trips and 2,084 daily trips generated by the 2,500 special event guests).
The Weekend Project Trip generation during a special event was based on 2,500 guests per day at the
Wave Basin and approximately 25 percent of the guests arriving or departing during the arrival and
departure peak hours. Discussions with City staff resulted in the selection of the Saturday peak hour
between 10:00 a.m. and 2:00 p.m. As indicated in the TIA, the proposed project is anticipated to
generate a net total of 8,932 trip -ends per day on Saturday during a special event with 906 vehicles
per hours (VPH) during the arrival peak hour and 844 VPH during the departure peak hour. For each
special event, a Temporary Use Permit (TUP) would be required.
The traffic analysis shows that nine of the study area intersections would operate at an unacceptable
LOS without improvements to those intersections (see Table 8-4 of TIA). However, with completion
of the intersection improvements required for Phase 3 of the project, all study are intersections will
operate at an acceptable LOS. Implementation of Mitigation Measures TRA -9 through TRA -14 will
reduce traffic impacts of special events to less than significant levels. If special events occur prior to
completion of all Phase 3 improvements, TRA -9 requires the applicant to provide a focused traffic
analysis with the Temporary Use Permit that identifies any improvements that are necessary to
maintain acceptable levels of service at study intersections during special events. If the analysis does
not demonstrate acceptable operations, the TUP will be denied.
TRA -10 requires a special event traffic and parking plan to be submitted with a TUP to ensure that
special events will not cause any significant traffic or parking impacts. If the analysis does not
demonstrate acceptable operations, the TUP will be denied. TRA -11 requires Traffic Management
Plans to be submitted to the City and Police Department for review and approval prior to special
events. TRA -12 through TRA -14 require traffic control, which typically includes special event flaggers,
law enforcement personnel, online or transmitted event information (suggested routes, parking, etc.)
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and portable changeable message signs (CMS) located at critical locations identified by the La Quinta
Police Department. TRA -12 through TRA -14 will be included in TUP applications and would be added
as conditions of approval for each occurrence. Therefore, the Draft EIR concluded that traffic impacts
associated with special events will be reduced to less than significant levels. Please consult pages
4.13-42 to 4.13-47 of the Draft EIR for full discussion and analysis.
Vehicle Miles Traveled (VMT)
The Urban Crossroads VMT Evaluation calculated project VMT using the most current version of the
Riverside County Transportation Analysis Model (RIVTAM). Adjustments in socioeconomic data (SED)
(i.e., employment) were made to a separate Traffic Analysis Zone (TAZ) within the RIVTAM model to
reflect the project's proposed population and employment uses.
The project is anticipated to generate approximately 1,698 project residents and 19,773 Home -Based
VMT for baseline (2020) conditions. This results in 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/Service Population. Because the project exceeds the City's VMT/Capita
threshold of 11.03, impacts would be considered potentially significant. However, the project
incorporates design features and attributes promoting trip reduction which reduce residential VMT
from 11.64 VMT/resident to 10.94 VMT/resident, including the placement of different land use types
near one another as well as elements of the project that enhance walkability and connectivity
between the mix of use types such as sidewalk coverage, building setbacks, street widths, pedestrian
crossings and the presence of street trees. Implementation of the project design features will reduce
potential impacts to below the City's established threshold for a significant VMT impact, and
therefore, the residential portion of the project would have a less than significant VMT impact. The
project Development Agreement and/or conditions of approval will ensure that the project design
features identified in the Draft EIR are enforceable by the City. Trip reduction project design features
are listed on pages 4.13-54 and 4.13-55 in the Draft EIR.
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. 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 referred to as "boundary method," and evaluates hotel
occupants, Wave Basin visitors and retail patrons. Using the boundary method, the Coachella Valley
Association of Government's (CVAG) area VMT with project employment is compared to without
project conditions to determine whether there is a significant impact. The CVAG subregion VMT/SP
without project is estimated at 21.56, whereas with the project employment, the CVAG subregion
VMT is estimated at 21.53. Therefore, it was determined that the project's effect on VMT (for non-
residential uses) is not significant because it results in a cumulative link -level boundary decrease
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under the plus project condition compared to the no project condition (see pages 4.13-55 and 4.13-
56 of the Draft EIR). Impacts were determined to be less than significant.
Overall, project related impacts associated with traffic during project construction, normal operation,
and during special events were determined to result in less than significant impacts with the
implementation of mitigation measures.
2.2.6 Length of Draft EIR
The length of the Draft EIR was a concern for some commenters. The State CEQA Guidelines provide
recommendations in order to guide CEQA practitioners when writing environmental documents, such
as EIRs or Negative Declarations. Section 15141 of the CEQA Guidelines, recommends EIRs to normally
be limited to 300 pages. This recommendation is not a mandate, and in this case, due to the project's
complexity, project history, the various project components, and environmental setting in which the
project site is located, the Coral Mountain Resort Draft EIR exceeded the recommended 300 pages.
The CEQA Guidelines recommendations are taken into consideration when writing the Draft EIR,
however, in order to provide a document that thoroughly disclosed all of the project components,
technical methodologies, analysis, discussion, and findings of each environmental topic, the
document exceeded 300 pages.
The EIR's exceedance of 300 pages does not invalidate the document and does provide any cause for
replacement or recirculation of the document.
2.2.7 Ability to Comprehend Draft EIR
The inability to comprehend the Draft EIR was also a concern amongst some area residents. Technical
reports were generated for the project in order to analyze project impacts to air quality, biological
resources, cultural resources, geology and soils, paleontological resources, greenhouse gas emissions,
hydrology, noise, and traffic. In order to appropriately analyze the environmental topics and
determine whether the project would result in significant impacts, there is a level of technicality and
understanding that is required by experts in these fields to provide reports that satisfy all
requirements under CEQA. It is the responsibility of the CEQA practitioner to translate this technical
data and covey the conclusions regarding the significance of potential impacts to the public, which is
set forth in the Draft EIR, and further explained where necessary in the response to comments
provided in this Final EIR. The Draft EIR is not overly technical and uses explanations of technical
concepts and terms wherever appropriate.
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2.3 Public Agency & Area Residents Comment Letters & Responses
Public Agencies
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Comment Letter No. 1: Airport Land Use Commission (ALUC)
Name: Paul Rull, ALUC Director
Date: June 22, 2021
Affiliation: Airport Land Use Commission
Address: 4080 Lemon Street, 14th Floor
Riverside CA, 92501
Comment 1-a:
This project is outside of the airport influence area, and therefore ALUC has no comments at this time.
If you have any questions, please feel free to contact me.
Response 1-a:
The City thanks the ALUC for participating in the review of the Draft EIR. Since the comment did not
raise any questions or concerns with the Draft EIR, no further response is warranted.
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Comment Letter No. 2: Airport Land Use Commission (ALUC)
Name: Daniel Zerda, Student Intern
Date: June 22, 2021
Affiliation: Airport Land Use Commission
Address: 4080 Lemon Street, 14th Floor
Riverside CA, 92501
Comment 2-a:
Thank you for the transmittal. Please note that the project is not located within an Airport Influence
area, and as a result, ALUC review will not be required at this time. Please let me know if you have
any questions.
Response 2-a:
The City thanks the ALUC for participating in the review of the Draft EIR. Since the comment did not
raise any questions or concerns with the Draft EIR, no further response is warranted.
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Comment Letter No. 3: Cal Fire
Name: Kohl Hetrick, Fire Safety Specialist/Office of the Fire Marshall
Date: June 28, 2021
Affiliation: Cal Fire/Riverside County Fire Department
Address: 78495 Calle Tampico,
La Quinta CA, 92253
Comment 3-a:
Yes, I should be routed for these reviews and will ensure that they are sent to the appropriate Fire
Strategic Planning Representative in our Riverside Office.
Which case in Trakit is being utilized for documenting this review?
Response 3-a:
The City thanks Cal Fire for participating in the review of the Draft EIR.
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Comment Letter No. 4: Southern California Association of Governments (SCAG)
Name: Annaleigh Ekman, Assistant Regional Planner
Date: June 29, 2021
Affiliation: SCAG Intergovernmental Review (IGR) Program
Address: 900 Wilshire Boulevard, Suite 1700
Los Angeles, CA 90017
Comment 4-a:
Thank you for sending this NOA for the Coral Mountain Resort DEIR. I have a couple of follow-up
questions related to the incorporation of SCAG's comments on the NOP (starting page 66 in Appendix
A) and I'm wondering if we can chat over the phone in the coming weeks. I'm out of the office next
week, but my schedule is open this Friday, July 2nd and in the morning and afternoon on Tuesday, July
13th. Let me know if any of these times work for you.
Response 4-a:
The City arranged a phone call with Ms. Ekman on July 13, 2021 to discuss the follow-up questions
mentioned in Comment 4-a. Ms. Ekman wanted to confirm that SCAG's letter was received during the
NOP comment period. The City confirmed that the letter was received. Ms. Ekman also asked that
future EIR projects include a Regional Transportation Plan/Sustainable Communities Strategy
(RTP/SCS) policy analysis. The City thanks SCAG for participating in the public review period and it has
been noted to include the RTP/SCS policy analysis in future EIR projects. In addition, an analysis
confirming the project's consistency with the RTP/SCS policies has been added to the EIR and included
in Chapter 3.0, Revisions to the Draft EIR, in this Final EIR.
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Comment Letter No. 5: Cal Fire
Name: Kohl Hetrick, Fire Safety Specialist/Office of the Fire Marshall
Date: June 30, 2021
Affiliation: Cal Fire/Riverside County Fire Department
Address: 78495 Calle Tampico
La Quinta CA, 92253
Comment 5-a:
The Draft Environment Impact Report for the Coral Mountain Resort (The Wave Development, LLC) is
now available for review. The documents may be accessed at the following link:
haps://www.laquintaca.gov/ourcity/city-departments/design-and-development/planning-
division/the-wave-at-coral-mountain
This Draft EIR is available for a 45 -day public review period beginning on June 22, 2021, and ending
on August 6, 2021.
To provide comments in response to this notice (please include "Coral Mountain Resort DEIR" in the
subject line in writing, by August 6, 2021, to: Nicole Sauviat Criste, Consulting Planner, City of La
Quinta, 78-495 Calle Tampico, La Quinta, CA 92253, or consultingplanner@laquintaca.gov. Please
include your name, address, and other contact information in your response.
Please let me know if you have any questions.
Response 5-a:
The City thanks Cal Fire and the Strategic Planning Team for participating in the review of the Draft
EIR.
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Comment Letter No. 6: Riverside County Flood Control & Water Conservation District
Name: Deborah De Chambeau, Engineering Project Manager
Date: August 3, 2021
Affiliation: Riverside County Flood Control and Water Conservation District (RCFC)
Address: 1995 Market Street
Riverside, CA 92501
Comment 6-a:
The Riverside County Flood Control and Water Conservation District (District) does not normally
recommend conditions for land divisions or other land use cases in incorporated cities. The District
also does not plan check City land use cases or provide State Division of Real Estate letters or other
flood hazard reports for such cases. District comments/recommendations for such cases are normally
limited to items of specific interest to the District including District Master Drainage Plan facilities,
other regional flood control and drainage facilities which could be considered a logical component or
extension of a master plan system, and District Area Drainage Plan fees (development mitigation
fees). In addition, information of a general nature is provided.
Response 6-a:
The City thanks the District for participating in the review of the Draft EIR, and acknowledges the
District's role in the CEQA process.
Comment 6-b:
The District's review is based on the above -referenced project transmittal, received June 23, 2021.
The District has not reviewed the proposed project in detail, and the following comments do not in
any way constitute or imply District approval or endorsement of the proposed project with respect
to flood hazard, public health and safety, or any other such issue:
El This project would not be impacted by the District Master Drainage Plan facilities, nor are other
facilities of regional interest proposed.
❑ This project involves District proposed Master Drainage Plan facilities, namely, . The District
will accept ownership of such facilities on written request of the City. Facilities must be
constructed to District standards, and District plan check and inspection will be required for
District acceptance. Plan check, inspection, and administrative fees will be required.
LI An encroachment permit shall be obtained for any construction related activities occurring within
District right of way or facilities, namely, . For further information, contact the
District's Encroachment Permit section at 951.955.1266.
LI The Districts previous comments are still valid (see attached letter dated 03/09/21).
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Response 6-b:
Comment noted. The District attached its letter dated March 9, 2021 in response to the Notice of
Preparation for the Coral Mountain Resort EIR. The City acknowledges that it received the District's
March 9 letter (please see Appendix A of the Draft EIR), and that the District's comments in that letter
were considered in the research and documentation undertaken to complete the Draft EIR.
Comment 6-c:
GENERAL INFORMATION
This project may require a National Pollutant Discharge Elimination System (NPDES) permit from the
State Water Resources Control Board. Clearance for grading, recordation, or other final approval
should not be given until the City has determined that the project has been granted a permit or is
shown to be exempt.
If this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then
the City should require the applicant to provide all studies, calculations, plans, and other information
required to meet FEMA requirements, and should further require that the applicant obtain a
Conditional Letter of Map Revision (CLOMR) prior to grading, recordation, or other final approval of
the project and a Letter of Map Revision (LOMR) prior to occupancy.
If a natural watercourse or mapped floodplain is impacted by this project, the City should require the
applicant to obtain a Section 1602 Agreement from the California Department of Fish and Wildlife
and a Clean Water Act Section 404 Permit from the U.S. Army Corps of Engineers, or written
correspondence from these agencies indicating the project is exempt from these requirements. A
Clean Water Act Section 401 Water Quality Certification may be required from the local California
Regional Water Quality Control Board prior to issuance of the Corps 404 permit.
Response 6-c:
Comments noted. The City will require compliance with all applicable federal and state permitting
requirements as noted above.
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Comment Letter No. 7: Imperial Irrigation District
Name: Donald Vargas, Compliance Administrator 11
Date: August 4, 2021
Affiliation: Imperial Irrigation District (IID)
Address: P.O. Box 937
Imperial, CA 92253
Comment 7-a:
On June 28, 2021, the Imperial Irrigation District received from the City of La Quinta, the Notice of
Availability of a Draft Environmental Impact Report for the Coral Mountain Resort project. The project
proposes to develop a 386 -acre site with a mix of uses including up to 600 dwelling units of varying
product types, a resort facility with up to 150 rooms, 57,000 sq. ft. of tourist commercial uses, a 16.62 -
acre artificial wave basin for recreational purposes, 60,000 sq. ft. of neighborhood commercial uses
and 23.6 acres of open space recreational uses. The project includes the installation of an off-site
transformer bank at an existing IID substation (Ave. 58 Substation) as part of the proposed upgrades.
The 386 -acre site is generally bounded by Avenue 58 to the north; Madison Street to the east; the
extension of Avenue 60 to the south; and Coral Mountain to the west in La Quinta, CA.
The IID has reviewed the project information and found that the comments provided in their letter
dated March 18, 2021 (see attached letter) continue to apply.
Should you have any questions, please do not hesitate to contact me at (760) 482-3609 or at
dvargas@iid.com. Thank you for the opportunity to comment on this matter.
Response 7-a:
The City thanks IID for participating in the review of the Draft EIR.
Comment 7-b:
This comment is the March 18, 2021 letter submitted by IID during the NOP public review period. In
this letter, IID provided comments related to project electricity infrastructure and usage.
Response 7-b:
The City acknowledges that it received the District's March 18 letter (please see Appendix A of the
Draft EIR), and that the District's comments in that letter were considered in the research and
documentation undertaken to complete the Draft EIR.
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Comment Letter No. 8: CactusToCloud
Name: Sendy Barrows
Date: August 6, 2021
Affiliation: CactusToCloud
Address: www.CactusToCloud.org
Comment 8-a:
CactusToCloud values the opportunity to submit comments for the project above referenced, and we
respectfully request you please share our comments with the La Quinta City Council. CactusToCloud
is a group of desert advocates collaborating on community science and environmental education
projects in the Coachella Valley, and our goal is to celebrate and protect our desert home. We
represent diverse backgrounds and life experiences, and we are all UCR-Palm Desert California
Naturalists and Climate Stewards. As it happens, we are also all homeowners in the City of La Quinta.
As concerned La Quinta residents, and given our training and time spent in our community, we
consider it imperative that we, CactusToCloud, oppose this project, and we ask that the DEIR be
revised to address the concerns contained in this letter, and other letters of concerned residents and
conservation organizations.
Response 8-a:
The City thanks CactusToClouds for participating in the review of the Draft EIR. The commenter's
opposition to the project is noted. The commenter's concerns are addressed in the comments below,
and responses are included as Response 8-b through 8-d.
Comment 8-b:
This project threatens to negatively impact the existing cultural, ecological, and recreational features
in this area. Coral Mountain itself is a culturally and historically rich space, where Native American
petroglyphs, intact honey mesquite hummocks, and the ancient Lake Cahuilla Shoreline are visible
and accessible to our community. We are concerned irresponsible development of this area would
damage these irreplaceable assets in our beautiful city, and that access to public lands will be limited.
Response 8-b:
A project -specific Cultural Report was conducted for the project site in order to provide the City with
the necessary information and analysis to determine whether the proposed project would cause
substantial adverse changes to any "historical resources," as defined by CEQA, that may exist in or
around the project area. The Cultural Report is provided in Appendix E of the Draft EIR, and
summarized in Section 4.4 of the Draft EIR. As described in these documents, existing petroglyphs are
known to occur adjacent to the site, at the base of Coral Mountain. As disclosed in the Draft EIR, at
page 4.4-14 — 4-15 and 4.14-11— 4.14-14, impacts to these historic features would be significant. As
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a result, the Drat EIR includes Mitigation Measure CUL -2, CUL -3, TCR -4, TCR -5, and TCR -6, which
assure that these resources will be avoided and protected in situ.
In addition, the project applicant has agreed to provide a trail linkage across the open space in the
southwestern portion of the site, in cooperation with the Desert Recreation District, which will also
be located and fenced to protect the tribal cultural resources (rock art panels and bedrock milling
features) located at the base of Coral Mountain. Please see pages 4.14-11— 4.14-12, and Mitigation
Measures TCR -4 and TCR -5, which require both avoidance of this resource and a Rock Art
Management Plan that is subject to review and approval by the ACBCI Tribal Historic Preservation
Office. Therefore, the petroglyphs identified by the commenter have been protected by required
mitigation and impacts to these cultural resources will be less than significant, as identified in the
Draft EIR.
A project -specific Biological Report was also conducted for the project site in order to determine the
existence or potential occurrence of special-interest plant and animal species within the study area
and in the project vicinity. The Biology Report is provided as Appendix D.1 in the Draft EIR, and
summarized in Section 4.3. As explained on page 4.3-21, the removal of the mesquite hummock on
the project site does not conflict with any local plan or policy and is not a significant effect.
With respect to the ancient Lake Cahuilla shoreline that is visible along a portion of Coral Mountain,
no development is proposed or allowed on any portion of Coral Mountain. As explained in the Topical
Response on Biological Resources in Section 2.2.2, a sheep barrier will be installed on the project site
that will separate the project development from Coral Mountain itself and the surrounding BLM open
space. In addition, as described in Response No. 13-j below, the project is cooperating with the Desert
Recreation District in providing a public trail connection through the southwestern portion of the
project site, near the base of Coral Mountain, that will be on the project side of the sheep barrier.
The ancient shoreline will remain visible to the public from this location.
Comment 8-c:
It is common knowledge that we are in the middle of one of the worst droughts in the history of our
state. The use of our ever -diminishing water resources to fill and maintain a 20 -acre basin would be
short-sighted and does not consider reduced water availability during an unprecedented drought, or
uncertain future conditions due to a changing climate. We fear the DEIR has not properly addressed
this, and if this project is approved our community risks water shortages and similar water restrictions
to those now in effect in other parts of our state. California's water board recently unanimously
approved emergency regulations to temporarily stop thousands of landowners, residents and farmers
alike, from using water from Sacramento — San Joaquin Delta watershed. Consumers are now living
with a 55 gallon per day per person per day allowance, and face penalties up to $1000 per day, plus
$2500 per acre-foot, for illegally diverting water. Only through responsible use of water, both
imported and from our underground aquifer, can we avoid similar restriction in La Quinta.
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Response 8-c:
Please see the Topical Response, Water Resources, in Section 2.2.3 relating to the availability of
water. A project -specific Water Supply Assessment/Water Supply Verification (WSA/WSV) was
completed for the proposed project and uses. Per the WSA/WSV, the proposed project is expected
to consume approximately 958.63 -acre feet per year (AFY) based on the residential indoor demand,
non-residential indoor demand, and outdoor demands of the project at buildout.
Additionally, the project is required to implement measures to conserve water as required by CVWD.
Water conservation methods implemented by the project site include the installation and
maintenance of efficient and drip irrigation systems for project landscape, the use of native plant
materials and other drought tolerant plants, and the use of low -flush toilets and water -conserving
showerheads and faucets. These methods will reduce indoor and outdoor water consumption by the
project and the land uses that consume the bulk of the project's calculated water demand. The project
is also subject to all existing and future water use restrictions imposed by the California State Water
Resources Control Board or CVWD.
Comment 8-d:
While we oppose this specific project as presented, we support the responsible development of this
site in general. Indeed, smart development around Coral Mountain has the potential to fulfill
important community needs such as affordable housing, equitable access to public lands, and climate
resilience planning (as required of city governments by SB 379). Any development should incorporate
resilience best practices, such as community input and consideration of environmental justice,
sustainable water use, native plant landscaping, and outdoor recreational access to Coral Mountain,
Boo Hoff Trail, and the Santa Rosa Wilderness.
Response 8-d:
Please see Response 8-c.
The project site will remain private property throughout the development and operation of the site.
However, a public trail associated with the proposed Coral Mountain Interpretive Center trail
designated by the Desert Recreation District Master Plan and future Coral Mountain Interpretive
Center has been incorporated into project plans, as described on page 4.13-4 of the Draft EIR, and is
documented in a letter agreement between the developer, CM Wave Development, LLC, and the
Desert Recreation District, dated July 29, 2021, which is attached to this Final EIR as Appendix P.
Accommodations for this trail shall be located along the approximate toe of Coral Mountain, within
the designated conservation area at the southwestern edge of the property and on the project side
of the proposed sheep barrier to avoid inviting threats to Peninsular bighorn sheep onto Coral
Mountain. Assurance for public access is also provided in Mitigation Measure TRA -15 in the Draft EIR.
Public access to the Boo Hoff Trail and the Santa Rosa Wilderness will not be impacted by the
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proposed project, as neither the Boo Hoff Trail nor the Wilderness area are on or adjacent to the
project site, which is private property.
The commenter's position on resilience best practices, such as community input and consideration of
environmental justice is noted. Community input has been sought and obtained throughout the
planning process, including the public comment period provided for the Notice of Preparation, the
public scoping meeting held for this EIR on March 30, 2021, circulation of the Draft EIR for public
comment and the joint City Council/Planning Commission study session held on September 28, 2021.
Environmental justice is a policy consideration but not a topic under CEQA.
Comment 8-e:
Instead of a surf park which is out of character with our desert, a development that not only preserves
but enhances the natural and cultural heritage of our City would be an asset to the community. The
CactusToCloud team is ready and interested in working with the City and developers to assist in the
implementation of these features, and working together to build a resilient and inclusive community
for people and wild plants and animals to thrive in the Coachella Valley.
Response 8-e:
The City of La Quinta thanks the CactusToCloud organization for participating in the EIR process. The
project is proposed by private property owners, and the City will consider the proposal based on the
goals and policies of the General Plan, and the information detailed in the EIR.
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Comment Letter No. 9: Cal Fire
Name: Adria Reinertson, Deputy Fire Marshal
Date: August 6, 2021
Affiliation: Cal Fire — Riverside Unit
Address: 2300 Market Street Suite #150
Riverside, CA 92501
Comment 9-a:
The Riverside County Fire Department Strategic Planning Division has reviewed the Draft
Environmental Impact Report for the Coral Mountain Resort.
Response 9-a:
The City thanks Cal Fire for participating in the review of the Draft EIR.
Comment 9-b:
Section 3.5.3 Project Components makes mention of the potential of up to four special events per
year with no more than 2,500 guests at each event. We are requesting further information on these
events as well as clarification on the daily operation of the Wave in respect to anticipated daily
attendance, hours of operation, whether the venue is open to the public, etc. Clarification of these
items will assist the Riverside County Fire Department in determining the anticipated need for service
and if additional mitigations will be needed to provide service to the proposed development.
Thank you for the opportunity to review the Draft EIR and comment. Should you have any questions
or comments, I can be reached at (951) 955-5272 or via email at adria.reinertson@fire.ca.gov.
Response 9-b:
The Draft EIR provides extensive descriptions regarding special events, including within the Project
Description in Chapter 3.0, Sections 4.11, Noise, and 4.13, Transportation. As stated in the Draft EIR,
the project will be private, and the Wave Basin will be open to only residents and their guests, and
hotel guests (see, e.g., page 3-8). As stated on page 4.1-73, the Wave Basin will be operated from 7
am to 10 pm daily. Additional information regarding the special events provided in the EIR: Special
events will have a maximum of 2,500 people in attendance and will require issuance of a temporary
use permit from the City to ensure that the events will not have any significant traffic or safety
impacts. Further details on special events have not been developed at this time and will be
determined in connection with the temporary use permit process as required under the LQMC.
A thorough analysis of the impacts to fire services is provided in Section 4.12 of the Draft EIR, under
Public Services. As described in that section The project would be required to implement all applicable
fire safety requirements, to include installation of fire hydrants and sprinkler systems. Moreover, the
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project would be required to pay the City's Development Impact Fees (DIF) in place at the time of
construction. The current DIF for detached single-family residential is $9,380, which the City has
documented is adequate to mitigate any significant impacts to public services from new
development. Payment of these fees goes towards the funding of public facilities including but not
limited to fire stations, park and recreation facilities, major thoroughfares and bridges and traffic
signalization, public safety facilities and other public buildings. The development of the future fire
station, whose location is being established by the Riverside County Fire Department and the City,
will be funded via the fire facilities component of the City's adopted DIF and the County's
development impact fees. The City's DIF ensures that the project will participate in the funding of the
fire station in proportion to its impact on fire facilities. As a result, and as correctly determined in the
Draft EIR, impacts to the Fire Department will be less than significant.
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Comment Letter No. 10: Coachella Valley Water District (CVWD)
Name: William Patterson, Environmental Supervisor
Date: August 6, 2021
Affiliation: Coachella Valley Water District (CVWD)
Address: 2300 Market Street Suite #150
Riverside, CA 92501
Comment 10-a:
Please also include the following comment:
Pages 88, 89 (Section 3.8), 609, and 617 (Section 4.15) of the pdf refer to and/or depict the proposed
water infrastructure through the project. CVWD will require an offsite pipeline in Ave. 60 in
accordance with the existing Agreement. In addition, there are changes to other portions of the onsite
pipeline that will be needed. We suggest the project proponent meet with CVWD to discuss these
requirements.
Response 10-a:
The City thanks CVWD for participating in the review of the Draft EIR. The District's requirement for
an offsite pipeline in Avenue 60, from Madison Street westerly to the southeast corner of the project,
is noted and has been added to page 3-29 of the EIR (see Chapter 3.0 of this Final EIR). This
clarification will not have any new or more significant environmental effects than disclosed in the
Draft EIR because this improvement will be installed in the existing, disturbed portion of the Avenue
60 right-of-way. In addition, this pipeline in Avenue 60 is a requirement of an existing service
agreement made as part of previous project approvals for the site, including the City of La Quinta
approval of the Andalusia at Coral Mountain Specific Plan 03-067, which was also the subject of
approved Environmental Assessment No. 2003-483 (See Draft EIR at p. 3-6). This condition will be
satisfied in accordance with the existing agreement as it may be modified per the West Tract -Partial
Assignment and Assumption of Domestic Water Agmt-Inst No. 2019-0158543 recorded 5-8-19.
Changes to onsite water systems will be reviewed and approved by CVWD throughout the
development process, as entitlements are proposed for various portions of the project. The City will
continue to provide CVWD with development plans as part of the entitlement review process.
Comment 10-b:
CVWD would like to submit the following comments in response to the Public review period for the
Coral Mountain Resort Draft Environmental Impact Report. The Coachella Valley Water district
(CVWD) received notice that the 45 -day public review period would begin on June 22, 2021 and end
on August 6, 2021. CVWD has the following comments for your consideration in the document.
Response 10-b:
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The City thanks CVWD for participating in the review of the Draft EIR. CVWD's comments are
addressed in Comment 10-c through 10-e.
Comment 10-c
Location: Pages 3-5; Comment: Draft EIR "CVWD Levees" be changed to "USBR Levees".
Response 10-c:
The EIR has been revised to reflect CVWD's comment. Please see Chapter 3.0, page 3-1.
Comment 10-d:
Project is adjacent to USBR lands managed by CVWD; any impacts to these lands will require CVWD's
review.
Response 10-d:
Comment is noted. The project proponent shall engage CVWD if USBR lands managed by CVWD are
proposed to be impacted.
Comment 10-e:
The project's footprint is within CVWD's irrigation lateral system. Project will require review by CVWD.
Response 10-e:
Comment is noted. As described on page 4.15-17 of the Draft EIR, non -potable water will be used for
irrigation and further review by CVWD will be required. As noted in this comment, and as required
of all projects which affect CVWD facilities, any modifications to CVWD's irrigation lateral system will
require CVWD review.
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Comment Letter No. 11: Center for Biological Diversity
Name: Ross Middlemiss, Staff Attorney
Date: August 6, 2021
Affiliation: Center for Biological Diversity
Address: 660 S. Figeroa Street, Suite 1000
Los Angeles, CA 90017
Comment 11-a:
These comments are submitted on behalf of the Center for Biological Diversity (the "Center")
regarding the Coral Mountain Resort Draft Environmental Impact Report (DEIR) drafted and released
by the City of La Quinta (the "City"). The Center has reviewed the Coral Mountain Resort (the
"Project") DEIR closely and is concerned that the DEIR fails to adequately assess the project's impacts
on biological resources and water supply, among other impacts. The Center urges the City to address
deficiencies identified in this letter and recirculate a new DEIR for public comment prior to preparing
a final EIR for the project.
The Center is a non-profit, public interest environmental organization dedicated to the protection of
native species and their habitats through science, policy, and environmental law. The Center has over
1.7 million members and online activists throughout California and the United States. The Center has
worked for many years to protect imperiled plants and wildlife, open space, air and water quality,
and overall quality of life for people in and around La Quinta.
CEQA and the CEQA Guidelines impose numerous requirements on public agencies proposing to
approve or carry out projects. Among other things, CEQA mandates that significant environmental
effects be avoided or substantially lessened where feasible. (Pub. Res. Code § 21002; CEQA Guidelines
§§ 15002(a)(3), 15021(a)(2), 15126(d).) Unfortunately, the DEIR for the Project fails to comply with
CEQA and the CEQA Guidelines in numerous respects.
Response 11-a:
The City thanks the Center for Biological Diversity for participating in the review of the Draft EIR and
providing a description of its organization, mission, and citations of several sections of the CEQA
Guidelines. The organization's concerns are listed in the comments below, and responses are included
as Response 11-b through 11-i.
As demonstrated in the responses below, recirculation of the Draft EIR is not required or appropriate
here because no significant new information has been added to the Draft EIR in the comment letter
or responses that would deprive the public of a meaningful opportunity to comment upon a
substantial adverse environmental effect or feasible way to mitigate or avoid such an effect, which is
the standard for recirculation under CEQA Guidelines Section 15088.5. Examples of such "significant
new information" would include a new or substantially more severe adverse environmental effect
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than previously disclosed in the Draft EIR, which is not the case here, where additional information is
provided in response to the comments to clarify or amplify the information provided in the Draft EIR
with further detail or discussion.
Comment 11-b:
1. Biological Issues
While we recognize that the project area is within the "take" boundary of the Coachella Valley
Multiple Species Habitat Conservation Plan, concerns still remain about the absence of mechanisms
to prevent Peninsular bighorn sheep from being attracted to the wave pool feature and non-native
plantings. We also have concerns about the night lighting as described below.
Response 11-b:
Please see the Topical Response on Biological Resources at Section 2.2.2, above, for a discussion of
the proposed sheep barrier along the western project boundaries and the project's avoidance of
plantings that could be harmful to Peninsular bighorn sheep (PBS). Also, as noted on Page 4.3-15 of
the DEIR, the site does not provide suitable habitat for PBS. The proposed project does not
incorporate any proposed land uses on the Coral Mountain topographic feature, the majority of which
occurs on land holdings owned by the United States Department of the Interior, managed by the
Bureaus of Land Management and Reclamation. Active land uses are separated from the mountain
slopes by a proposed open space area that will include a combination of conservation and low -impact
recreation activities (DEIR Exhibit 3.5). As described in the project description (DEIR Page 3-11) the
project will utilize a combination of fences and walls with gated access points. The Specific Plan
provides a thorough list of compatible trees, shrubs, and ground covers that are consistent with
CVMSHCP requirements and would be subject to Site Development Permit Review and Final
Landscaping Plan permits. The commenter's concerns are addressed in greater detail in Responses
11-c and 11-d, and have been comprehensively addressed in consultation with the California
Department of Fish and Wildlife. With respect to night lighting, the light orientation and visor cut-
offs ensure that there is no light overspill onto Coral Mountain. This is required by Mitigation
Measure BIO -4. BIO -4 which requires that a supplemental light study be performed to collect
nighttime lighting measurements and confirm that no light trespass onto Coral Mountain is occurring.
The supplemental light study must be completed prior to issuance of any permit for occupancy or use
of the Wave Basin. Also see the Topical Response on Light and Glare at Section 2.2.1, above.
Comment 11-c:
A. Peninsular bighorn sheep
The Center has worked for years trying to protect and recover the Peninsular bighorn sheep, a
federally endangered species protected under the federal Endangered Species Act and state -listed
and fully protected species under State law. Nearby projects in La Quinta have been responsible for
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numerous Peninsular bighorn sheep deaths (Hurt 2016). At the city -owned SilverRock golf course,
fences have been erected to preclude bighorn from coming onto the golf course and associated
facilities, helping to keep bighorn out of harm's way (KESQ News Team 2019). The U.S. Fish and
Wildlife Service's Peninsular Bighorn Sheep Recovery Plan (2000) recommends the following
measures be implemented to help in the recovery of Peninsular bighorn, which is particularly
important in the La Quinta area where mortalities of bighorn continue.
1.2.1.1 Construct fences to exclude bighorn sheep from urban areas where they have begun or
may begin using urban sources of food and water. Fences serve several functions including: (1)
separating bighorn sheep from potential threats of urbanization (e.g., toxic plants, parasites,
accidents, vector-borne diseases, traffic, herbicides, pesticides, behavioral habituation), (2)
controlling human and pet access to remaining bighorn sheep habitat, (3) preventing bighorn sheep
from becoming habituated to and dependent upon artificial sources of food and water, and (4)
modifying habituated behaviors and redirection into remaining native habitat. In the northern Santa
Rosa Mountains, ongoing coordination with cities and landowners on a regional fencing strategy will
be critical to the long-term health and maintenance of this ewe group... cooperation by residential
landowners will be critical to the success of excluding the northern Santa Rosa Mountains ewe group
from urban habitats. Along the remainder of the urban interface, where sheep have not yet shown
indications of habituation to human habitats, future behavioral habituation also may occur. Although
fencing may be viewed as a last resort to other potential forms of aversive conditioning, prudent
planning dictates that mitigation be required to offset the likelihood of future adverse effects
(behavioral habituation and increased mortality rates) when new projects are approved along the
urban interface. Though actual fence construction could be contingent upon future use by sheep and
the ineffectiveness of other potential deterrents, the wherewithal, responsibilities, and easements for
fences should be determined and secured at the time of project approval. (emphasis added) Fences
should be 2.4 meters (8 feet) high, or functionally equivalent, and should not contain gaps in which
bighorn sheep can be entangled. Gaps should be 11 centimeters (4.3 inches) or less. This fence design
should only be used at the urban interface."
1.2.1.2 Avoid non-native vegetation along unfenced habitat interfaces where it may attract or
concentrate bighorn sheep. Along fenced sections of the urban interface, ornamental and toxic plants
should not extend over or through fences where they may be accessible to browsing bighorn sheep.
1.2.1.4 Prohibit the use of any known toxic plants where they may be accessible to bighorn
sheep or potentially invade bighorn sheep habitat. A list of known toxic plants should be provided to
all developers, landscapers, and homeowners.
1.2.1.5 Discourage the use of plants known to invade and degrade bighorn sheep habitat (e.g.,
tamarisk, fountain grass).
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1.2.1.6 Prohibit intentional enticement of bighorn sheep onto private property. This item
includes, but is not limited to, vegetation, mineral licks, or unfenced swimming pools, ponds, or
fountains upon which bighorn sheep may become dependent for water.
1.2.1.9 Prohibit the construction of water bodies in developed areas adjoining sheep habitat
that may promote the breeding of midges (Culicoides sp.) and monitor/control vectors in existing
problematic ponds. Water features should be designed to eliminate blue -tongue and other vector-
borne diseases by providing deeper water (over 0.9 meters [3 feet]), steeper slopes (greater than 30
degrees), and if possible, rapidly fluctuating water levels (see Mullens 1989, Mullens and Rodriquez
1990). Landowners and managers should coordinate with local mosquito and vector control districts
to ensure management of existing water bodies that harbor vector species.
1.2.1.10 Discourage the artificial feeding of coyotes because of the potential for increasing
predator abundance and consequent predation on bighorn sheep.
USFWS at 80-83.
We request that these recommendations be incorporated into the conditions for approval for the
proposed project.
Response 11-c:
Please see the Biological Resources Topical Response in Section 2.2.2, above, and Responses 13-d
through 13-m. In response to concerns relative to impacts to PBS in the area from several
commenters, a supplemental Biological Assessment Memorandum ("Memo") was completed by Dr.
Tom McGill, with ELMT Consulting, to assess the suitability of the project site to support Peninsular
bighorn sheep (PBS) and the potential for the project to directly or indirectly affect the PBS. Dr.
McGill's Biological Assessment Memo was completed for the site due to its adjacency to Coral
Mountain and proximity to US Bureau of Land Management (BLM) federally managed lands. The
Biological Assessment Memo is included in this Final EIR as Appendix D.S. The Draft EIR correctly
determined that the project site is not within critical habitat for the PBS. However, development in
the vicinity of the Santa Rosa Mountains has the potential to add water and vegetation to the desert
floor that can attract PBS out of their established habitat. Therefore, Dr. McGill identified the
following Avoidance and Minimization Measures and Land Use Adjacency Guidelines from the
CVMSHCP, and recommended that all applicable requirements be incorporated into the Conditions
of Approval to ensure compliance with the CVMSHCP and avoid or minimize indirect impacts to PBS.
These requirements include:
New projects within or adjacent to conservation areas shall not use toxic or invasive plant
species in landscaping. Table 4-112 in the CVMSHCP provides a list of acceptable plant species,
while Table 4-113 lists out prohibited plant species.
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- Land Use Adjacency Guidelines require that projects adjacent to a Conservation Area adhere
to the following guidelines: Drainage; Toxics; Lighting; Noise; Barriers; and Grading/Land
Development. Please see Appendix D.5 for a description of these guidelines, which are also
discussed in detail below in Response No. 13-e.
With incorporation of these measures, the project fully complies with the avoidance and minimization
measures specified in the CVMSHCP for PBS and other protected species, as well as the Land Use
Adjacency Guidelines.
As described in the Biological Resources Topical Response in Section 2.2.2, above, and Responses 13-
d through 13-m, the project as modified will avoid impacts to PBS because the Specific Plan has been
modified to include a requirement to construct a sheep barrier/perimeter fence along its southern
and western boundaries that will be designed to exclude PBS from the project site and includes a
landscape plant palette that is consistent with CVMSHCP guidance, directly addressing the
commenter's concerns. The sheep barrier is to consist of 8 -foot -high fencing as shown in approved
Coachella Valley Conservation Commission (CVCC) "PBS Barrier Project" or an equivalent combination
of 6 -foot CMU and 2 -foot decorative wrought iron or tubular steel view fence as appropriate. The
balance of the project boundaries fronting on perimeter roadways will be surrounded by 6 -foot block
walls along the northern, eastern, and southeastern boundaries, consistent with City standards.
Please see the Conceptual PBS Barrier Plan (page 2-15) in the Biological Resources Topical Response
in Section 2.2.2, above. These measures ensure that the project will not have any significant Impacts
on Peninsular bighorn sheep, as concluded in the DEIR.
Even though the project site is located approximately 0.6 miles from the nearest portion of the PBS
Conservation Area, the project is being required by the City to comply with Land Use Adjacency
Guidelines, as recommended by Dr. McGill, because PBS have been tracked on Coral Mountain.
These Land Use Adjacency Guidelines address the avoidance of non-native vegetation along unfenced
area as recommended in USFWS Measure 1.2.1.2, the prohibition of known toxic plants as
recommended in USFWS Measure 1.2.1.4. and the avoidance of plants known to invade and degrade
bighorn sheep habitat as recommended in USFWS Measure 1.2.1.5 quoted in this comment. The
Specific Plan has been modified to include a landscape plant palette that is consistent with CVMSHCP
guidance for the 25 foot buffer area adjacent to the proposed sheep barrier. These modifications are
consistent with Table 4-112 in the CVMSHCP, which provides a list of acceptable plant species, and
Table 4-113 which lists prohibited plant species.
The proposed sheep barrier will also avoid the impact of enticing PBS onto private property by
creating an effective barrier to separate PBS from humans and their pets, as recommended in USFWS
Measure 1.2.1.6. The proposed trail to be located through the property as part of the Desert
Recreation District (DRD) trail system, and all other recreational activities in Planning Area IV of the
Specific Plan, will occur east of the barrier. The modifications to the project will effectively discourage
the artificial feeding of coyotes as recommended in Measure 1.2.1.10 because the sheep barrier will
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also help keep project residents and guests from accessing Coral Mountain and other adjacent BLM
open space where they could encounter coyotes, as well as help keep coyotes from accessing the
project site.
Finally, Mitigation Measure BIO -9 has been added to the Draft EIR to require that all water features
be designed and maintained to eliminate the potential for arboviral disease vectors, as recommended
in USFWS Measure 1.2.1.9 (please see Section 3.1 of this Final EIR).
The changes in the Specific Plan described in this response will be made enforceable by the City
through the Project Development Agreement and/or conditions of approval. In addition, the
measures will also be made enforceable for the life of the project through the Covenants, Conditions
& Restrictions (CC&Rs) that will be recorded against all applicable properties within the project site.
Comment 11-d:
B. Light Study Needed in the DEIR Review
While Mitigation Measure BIO -4 requires a Light Study to be performed in the future in order to
evaluate how the proposed lighting plan will affect Coral Mountain, this type of study should have
been provided in the DEIR. The detrimental effects of artificial night lighting on wildlife are
scientifically well documented (Longcore and Rich 2004, Gaston et al. 2013, Gaston and Bennie 2014).
While the proposed shielded lighting is likely to be helpful to offset impacts, until the Light Study is
actually implemented and the results are identified, it may be insufficient to offset impacts to the
plants and animals that reside on Coral Mountain. The results of the Light Study should be included
in a revised DEIR for public review.
Response 11-d:
Contrary to the commenter's assertion, light studies have already been performed and described in
the DEIR at page 4.1-60 — 4.1-70. The future light study required by Mitigation Measure BIO -4 can
only be performed once the lighting at the Wave Basin is installed, to confirm that the lighting will
not create any overspill of light onto Coral Mountain. As explained in the DEIR, the lighting for the
Wave Basin includes shielded, directional energy efficient LED light fixtures that prevent significant
light spillage outside of the Wave Basin planning area (see DEIR pp. 4.1-60 — 4.1-63). The DEIR also
includes a lighting analysis in Appendix B that shows the light from the Wave Basin system will drop
below 1 foot candle within 50 feet of the Wave Basin on all sides. Adjacent to Coral Mountain, exhibit
on page 2-10 above demonstrates that the light levels will be drop to the imperceptible level of 0.01
footcandles in the immediate vicinity of the Wave Basin planning area, and approximately 375 feet
away from the nearest portion of Coral Mountain. Please also see the Light and Glare Topical
Response in Section 2.2.1, above and Appendix B.2 to this Final EIR.
In order to assure that the analysis completed for the Draft EIR is consistent with conditions on the
ground when the project is construction, additional protection is provided by Mitigation Measure
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BIO -4, which requires all project lighting to be shielded and directed to avoid light spillage onto Coral
Mountain, and requires a supplemental analysis be completed to measure actual light from the
constructed Wave Basin lighting to confirm that there is no overspill of light onto Coral Mountain.
This confirmation study cannot be performed until the lighting system has been constructed, and thus
has not been improperly deferred.
Comment 11-e:
11. the DEIR's Analysis of Water Supply Impacts is Inadequate
California, and much of the western United States, is suffering the effects of a historic drought, the
end of which is not predicted any time soon. The majority of Riverside County is experiencing either
"severe", or "extreme" drought conditions, with a small portion in the most dire, "exceptional"
drought category. (U.S. Drought Monitor.) As the frequency and intensity of droughts in California
increase due to climate change, it is critical that land use decision-making be made based on robust
and thorough water supply analyses. Unfortunately, the DEIR completely ignores the reality in which
the proposed project would operate, and fails to include a legally adequate discussion of the project's
demand for water, the available supply, nor the environmental consequences of providing the needed
supply.
Response 11-e:
Please see the Water Resources Topical Response in Section 2.2.3, above. It is noted that La Quinta is
shown as being in drought conditions, according to the U.S. Drought Monitor. As regards the
commenter's assertion that the Draft EIR "ignores" drought conditions, the comment is incorrect. As
described in the Water Resources Topical Response in Section 2.2.3, the CVWD, the site's and the
City's water provider, has thoroughly and comprehensively researched and documented water
demand and supply, including the effects of climate change, in its Urban Water Management Plan
and Indio Subbasin Water Management Plan. As described above, the CVWD's documentation shows
that both short-term and long-term impacts of climate change have been assessed, and that the
management techniques, water supplementation measures and other strategies implemented by
CVWD and its sister agencies within the Subbasin will assure a balanced and positive long term water
supply.
Finally, as relates to the assertion that the Draft EIR does not contain an adequate discussion of water
demand and supply, the comment is mistaken. The Draft EIR and Appendix M, the project's approved
Water Supply Assessment were reviewed, investigated and ultimately approved by the expert in this
area, the CVWD. The City has correctly relied on their expertise, deep understanding and
management responsibilities as they relate to water supply within the City and region.
Comment 11-f:
A. the DEIR's Presentation of Project Water Demand is Misleading
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The DEIR attempts to frame the project's water use as an improvement compared to what could be
used under different plans for the site. It's a false comparison that distracts from the project's
astronomically high per capita water use. The DEIR presents the project's water use in comparison to
uses approved under the current Specific Plan, which would use a total of 1,058.4 acre-feet per year
("AFY"), compared with the project's water demand of 958.63 AFY. (DEIR at 4.15-28-29.) The project
site is currently undeveloped (DEIR at 3-5), and not currently receiving any water from the Coachella
Valley Water District ("CVWD"), who will serve the project. The DEIR must describe the project's
existing conditions so that the public and decision -makers are adequately informed of the impacts of
supplying this project with water. (See Woodward Park Homeowners Assn., Inc. v. City of Fresno
(2007) 150 Cal.App.4th 683, 709-10 ["[i]n assessing the impacts of a project proposed for an
undeveloped piece of property, agencies should compare project impacts against the existing
environment, rather than some hypothetical, impacted future environment that might occur without
the project under existing general plan and/or zoning designations" (internal quotations omitted)].)
The project is a standalone land use proposal for a site that is not developed, the water supply impacts
of the project must be presented as such, without any misleading comparisons to irrelevant
preexisting land use designations. A wave park may be a more conservative use of water compared
to a hypothetical golf course, but a wave park where once was parched desert earth is a different
consideration all together.
Response 11-f:
The Draft EIR clearly states the project's existing vacant condition throughout the document, and
again specifically as it relates to water resources on page 4.15-1 and 4.15-2. The Draft EIR also states
on page 4.15-26 that "development of the project would result in an overall increase in water demand
from the project site during operation" (Draft EIR page 4.15-2). Both the Draft EIR and the WSA/WSV
analyzed project water consumption, and determined that water provided by the local water
purveyor (CVWD) could support development and operation of the proposed project as well as all
other existing and planned future uses. Contrary to the assertion in this comment, this analysis
properly used the current baseline of no water use in evaluating the potential impact of the project.
The fact that the project's anticipated water demand is already accounted for in CVWD's long-range
plans is an appropriate consideration as it relates to CVWD's long range planning and conclusion that
it has adequate water supplies for the project and all other projected demand.
A comparison of the project's water demand versus what CVWD has included in its long range land
use assumptions, which include residential, golf course, and neighborhood commercial, is provided
to demonstrate consistency with CVWD planning documents, and not instead of analyzing the
anticipated increase in water demand over existing conditions. This comparison indicates that the
proposed project would consume less water than would be required based on CVWD's future demand
assumptions. Likewise, as shown in Appendix 0 of the Draft EIR, the project would consume
approximately 100 acre-feet per year less than if developed under the existing entitlements. Since it
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is unlikely that the project site would remain vacant, this analysis provides relevant information to
City decision -makers and the public, while in no way undermining the valid water supply and demand
analysis set forth in the WSA/WSV and Draft EIR. Please also see subsection 4.15.5, Cumulative
Impacts, of Section 4.15, Utilities and Service Systems, in the Draft EIR (page 4.15-34) and the Water
Resources Topical Response in Section 2.2.3. Overall, the WSA/WSV and the Draft EIR analyze project -
related water consumption in compliance with CVWD standards and CEQA standards.
Comment 11-g:
The DEIR fails to adequately describe the project's water use in terms of per capita use. The DEIR
notes that CVWD's per capita use is dropping so that in 2015 users within the CVWD service area used
383 gallons per day per capita ("gpdc"). (DEIR at 4.15-30.) As a threshold matter, this is an astonishing
amount of water use, especially compared to the statewide average in 2016 of 85 gpdc. After noting
CVWD's purportedly positive achievement of recent reductions meaning per capita use is now only 4
times the state average of water per person, the DEIR fails to disclose what the project's per capita
water use will be. Instead, the DEIR presents the project's water use in terms of AF/acre, without any
explanation of why this metric is used, or what an acceptable threshold is compared to other
development within CVWD's service area. (See DEIR at 4.15-31.) The project would include 600
residential dwelling units, with 2.63 persons per units. (DEIR App. M [hereinafter "Water Supply
Assessment (WSA)" at 21.) Should the public presume that the project's 958.63 AFY of use will be
attributed to these 1,578 new residents, such that per capita use is approximately 532 gpdc? The DEIR
must be revised to present the project's per capita water use, and it must present this information
using metrics consistent with other CVWD planning documents so that the public and decision -
makers can properly judge the project's water supply impacts.
Response 11-g:
As stated in Response 11-f, a project -specific Water Supply Assessment/Water Supply Verification
(WSA/WSV) was completed for the proposed project. Per the WSA/WSV, the proposed project is
expected to consume approximately 958.63 -acre feet per year (AFY) based on the residential indoor
demand, non-residential indoor demand, and outdoor demands of the project at buildout. Measuring
project water use in acre-feet per year is consistent with the method and metrics used to account for
water resource availability.
The commenter cites the State's Legislative Analyst's Office for the figure of 85 gallons per person per
day, but fails to mention that this metric is only for average indoor residential water use. The
approved WSA, as described on page 20, uses a residential rate of 55 gallons per day (gpd) per person
based on CVWD guidelines and California Water Code Section 10608.20 for indoor use only).
Therefore, CVWD's customers use substantially less water than the State average on the basis of per
capita indoor use.
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As discussed on page 4.15-30 of the Draft EIR, CVWD's 2016 CVWMP Update estimates total water
demand of 383 gallons per capita per day (gpcd), which factors outdoor uses in addition to the
residential indoor factor of 55 gallons per day per person to determine per capita use. As a result,
the district -wide per capita values are inherently larger than those solely attributed to indoor
residential uses. The commenter's assertion that CVWD's per capita water use is 4 times the state
average is therefore incorrect.
At the project level, the WSA/WSV must aggregate, quantify and disclose the total project use, which
was correctly undertaken by calculating all indoor and outdoor uses, as shown in Table 4.15-7 on page
4.15-29 of the Draft EIR. CVWD's standard practice is to do aggregate demand in terms of AFY to
match its method for calculating and analyzing regional water supplies, thereby providing an "apples
to apples" analysis. Furthermore, the commenter's assertion that the project's water use is not
compared to other development is incorrect. As described on page 4.14-31 of the Draft EIR, CVWD
assigns a MAWA to all development projects to limit total outdoor water use. For design purposes,
the upper limit of annual applied water for the established landscape area as specified in Division 2,
Title 23, California Code of Regulations, Chapter 7, Section 702, is based upon the area's reference
evapotranspiration, ET adjustment factor, and the size of the landscaped area. The estimated applied
outdoor water use shall not exceed the MAWA. The MAWA reflects the maximum amount of outdoor
water use that a proposed project may use under the CVWD and City of La Quinta Landscape
Ordinances. This also ensures compliance with applicable state law restrictions on outdoor water use.
The WSA/WSV approved by CVWD calculates this maximum water allocation and assumes that all of
it will be used. The WSA/WSV also evaluates and confirms that there are adequate water supplies to
provide this amount of water, along with all other existing and planned future water uses. For this
project, the MAWA is 962 AFY and the project as designed will use 801.47 AFY. Also see the Water
Resources Topical Response in Section 2.2.3, above.
The suggestion in the comment that the project's per capita water use would exceed CVWD's
estimated average per capita use of 383 gallons is not accurate because only a portion of the project's
total water demand is for indoor and outdoor residential use. The calculation described in this
comment ignores the water use for the hotel, commercial and recreational uses. A detailed
breakdown of the outdoor water use (which constitutes approximately 801 AFY out of the project's
total 958 AFY water demands) is provided in Table 2.0-3 of the WSA/WSV, and duplicated on page 2-
17 above.
Finally, contrary to the comment's closing sentence, the Draft EIR does, as described above, calculate
residential water use on a per capita basis, and does use the metrics that CVWD uses to calculate
water demand and supply in its Urban Water Management Plan and other documents, which is in
AFY.
Comment 11-h:
B. the Draft EIR Fails to Assess the Environmental Impacts Associated Providing Project Water
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Beyond its muddled presentation of the Project's exceedingly high water demands, the DEIR fails to
address the impacts associated with acquiring the water supplies needed for the project and other
users in the CVWD service area. CEQA requires lead agencies both to demonstrate that an adequate
water supply is available for the lifespan of a project, and to analyze the environmental impacts
associated with providing that supply. (See Vineyard Area Citizens v. Rancho Cordova (2007) 40 Cal.
4th 412, 434.)
A majority of the high per capita use within the CVWD service area is supplied by groundwater from
the Indio Subbasin. (WSA at 29.) The Indio Subbasin has experienced historical overdraft, which CVWD
has been addressing with artificial recharge using imported surface water supplies. (See WSA at 35.)
The imported surface water used to replenish the historically over -taxed groundwater basin comes
from the Colorado River, with annual CVWD diversions totaling more than 335,000 AF. (WSA at 41.)
The WSA states that this supply will increase in the future to well over 400,000 AFY, which will be
used to meet increased demand within the CVWD service area so that reliance on groundwater is
lessened. (Id.) This discussion ignores the reality that the Colorado River is in a state of crisis, with the
major water supply reservoirs at historically low levels. The level of Lake Mead has dropped to below
the 1,075 feet mean sea level ("feet msl") threshold where mandatory cuts to water sent to Arizona
and Nevada will occur. If the Lake Mead levels drop further, which is predicted to occur, California
will see its deliveries curtailed. The DEIR is silent when it comes to whether CVWD will be able to
receive its full allocation of Colorado River water into the future, nor does it address what continued
extraction to supplement CVWD's groundwater use will mean to the environment.
Response 11-h:
Please see the Water Resources Topical Response in Section 2.2.3. As described in the Topical
Response, both the WSA/WSV and CVWD's Indio SMGA Update consider the potential for extended
drought conditions. In addition, the Indio SMGA Update specifically considers the impact of climate
change and examines multiple scenarios for its effect on the subbasin groundwater levels for the 50 -
year period 2020 — 2070, taking into account both cumulative water demand and CVWD's
groundwater management efforts. In total, several alternative scenarios are addressed in the SGMA
Update that account for all projected growth, expanded agricultural water use, and climate
change/drought effects, including the potential need for CVWD to contribute water to California's
Lower Basin Drought Contingency Plan allotment for Colorado River Water. Based on this detailed
analysis, CVWD projects a substantial increase in future subbasin groundwater storage, not an
overdraft condition, due to its ongoing groundwater management efforts and future planned CVWD
projects that will reduce the net demands on the Subbasin. (See, e.g., Indio SMGA Update', pp. ES -9
— ES -12, and p. 7-89). Contrary to the comment's assertion, it is not the responsibility of the project -
specific EIR to analyze the environmental impacts of the CVWD's water management plans or the
2 The Indio SGMA Update can be accessed here: http://www.indiosubbasinsgma.org/wp-content/uploads/2021/12/Indio-
SGMA-AlternativePlan-voll-Alternative-Plan-FINAL-to-be-Adopted-Nov-2021v3.pdf.
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regional SMGA Update. The responsibility of the City is to assure that the water supplies required for
the project will not impact the environment. That analysis has been completed in the Draft EIR, and
supplemented in this Final EIR.
Comment 11-1:
The DEIR creates further uncertainty to its future supply, and the impacts associated therewith, when
discussing the amount of State Water Project ("SWP") water it will import to facilitate an exchange
agreement with Metropolitan Water District ("MWD"). (WSA at 42-43.) The projected SWP deliveries
provided in the DEIR are misleading, as these totals represent nothing more than "paper water"
allocations, not what will actually be delivered. The DEIR only lists the actual allocations up until 2018.
(WSA at 43.) Table A allocation for 2020 was 20%, and only 5% for 2021.3 Existing constraints on
deliveries from the SWP will only increase as climate change alters precipitation patterns and
droughts intensify. The DEIR should properly recognize this reality, and revise its discussion to present
how much SWP is actually received by CVWD, so that the public is adequately informed of the
potential to serve the project.
Response 11-1:
Please see the Water Resources Topical Response in Section 2.2.3. First, the commenter's inference
that the project will result in additional SWP water demand is incorrect. CVWD's SWP deliveries are
not tied to any project, and its allocation is not project -dependent. The WSA/WSV provides the actual
annual deliveries of SWP exchange water in Table 3.0-9, which included deliveries as low as 5% in a
critical dry year. In addition, the various threats to the reliability of SWP exchange water, including
climate change and further regulatory restrictions to protect endangered species, are described on
page 45 of the WSA.WSV. The Draft EIR and WSA/WSV properly disclosed the actual amounts of SWP
exchange water delivered and disclosed the future risks to those supplies.
In addition, CVWD's analysis and projections for future water supplies take into account the potential
reductions in water deliveries from SWP exchange water and the Colorado River due to extended
drought conditions in its SMGA Update scenario analysis (described in Topical Response 2.2.3). As
described above on page 2-23 of the Topical Responses, all future water supply scenarios in the SGMA
Update assume only 45% of the SWP allocations will actually be delivered, consistent with historical
SWP deliveries since 2007. For the climate change scenarios, further reductions in deliveries from the
SWP exchange and the Colorado River were assumed, also as described in the Water Resources
Topical Response in Section 2.2.3.
Comment 11-j:
111. Conclusion
Given the possibility that the Center will be required to pursue appropriate legal remedies in order to
ensure enforcement of CEQA, we would like to remind the City of its duty to maintain and preserve
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all documents and communications that may constitute part of the "administrative record." As you
may know, the administrative record encompasses any and all documents and communications which
relate to any and all actions taken by the City with respect to the Project, and includes "pretty much
everything that ever came near a proposed [project] or [] the agency's compliance with CEQA ...."
(County of Orange v. Superior Court (2003) 113 Cal.App.4th 1, 8.) The administrative record further
contains all correspondence, emails, and text messages sent to or received by the City's
representatives or employees, which relate to the Project, including any correspondence, emails, and
text messages sent between the City's representatives or employees and the project proponent's
representatives or employees. Maintenance and preservation of the administrative record requires
that, inter alia, the City (1) suspend all data destruction policies; and (2) preserve all relevant
hardware unless an exact replica of each file is made.
Thank you for the opportunity to submit comments on the Draft Environmental Impact Report for the
proposed Coral Mountain Resort Project. The Center is deeply concerned by the significant
environmental and social impacts of the proposed Project. The DEIR fails to meet CEQA's
requirements for thorough, transparent and evidence -based environmental review, and is thus legally
deficient. We ask the City to address and correct the deficiencies we have identified above and
recirculate an updated Draft EIR for public review and comment.
Please add the Center to your notice list for all future updates to the Project and do not hesitate to
contact the Center with any questions at the number or email listed below.
Response 11-j:
The City thanks the Center for Biological Diversity for participating in the Draft EIR public review
process. The comment regarding preservation of the administrative record is noted. The City has and
will continue to maintain a complete record of the project's proceedings.
The commenter's opinions regarding the adequacy of the Draft EIR and the request for recirculation
are noted. However, recirculation is not required or appropriate here because the responses to
comments and additional information added in the Final EIR elaborate and clarify the analysis and
conclusions in the Draft EIR. As the conclusions in the Draft EIR have not changed and no significant
new information has been added that would deprive the public of a meaningful opportunity to
comment upon a substantial adverse environmental effect or a feasible way to mitigate or avoid such
an effect, recirculation of the Draft EIR is not required under CEQA Guidelines § 15088.5.
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Comment Letter No. 12: California Department of Fish and Wildlife (CDFW)
Name: Heather A. Pert, Senior Environmental Scientist (Supervisor)
Date: August 9, 2021
Affiliation: California Department of Fish and Wildlife (CDFW)
Address: 3602 Inland Empire Boulevard, Suite C-220
Ontario, CA 91764
Comment 12-a:
The California Department of Fish and Wildlife (CDFW) is requesting an extension to submit
comments to 8/13/21 on the draft EIR for Coral Mountain Resort DEIR. We had some staffing changes
around the time of release for this document and in combination with a heavy workload were not
aware of the release of the draft EIR.
Response 12-a:
The City accepted the CDFW request for an extension to provide written comments to August 13,
2021.
Comment 12-b:
Our specific concerns are that the draft EIR does not adequately address the documented presence
of Peninsular bighorn sheep (PBS) on the project site, PBS are a California fully -protected species and
a covered species under the Coachella Valley Multiple Species Habitat Conservation Plan. The draft
EIR states "this species [Peninsular Bighorn Sheep] is not present at the site due to the absence of
suitable habitat" (EIR page 231), however, CDFW wildlife biologist have documented use of the area
by PBS. It appears that CDFW wildlife biologist were not consulted in preparation of the Draft EIR. In
addition, this project is adjacent to the east side of the mountain (map on EIR page 16) where sheep
are present. If the project moves forward, CDFW recommends fencing around the property to keep
both sheep and people in their respective areas. However, our initial request is consultation with
CDFW staff to discuss presence of PBS and develop appropriate avoidance and minimization
measures. Given the adjacency of the project site to PBS habitat, avoidance and minimization
measures should be included in the Draft EIR that are consistent with the Coachella Valley MSHCP.
We would appreciate the additional time to provide a more detailed response.
Response 12-b:
The commenter's concerns are noted. However, the commenter's assertion that CDFW was not
consulted in preparation of the Draft EIR is incorrect. As required by Guidelines Section 15082, the
City transmitted the Notice of Preparation for the Coral Mountain Resort EIR to CDFW on February
11, 2021. It was received on February 17, 2021. In addition, the NOP was sent to CDFW by the Office
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of Planning and Research on February 11. Please consult Comment Letter No. 13 for letter from
CDFW, which expands discussion of agency concern for PBS at the project site.
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Comment Letter No. 13: California Department of Fish and Wildlife (CDFW)
Name: Heather A. Pert, Senior Environmental Scientist (Supervisor)
Date: August 13, 2021
Affiliation: California Department of Fish and Wildlife (CDFW)
Address: 3602 Inland Empire Boulevard, Suite C-220
Ontario, CA 91764
Comment 13-a:
The California Department of Fish and Wildlife (CDFW)received and reviewed the Draft Environmental
Impact Report (DEIR) from the City of La Quinta for Coral Mountain Resort (Project), State
Clearinghouse No. 2021020310, pursuant the California Environmental Quality Act (CEQA) statute
and guidelinesl. Thank you for the opportunity and extension of August 13, 2021 to provide
comments and recommendations regarding those activities involved in the Project that may affect
California fish, wildlife, plants, and their habitats. Likewise, CDFW appreciates the opportunity to
provide comments regarding those aspects of the Project that CDFW, by law, may need to exercise
its own regulatory authority under the Fish and Game Code (Fish & G. Code).
Response 13-a:
The City thanks the CDFW for participating in the review of the Draft EIR. In response to this comment
letter, and as requested by the commenter, the City scheduled a conference call between CDFW
biologists, City representatives, Dr. Tom McGill (a biologist with extensive experience with bighorn
sheep who was hired by the applicant to ensure that all potential impacts to bighorn sheep are
properly addressed), and other representatives of the applicant. During the September 29, 2021 call,
the comments raised in the CDFW letter were discussed, and the applicant agreed to (1) include an
8 -foot high sheep barrier along the western boundary of the project as requested by CDFW, and (2)
to provide a draft of the responses to this letter to CDFW prior to finalizing and publishing the Final
EIR.
A second conference call was held on January 25, 2022, to discuss CDFW's review of the draft
responses to comments made in CDFW's comment letter on the Draft EIR and revisions to the Draft
EIR and to discuss any additional comments and recommendations from CDFW. CDFW thanked the
City and project applicant for the commitments to (1) install the proposed sheep barrier, and (2)
continue to consult with CDFW on the final design, location, and construction of the barrier. Based
on that meeting, the City agreed to make certain additional clarifications to the mitigation measures
for biological resources and certain clarifications to the responses to CDFW's comments to fully
address the issues raised by CDFW in their comment letter. These responses have been revised to
clarify that Coral Mountain has been identified as essential habitat for PBS and, for this reason, the
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project has been designed to be consistent with the conservation objectives for PBS in Section 9.8.4
of the CVMSHCP and the Land Use Adjacency Guidelines in Section 4.5 of the CVMSHCP.
Comment 13-b:
CDFW is California's Trustee Agency for fish and wildlife resources and holds those resources in trust
by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802; Pub. Resources
Code, § 21070; CEQA Guidelines § 15386, subd. (a)) CDFW, in its trustee capacity, has jurisdiction over
the conservation, protection, and management of fish, wildlife, native plants, and habitat necessary
for biologically sustainable populations of those species. (Fish & G. Code, § 1802.) Similarly, for
purposes of CEQA, CDFW provides, as available, biological expertise during public agency
environmental review efforts, focusing specifically on Projects and related activities that have the
potential to adversely affect fish and wildlife resources.
CDFW may also act as a Responsible Agency regarding any discretionary actions under CEQA (Pub.
Resources Code, § 21069; CEQA Guidelines, § 15381), such as the issuance of a Lake or Streambed
Alteration Agreement (Fish & G. Code Sections 1600 et seq.), a California Endangered Species Act
(CESA) Permit for Incidental Take of Endangered, Threatened, and/or Candidate species (Fish & G.
Code Sections 2080 and 2080.1), and/or for administering the Natural Community Conservation
Planning Program (NCCP). CDFW also administers the Native Plant Protection Act, Natural Community
Conservation Program, and other provisions of the Fish and Game Code that afford protection to
California's fish and wildlife resources.
CDFW issued Natural Community Conservation Plan Approval and Take Authorization in 2008 for the
Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP), as per Section 2800, et seq.,
of the California Fish and Game Code. The CVMSHCP established a multiple species conservation
program to minimize and mitigate habitat loss and the Incidental Take of Covered Species in
association with activities covered under the permit. CDFW is providing the following comments as
they relate to the Project's consistency with the CVMSHCP and the CEQA.
Response 13-b:
This introductory comment describing the role of CDFW role as a trustee agency does not identify a
specific concern or question regarding the adequacy of the Draft EIR in identifying and analyzing the
potential environmental impacts of the project. For this reason, no further response to this comment
is provided.
Comment 13-c:
Project Location
The Project site encompasses an area of approximately 929 acres in the southeastern portion of the
City of La Quinta. The local area is characterized as a developing area with a number of golf course
and residential communities to the north, west, east, and southeast, the Santa Rosa Mountains to the
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west and south, and open space and the Coachella Valley Water District (CVWD) percolation ponds
to the south. The Santa Rosa Mountains are to the west and south and Coral Mountain is within the
southwest portion of the Project property. The approximately 386 -acre portion of the Project site, to
be developed under SP 2020-0002, is bounded by vacant land and Avenue 58 to the north; Madison
Street to the east; residential estates, vacant land, and the Avenue 60 alignment to the south; and
Coral Mountain, and vacant land to the west.
Project Description
The Project area consists of 929 acres in total. Of that, 543 acres occur on the east side of Madison
Street, and will continue to develop as provided under SP 03-067, as a residential and golf country
club. The western portion of the Project, on the west side of Madison Street, proposes the
development of the approximately 386 -acre area and is the focus of the DEIR. This portion of the
Project would be developed under a new Specific Plan (SP 2020-0002) with up to 496 low density
residential units on 232.3 acres; tourist and commercial land uses including a resort hotel with up to
150 rooms, a 16.62 -acre recreational Wave Basin facility, 104 resort residential units, and 57,000
square feet of commercial development on approximately 120.8 acres; 60,000 square feet of
neighborhood commercial uses on approximately 7.7 acres; and open space recreational uses on
approximately 23.6 acres adjacent to Coral Mountain.
Within the 386 acres west of Madison Street, the Project also requests approval of General Plan
Amendment (GPA 2019-0002), Zone Change (ZC 2019-0004), Specific Plan Amendment (SP 03-067),
Specific Plan (SP 2020-0002), Tentative Tract Map (TTM 2019-0005), Site Development Permit (SDP
2021-0001), and Development Agreement (DA 2021-0002), as detailed below.
1. General Plan Amendment
The General Plan Amendment (GPA 2019-0002) will amend the current General Plan land use
designations from General Commercial, Low Density Residential, and Open Space — Recreation to
Neighborhood Commercial, Low Density Residential, Tourist Commercial, and Open Space —
Recreation.
2. Zone Change
The proposed Zone Change (ZC 2019-0004) will revise the existing zoning of the Specific Plan Area
from Neighborhood Commercial, Low Density Residential, and Golf Course, to Neighborhood
Commercial (CN), Low Density Residential (RL), Parks and Recreation (PR), and Tourist Commercial
(CT).
3. Specific Plan Amendment
The Specific Plan Amendment (Amendment V of Specific Plan 03-067) is being processed to remove
the area west of Madison Street from Specific Plan 03-067, thus, creating two separate and distinct
communities, "Coral Mountain Resort", west of Madison Street, and "Andalusia Country Club",
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east of Madison Street. The Specific Plan Amendment will result in only the deletion of the westerly
386 acres. No changes to land use designations, densities or intensities, development standards or
guidelines are proposed for the lands east of Madison Street. It is expected that Andalusia will
continue to build out under the requirements of the SPA.
4. Specific Plan
Approval of the Coral Mountain Resort Specific Plan (SP 2020-0002) will establish a new master
plan governing the allowable land uses, design guidelines, and development standards for the 386 -
acre property west of Madison Street, to allow creation of a boutique resort and master -planned
community. The Project will result in a variety of land uses on the westerly 386 acres, as shown in
Exhibit 3-5 of the DEIR. Low Density Residential land uses will occupy approximately 232.3 acres
and result in a maximum of 496 dwelling units. Tourist Commercial land uses will result in 104
dwelling units, 150 hotel rooms, and 57,000 square feet of private resort -serving commercial uses
available to residents and hotel guests, on approximately 120.8 acres. General Commercial land
uses will occupy approximately 7.7 acres, with up to 60,000 square feet of retail commercial uses
available to the general public. Open Space Recreation land uses will occur on approximately 23.6
acres in the southwest portion of the site.
The Project proposes four planning areas, identified as Planning Areas (PA) I, II, III, and IV, on the 386 -
acre property. PA I is designated for Neighborhood Commercial; PA II is designated for Low Density
Residential; PA III is designated for Tourist Commercial; and PA IV is designated for open space Parks
and Recreation located adjacent to Coral Mountain.
Response 13-c:
This comment provides a summary of the project and does not identify a specific concern or question
regarding the adequacy of the Draft EIR in identifying and analyzing the potential environmental
impacts of the project. For this reason, no further response to this comment is provided.
Comment 13-d:
CDFW's comments and recommendations on the DEIR are explained in greater detail below and
summarized here. CDFW has concerns regarding the completeness of the DEIR and finds the
conclusion in the DEIR that Peninsular bighorn sheep (PBS; Sheep; Ovis canadensis nelsoni) are not
on the Project site inaccurate, and the corresponding lack of avoidance and minimization measures
inadequate to protect fish and wildlife resources, specifically Peninsular bighorn sheep. Specific
comments include that there is: no discussion or analysis that addresses the presence of sheep on
and directly adjacent to the Project site; inadequate avoidance and minimization measures for
Peninsular bighorn sheep, burrowing owl, bats, and nesting birds; questions about land ownership
and adjacency to the Santa Rosa Mountains Wildlife Area; and concerns about the adequacy and
enforceability of mitigation measures proposed by the City of La Quinta (the CEQA lead agency).
CDFW is concerned that the DEIR fails to adequately address Peninsular bighorn sheep and requests
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that the DEIR be revised and recirculated pursuant to CEQA Guidelines §15088.5(a). The revised DEIR
should include: biological surveys to assess Peninsular bighorn sheep use of the site and the areas
immediately adjacent to the Project site; clear identification of any proposed avoidance and
minimization measures to avoid take of Peninsular bighorn sheep; discussion and analysis based on
documented sheep use of the Coral Mountain which demonstrates the reduction or elimination of
potential impacts; and discussion on land ownership for the Coral Mountain area, specifically
regarding Bureau of Land Management owned property; additional analysis of light and noise -related
impacts on Coral Mountain, among other items included in the discussion below. Additional details
on these comments are provided below.
Response 13-d:
As addressed in more detail in the responses to the specific comments below, the Draft EIR concluded
that the project would not result in any significant impacts on PBS because the project is not located
within the CVMSHCP designated conservation area and does not have suitable habitat for the PBS
(see DEIR at p. 4.3-15, and Appendix D.1 at p. 4). In order to clarify the Draft EIR, Section 4.3 has been
amended to read:
Peninsular bighorn sheep (Ovis canadensis nelsonii) (peninsula Distinct Population Segment): This
species occurs on open desert slopes below 1,220 meters (4,000 feet) elevation from San Gorgonio
Pass south into Mexico. Optimal habitats include steep -walled canyons and ridges bisected by rocky
or sandy washes, with available water. This spccics is not prcscnt at the site due to the absence of
suitable habitat. This species is not present on the development portion of the site due to the absence
of suitable habitat. While a small portion of the project site includes the northeastern most edge of
Coral Mountain and PBS have been tracked by monitoring devices on Coral Mountain itself, no
development activities of any kind are proposed or allowed on that portion of the property, which will
be separated from all development by an 8 -foot -high sheep barrier.
This clarification to page 4.3-15 is consistent with the Draft EIR's findings and does not provide
substantial new information.
The development site is located approximately 0.62 miles to the east of the PBS conservation area
designated in the CVMSHCP. As confirmed in the Memorandum from Dr. Tom McGill, an expert in
PBS habitat and conservation, the portion of the project site that will be disturbed in connection with
the project (the "Development Site") does not contain suitable habitat for PBS because all
development will occur on the valley floor, and no development will occur on Coral Mountain. The
Dr. McGill Report is attached in Appendix D.5 to the Final EIR.
It is acknowledged by the City that development in the vicinity of the Santa Rosa Mountains has the
potential to add water and vegetation to the desert floor that can attract PBS out of their established
habitat. The project will avoid this potential impact because the Specific Plan has been modified to
include a requirement to construct an 8 -foot -high sheep barrier/perimeter fence that will be designed
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to exclude PBS from the project site, and to include a landscape plant palette that prohibits the plants
listed in Table 4-113 of the MSHCP in all areas adjacent to Coral Mountain or other BLM open space
(see Specific Plan Section 2.5.2 and Figure 13). At the request of CDFW, and to assure that plans are
reviewed by CDFW prior to issuance of any earth moving or grading permit for the project, the City
shall apply a condition of approval on the Specific Plan, Tentative Tract Map and Site Development
Permit 2021-0001 that the sheep barrier plan shall be submitted to the City prior to the issuance of
the first earth moving or grading permit on the project site, for review and consultation with CDFW
on the final location, design and long-term maintenance of the sheep barrier, and that following
completion of such consultation, the plan shall be approved by the City prior to issuance of any earth
moving or grading permit for any aspect of the project. As explained in greater detail in the responses
below, the project fully complies with the avoidance and minimization measures specified in the
CVMSHCP for PBS and other protected species, as well as the Land Use Adjacency Guidelines, which
is also confirmed in the Memorandum from Dr. McGill attached in Appendix D.S. Please also see the
Biological Resources Topical Response in Section 2.2.2 of this Final EIR, which further explains the
conclusion that the project will not have any significant effects on PBS.
This additional information elaborates and clarifies the conclusion in the Draft EIR. As the conclusions
in the Draft EIR have not changed and no significant new information has been added that would
deprive the public of a meaningful opportunity to comment upon a substantial adverse
environmental effect or a feasible way to mitigate or avoid such an effect, recirculation of the Draft
EIR is not required under CEQA Guidelines § 15088.5.
Comment 13-e:
The proposed Project occurs within the CVMSHCP area and is subject to the provisions and policies
of the CVMSHCP. To be considered a covered activity, Permittees need to demonstrate that proposed
actions are consistent with the CVMSHCP and its associated Implementing Agreement. The City of La
Quinta is the Lead Agency and is signatory to the Implementing Agreement of the CVMSHCP. To
demonstrate consistency with the CVMSHCP, the DEIR should address, at a minimum, the City's
obligations as follows:
a. Addressing the collection of fees as set forth in Section 8.5 of the CVMSHCP.
b. Demonstrating how the Project complies with the CVMSHCP requirements and policies,
including: 1) compliance with relevant processes to ensure application of the Conservation
Area requirements set forth in Section 4.0 of the CVMSHCP and thus, satisfaction of the
local acquisition obligation; 2) compliance with the applicable Land Use Adjacency
Guidelines set forth in Section 4.5 of the CVMSHCP; 3) compliance with the Avoidance,
Minimization and Mitigation Measures in Section 4.4 of the CVMSHCP; and 4)
implementation consistent with the Species Conservation Goals and Objectives in Section
9 of the CVMSHCP.
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Thus, CDFW would like to make a clarification to the following statement within the DEIR:
"The construction of the proposed project will change the physical environment of the project site,
which is currently vacant and undeveloped. The site is surrounded by development to the north, east,
and south, and vacant land to the north, west, and south. Although the proposed project will result
in the permanent loss of approximately 386 acres of vacant land, the project will be required to pay
fees to assure the off-site conservation of habitat lands for sensitive species covered by the Coachella
Valley Multiple Species Habitat Conservation Plan (CVMSHCP). Therefore, the loss of biological
resources will be less than significant with the payment of fees to avoid impacts on special status
species. Additionally, the project is required to conduct burrowing owl, bat, and nesting bird surveys
to determine whether roosting or nesting is occurring at the site. If roosting or nesting is discovered
at the project site during the surveys, the mitigation measures include performance standards to
ensure construction of the project does not significant impact biological resources (see Section 4.3,
Biological Resources)."
This statement is inaccurate. Demonstrating implementation of the CVMSHCP is not simply paying
the required development fee; it requires demonstrating consistency with all the CVMSHCP's
requirements that provides a permittee's project with Take coverage through the CVMSHCP for
project impacts to Covered Species and covered natural communities classified by the CVMSHCP as
'adequately conserved' by the overall CVMSHCP. Please revise the DEIR to include a complete analysis
of how the City ensures the Project fully implements the required terms and conditions of the
CVMSHCP.
Response 13-e:
The Draft EIR accurately concluded that the project is consistent with the CVMSHCP. On page 4.3-7,
it notes that a "review of the Final Recirculated CVMSHCP (CVAG 2016) was also conducted in order
to determine CVMSHCP consistency and conservation measures that apply to the proposed project."
The project's consistency with the CVMSHCP is addressed on page 4.3-21, and in Appendix D.1
(Biological Resources Assessment and CVMSHCP Consistency Analysis), which concluded that the
project is consistent with the CVMSHCP because the project is not located in any conservation area,
will pay the CVMSHCP development fee, and will not remove trees or habitat that are subject to any
CVMSHCP conservation policies.
The project area is located in the portion of the CVMSHCP plan area designated for future
development, rather than conservation, and this site was approved for development by the County
of Riverside more than 20 years ago, prior to the property being annexed into the City of La Quinta.
As a result, the project is required to pay the CVMSHCP impact fee, which has been adopted by the
City of La Quinta to help fund CVCC's acquisition of additional high-quality habitat within the
conservation areas designated in the CVMSHCP.
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The project is also required to implement all applicable avoidance and minimization measures set
forth in Section 4.4 of the CVMSHCP. As described in the Draft EIR (see Mitigation Measure BIO -1),
the project is required to conduct burrowing owl surveys in accordance with the protocols set forth
in Section 4.4 of the CVMSHCP (see pp. 4-166 — 4-167). Section 4.4 also prohibits construction
activities within the PBS conservation area during the lambing season, but as the project site is located
outside of the designated conservation areas, this provision is inapplicable.
As indicated in the comment, compliance with the CVMSHCP also requires compliance with the Land
Use Adjacency Guidelines specified in Section 4.5 of the plan. The CVMSHCP defines "adjacent" as
"sharing a common boundary with any parcel in a Conservation Area" (see p. 4-176). No part of the
project satisfies this definition because the project is located approximately 0.62 miles to the east of
the nearest designated Conservation Area (see Figure 4-26(b) in the CVMSHCP).
However, in response to the CDFW comment letter, the City and applicant have agreed that the
project will comply with all provisions of those Guidelines for all areas adjacent to Coral Mountain or
other BLM open space, and this requirement is being made enforceable through the project
Development Agreement. As stated on page ES -12 of the CVMSHCP, "[t]he purpose of the Land Use
Adjacency Guidelines is to avoid or minimize indirect effects from Development adjacent to or within
the Conservation Areas. Such indirect effects are commonly referred to as edge effects, and may
include noise, lighting, drainage, intrusion of people into the adjacent Conservation Area, and the
introduction of non-native plants and non-native predators such as dogs and cats."
Here, all project lighting will be required to be shielded and directed to avoid light spillage onto Coral
Mountain (see Mitigation Measure BIO -4). In addition, the lighting system analysis conducted for
the project demonstrates that there will be no light spillage outside the Wave Basin planning area,
including toward Coral Mountain or other BLM open space. This is described in more detail in the
Light and Glare Topical Response in Section 2.2.1 of this Final EIR and is further demonstrated by the
lighting cut-off contour exhibit within that topical response, which shows the contours for where light
emissions will drop to 0.5 foot candles and 0.01 foot candles, which occurs in the immediate vicinity
of the Wave Basin itself and at least 375 feet away from Coral Mountain.
The Draft EIR also analyzed potential construction and operational noise impacts. As explained on
pages 4.11-32 — 4.11-35, construction noise can range from approximately 68 dBA to in excess of 80
dBA when measured at 50 feet from the source, with a reduction of 6 dBA for every doubling of
distance. The closest project construction will be the Wave Basin in Phase 1, and the highest projected
noise level is 76.5 dBA (see Table 4.11-15). Therefore, based on the noise attenuation caused by
distance, construction noise will not exceed 75dBA at 100 feet from the location of construction
activities. The closest any construction activity will be to Coral Mountain is approximately 100 feet at
the northwest corner of the project site. Based on the configuration of the project site and the
project, most construction activity will be located at least 300-400 feet from Coral Mountain. The
highest projected operational noise level is 64.5 dBA at location P-10 in the tourist commercial portion
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of the site next to the hotel and Wave Basin (see Table 4.11-25 and Exhibit 4.11-2). Accordingly, the
project will not exceed the CVMSHCP Land Use Adjacency Guidelines for noise levels at Coral
Mountain or in any designated Conservation Areas. This information from Section 4.11, Noise, of the
DEIR will also be added to Section 4.3, Biological Resources.
The Land Use Adjacency Guidelines also prohibit planting invasive, non-native plant species in and
adjacent to Conservation Areas, and includes tables of recommended and prohibited species (see
CVMSHCP p. 4-177 and Tables 4-112 and 4-113). Section 2.5.2 has been added to the Specific Plan to
prohibit all species listed on Table 4-113 in all portions of the project adjacent to Coral Mountain and
the other BLM open space (see Specific Plan pp. 35-36 and Figure 13). This requirement will be made
enforceable through the project Development Agreement, and will be enforceable for the life of the
project through the Covenants, Conditions & Restrictions (CC&Rs) that will be recorded against all
portions of the project site that are subject to the enhanced plant palette restrictions. The Draft EIR
has been revised to include this discussion (page 4.3-22) as follows:
"The Land Use Adjacency Guidelines also prohibit planting invasive, non-native plant species in and
adjacent to Conservation Areas, and include tables of recommended and prohibited species (see
CVMSHCP p. 4-177 and Tables 4-112 and 4-113). Section 2.5.2 has been added to the Specific Plan to
prohibit all species listed on Table 4-113 in all portions of the project adjacent to Coral Mountain and
the other BLM open space (see Specific Plan pp. 35-36 and Figure 13). This requirement will be made
enforceable through the project Development Agreement and will be enforceable for the life of the
project through the Covenants, Conditions & Restrictions (CC&Rs) that will be recorded against all
portions of the project site that are subject to the plant palette restrictions."
Finally, Section 4.5.6 of the Land Use Adjacency Guidelines requires the incorporation of barriers to
minimize unauthorized public access, domestic animal predation, illegal trespass, and dumping in a
Conservation Area. The Specific Plan has been revised to expressly include a protective sheep barrier
which complies to the requirements for PBS barriers in the CVMSHCP along the western boundary
(covering all areas adjacent to Coral Mountain and other BLM open space property). The protective
sheep barrier will be 8 -feet high, with the final design and location subject to City approval in
consultation with CDFW. In response to the CDFW request for this sheep barrier, the City and
applicant have agreed to include the sheep barrier in the Specific Plan and as a requirement under
the project development agreement.
Comment 13-f:
The proposed Project occurs in or immediately adjacent to Essential Habitat for Peninsular bighorn
sheep (U.S. Fish and Wildlife Service, 2000) and has the potential to impact Peninsular bighorn sheep,
a federally endangered species (Fed. Register, Vol. 63, No. 52, 1998) and a State endangered and
California Fully Protected species (Calif. Dep. Fish and Game 1992), and a Covered Species under
CVMSHCP. Fully Protected Mammals may not be taken or possessed at any time and no licenses or
permits may be issued for their Take except for necessary scientific research, including efforts to
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recover fully protected species (Fish & G. Code Section 4700). All Covered Activities of the CVMSHCP
must avoid actions that will result in violations of the fully protected species provisions (NCCP Permit
# 2835-2008-001-06). Take cannot be provided under the CVMSHCP for Peninsular bighorn sheep,
however, CDFW has acknowledged and agreed that if the measures set forth in the CVMSHCP are
fully complied with, the Covered Activities are not likely to result in Take of these species. It is critical
that to receive coverage for potential Take of Peninsular bighorn sheep habitat that the Project
properly implements the CVMSHCP. CDFW requests that the DEIR is modified to include a discussion
of State Fully Protected Mammals which should clearly state that no Take is allowed of Peninsular
bighorn sheep including under the CVMSHCP.
Response 13-f:
The proposed project development does not occur in the CVMSHCP designated conservation area for
PBS, but Coral Mountain and other adjacent BLM land were identified as Essential Habitat for the PBS
in the USFW Recovery Plan (2000) that preceded the CVMSHCP. The proposed project occurs 0.62
miles, at its closest point, from the designated conservation area for PBS as established in the
CVMSHCP, as shown in Exhibit 1 to the Dr. McGill report attached as Appendix D.S. The Draft EIR
acknowledges that Peninsular bighorn sheep is an endangered and fully -protected species (see p, 4.3-
8). As explained above, the project has been modified to avoid any take of PBS, as ensured by full
compliance with CVMSHCP Land Use Adjacency Guidelines, including the construction of an 8 -foot
high sheep barrier as requested by CDFW. As requested in this comment, a statement has been added
to the EIR (at p. 4.3-8) confirming that "no take of the Peninsular bighorn sheep is allowed because
the species is a federally endangered species and a California Fully Protected Species."
Comment 13-g:
The proposed Project occurs in Essential Habitat for Peninsular bighorn sheep (U.S. Fish and Wildlife
Service, 2000) and has the potential to impact Peninsular bighorn sheep, a federally endangered
species (Fed. Register, Vol. 63, No. 52, 1998) and a State endangered and California Fully Protected
species (Calif. Dep. Fish and Game 1992), and a Covered Species under CVMSHCP. The DEIR incorrectly
identifies that "this species [PBS] is not present at the site due to the absence of suitable habitat"
(page 231). This statement is inaccurate. CDFW has monitored PBS movement in the Santa Rosa and
Santa Jacinto mountains since 2009 with GPS collars and direct observation. CDFW's GPS data
documents current and historic sheep use of Coral Mountain (Figure 1; CDFW 2020).
An exhibit of historical Peninsular Bighorn Sheep use of the project site and surrounding area is
provided in this comment.
Response 13-g:
See response to comment 13-f above. In order to assure clarity, the Draft EIR, at page 4.3-15, will be
modified to read: "This species is not present on the development portion of the site due to the
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absence of suitable habitat. While a small portion of the project site includes the northeastern most
edge of Coral Mountain and PBS have been tracked by monitoring devices on Coral Mountain itself,
no development activities of any kind are proposed or allowed on that portion of the property, which
will be separated from all development by an 8 -foot -high sheep barrier."
Comment 13-h:
CDFW research on sheep movement, based on GPS data and direct observation, shows a trend of
ewes spending a greater portion of their time in low -elevation habitat particularly during the Iamb -
rearing season (CDFW 2020). This temporal shift to lower elevations may be a response to long-term
drought conditions. Alluvial fans and washes, where more productive soils support greater plant
growth than steeper, rockier soils, tend to have more concentrated, nutritious forage (US Fish and
Wildlife Service 2000). Following lambing, ewes have high energy needs for lactation and the time -
period surrounding lambing and nursing is very demanding in terms of the energy and protein
required by bighorn ewes. A wide range of forage resources and vegetation associations is needed to
meet annual and drought related variations in forage quality and availability. Lower elevation habitat
can include alluvial fans, washes, and desert flats that provide more abundant and high-quality
vegetation, such as water -rich cactus, than steeper terrain, and are crucial to the viability of bighorn
sheep populations during times of drought (FWS 2000), and provide an important source of nutrition
and water during lactation (Hansen and Deming 1980) and Iamb -rearing (Hines 2019).
CDFW is concerned that the proposed development will introduce forage and water sources that will
attract rams, ewes, and Iambs, where they may become at risk to injury and death from drowning in
swimming pools, toxic plants poisoning, vehicle strikes, the effects of ingesting intestinal parasites
present among watered lawns and grasses, and other potential urban hazards. In the City of La
Quinta, existing developments (including SilverRock, PGA West, and The Quarry at La Quinta) along
the wildland-urban interface have become attractive nuisances for sheep because of artificial features
that attract sheep, for example grass and artificial water sources. This results in sheep habituated to
urban environments, and can lead to increased mortality risk through transmission of disease,
ingestion of toxic materials, vehicle strikes, and drowning in artificial water sources. These
developments are adjacent to Peninsular bighorn sheep habitat in the Santa Rosa and San Jacinto
Mountains Conservation Area of the CVMSHCP. As a result of these issues, the MSHCP requirement
for building a fence at this interface was triggered and the City of La Quinta is currently working with
the Coachella Valley Conservation Commission to build a sheep fence. CDFW is concerned that this
Project will create similar conditions and become an attractive nuisance to sheep that currently use
Coral Mountain. Further, once the fence is built to exclude sheep in other areas of La Quinta the sheep
may migrate to this Project site if it has attractive features. The revised DEIR should identify and
implement specific measures, such as fencing, to keep sheep out of urban areas and prevent trespass
of humans and domestic animals into adjacent sheep habitat.
Response 13-h:
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The commenter's concerns are noted. The project occurs 0.6 mile east of the approved sheep fence
to be erected along the southern boundary of The Quarry development. In addition, two approved
development projects closer to the PBS essential habitat in the Santa Rosa Mountains, Coral Canyon
and Travertine, have or will have provisions that an approved sheep fence will be erected post -
development if sheep are found to be attracted to these developments. The CVCC/City fence
construction is imminent, but the schedule for the construction of the southern extension is not yet
known. As a result, and in order to assure that the proposed project does not impact PBS, since the
receipt of the CDFW letter, the City and the applicant have conferred with CDFW, and developed a
plan for an on-site barrier, an approved 8 -foot fence, that will provide protection from the attraction
created by landscaping and water sources on the project site and preclude sheep access. This
requirement has been added to the Specific Plan (at pp. 35-36) and also made enforceable through
the project Development Agreement.
This barrier fence will be designed to meet established MSHCP standards, with the final design and
location approved by the City in consultation with CDFW. The project also proposes a plant palette in
the western open space portions of the project and long the western perimeter that is consistent with
MSHCP Tables 4-112 and 4-113 with respect to native and prohibited plants.
Comment 13-i:
Prior to the adoption of the DEIR, CDFW requests completion surveys and a habitat use assessment of
Peninsular bighorn sheep, a California Fully Protected Species (Fish and Game Code § 3511), located within
the Project footprint and within offsite areas with the potential to be affected. The surveys and
assessment should address seasonal variations in use of the Project area. Focused species-specific surveys,
completed by a qualified biologist and conducted at the appropriate time of year and time of day when
the sensitive species are active or otherwise identifiable, are required. Acceptable species-specific survey
procedures should be developed in consultation with CDFW and the U.S. Fish and Wildlife Service. Note
that CDFW generally considers biological field assessments for wildlife to be valid for a one-year period,
and assessments for rare plants to be valid for a period of up to three years. Some aspects of the proposed
Project may warrant periodic updated surveys for certain sensitive taxa, particularly if the Project is
proposed to occur over a protracted time frame, or in phases, or if surveys are completed during periods
of drought.
Survey information and results in coordination with CDFW staff should be used to develop avoidance and
minimization measures to avoid Take of Peninsular bighorn sheep. Based on the survey results and historic
use of the Project site, Project modifications may be required to avoid Take of sheep.
Response 13-i:
The EIR has been modified to read that PBS that may be present on Coral Mountain but will not be
able to access the project development site due to the construction of the 8 -foot high sheep barrier
discussed in Response 13-h above (also see Draft EIR at p. 4.3-15). In addition, an assessment of
habitat has been completed by Dr. T. McGill (Appendix D.5), which confirms that habitat for PBS does
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not occur within the development site and that the proposed sheep barrier is an effective method to
avoid impacts to PBS.
Specifically, the perimeter fencing along Coral Mountain and the rest of the western project boundary
will be eight feet (8') high and will be designed and located to prevent PBS from accessing the
development and to avoid any risk of PBS entanglement. This perimeter fencing will ensure that the
project does not become an attractive nuisance to PBS. Please also see the Biological Resources
Topical Response in Section 2.2.2 of this Final EIR for a further discussion of the proposed sheep
barrier.
Comment 13-j:
Recreational Effects on Peninsular Bighorn Sheep
CDFW is concerned that the impacts of the increased human activity on Peninsular bighorn sheep and
other sensitive resources was not adequately addressed in the DEIR. The DEIR assumes no presence
of Peninsular bighorn sheep and therefore does not address edge effects on Essential Habitat for
Peninsular bighorn sheep. In the CVMSHCP, Species Objective 1d for Peninsular bighorn sheep is
"Ensure that any Development allowed does not fragment Essential Habitat, and that edge effects
from such Development are minimized." The Project is adjacent to Essential Habitat and the Santa
Rosa Mountains Habitat Wildlife Area. Addressing edge effects is a CVMSHCP requirement that has
not been adequately addressed and therefore the Permittee has not ensured that the Project
demonstrates compliance with the CVMSHCP.
The CEQA document describes Plan Area IV as 23.6 acres of natural open space for low -impact active
and passive recreational activities, including hiking, biking and rope and zipline courses. This open
space area is located adjacent to Coral Mountain, which has rock outcrops known to be used as
roosting habitat for several species of bats. Coral Mountain is also known to be used by Peninsular
bighorn sheep. Limited details are provided in the CEQA document on the types and locations of
proposed recreational infrastructure, e.g., multi -use trails, restroom facilities, trail and other
recreational lightning, etc., or the permitted recreational uses within the open space areas, and
enforcement plans.
Unauthorized public recreational use off trails by people, bikes, and dogs in sheep habitat within the
Santa Rosa mountains may impact sheep use of the habitat. The current lack of enforcement of trail
use and trail development in the adjacent conservation areas is creating undesirable conditions for
the Peninsular bighorn sheep (Colby and Botta 2016). Potential issues include startling of ewes and
Iambs foraging in washes by mountain bikes; off -leash dogs and dogs in areas that don't allow dogs
potentially chasing and harassing sheep; and creation of unauthorized trespass trails by user groups
that intrude into sensitive sheep habitat. While some recreationists observe the trail rules and keep
their dogs on leash, many people are observed not complying with the trail use regulations. The
Project should provide clear measures to avoid contributing to trespass issues and ensure a safe
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environment for PBS. CDFW recommends that inclusion of biological mitigation measures for sheep
that identify funding and resources for enforcing trail use rules which could include signage,
enforcement, public education, and removal of unauthorized trails.
Most of these measures will require enforcement to ensure they are enacted and properly followed
throughout the life of the Project. The trails, rope courses, and zipline may create an easy and
tempting access point for the residents into the open space areas. Without enforcement of trail use
rules within the Project's open space the adjacent habitat, Coral Mountain could become saturated
with unauthorized trails. Measures such as leash laws, Covenants, Conditions and Restriction for
invasive plants and pets, trail regulations, and fencing requirements require constant enforcement.
Response 13-j:
As described in Response 13-h, the project includes a barrier/perimeter fence that will separate the
PBS and other wildlife species from the project residents and pets. To ensure that the perimeter
fencing fully protects the PBS, the final design and location of the fencing along the western boundary
will be subject to City review and approval in consultation with CDFW. All project recreational areas,
including the segment of the public Desert Recreation District trail that will cross the open space in
the southwest portion of the project (Planning Area IV), will be located on the development side of
the sheep barrier, thus protecting any PBS or other wildlife using Coral Mountain from predation or
other threats from dogs and persons using the trail or the recreational amenities within the project.
The project is also required under the terms of the project Development Agreement to fully comply
with all CVMSHCP Land Use Adjacency Guidelines, even though no portion of the project occurs in or
adjacent to any CVMSHCP conservation area. In addition, the Specific Plan has been modified to
establish a restricted plan palette along the western portion of the project consistent with the
CVMSHCP restrictions, and the project Development Agreement requires that Covenants, Conditions
and Restrictions (CC&Rs) be recorded against all affected portions of the project site to ensure that
these plant palette restrictions are fully enforceable in perpetuity by the property owners'
association.
Comment 13-k:
CDFW requests that the City revise and recirculate the DEIR to analyze impacts to sheep, burrowing
owl, and bats prior to Project implementation and final approval. The level of significance should be
revised from "Less than significant" to "Significant" for biological resources unless the City provides
adequate analysis to the contrary. The Lead agency must commit itself to mitigation and either adopt
performance standard for future approval or analyze alternatives in detail. The strategy for identifying
and evaluating the mitigation should be identified and in place before the Project is initiated.
Response 13-k:
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The potential for impacts to Peninsular bighorn sheep, burrowing owl and bats have been fully
analyzed in the EIR, with the analysis contained in these Responses to Comments and the
modifications made to the project. All potential impacts to PBS will be avoided, and the addition of
the 8 -foot -high sheep barrier to the perimeter fencing does not constitute significant new information
that was not included in the Draft EIR. The modifications provided in the text, along with the addition
of project design features (the sheep barrier/fence and compliance with adjacency guidelines), will
assure that impacts to PBS are fully disclosed to the public, Planning Commission and City Council
prior to any decision being made on the project, and assure that no significant impacts to PBS will
occur as a result of the project. The conclusions of the Draft EIR have not changed and re -circulation
of the Draft EIR is not required or appropriate under CEQA Guidelines § 15088.5(a). As regards impacts
to burrowing owl and bats, please see Responses 13-o through 13-r below.
Comment 13-1:
The revised DEIR should provide clear details on recreational infrastructure and permitted
recreational activities; control of access to areas outside of the development; and enforcement
methods to ensure trespass, lighting, and noise does not affect adjacent sheep and bat roosting
habitat. The revised DEIR should identify who will be responsible for this enforcement and funding to
support enforcement of the land use adjacency mitigation measures to ensure they are properly
implemented throughout the life of the project. The CVMSHCP identifies a simple barrier fence as a
mitigation concept to separate PBS from lethal threats in urban environments. We request
coordination with CDFW to identify suitable locations for trails and fencing surrounding the property,
to keep both sheep and people in their respective areas. CDFW further requests that the City add a
mitigation measure for fencing along the boundaries of the property accessible to sheep to minimize
potential impacts to PBS from the project development.
Response 13-1:
As described in Responses 13-h and 13-j above, the project now includes a sheep barrier/perimeter
fence that will prevent PBS from entering the development and will prevent trespass from the project
site onto Coral Mountain and adjacent BLM open space from project residents and their pets, as well
as visitors using the public Desert Recreation District trial proposed to cross the southwestern portion
of the project. Also as explained in the Draft EIR and further explained in the Final EIR, the project's
lighting has been designed to avoid any light spillage off the project site, including onto Coral
Mountain, which has been confirmed with both computer modeling and an on-site lighting test (see
Appendices B.1 and B.2 to this EIR). In addition, Mitigation Measure BIO -4 requires a post -
construction lighting analysis to confirm that the actual Wave Basin lighting does not spill onto Coral
Mountain, before a certificate of occupancy for the Wave Basin will be issued. The Draft EIR also
confirms that the project will not generate construction or operational noise impacts to Coral
Mountain or other off-site locations (see, e.g., pp. 4.11-24 and 4.11-25). Potential noise impacts are
addressed further below, in response to Comment No. 13-q.
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Comment 13-m:
The Recovery Plan for Peninsular Bighorn Sheep identifies that fences should be constructed to
exclude bighorn sheep from urban areas where they may begin using urban sources of food and
water. Fences serve several functions including: "(1) separating bighorn sheep from potential threats
of urbanization (e.g., toxic plants, parasites, accidents, vector-borne diseases, traffic, herbicides,
pesticides, behavioral habituation), (2) controlling human and pet access to remaining bighorn sheep
habitat, (3) preventing bighorn sheep from becoming habituated to and dependent upon artificial
sources of food and water, and (4) modifying habituated behaviors and redirection into remaining
native habitat. Although fencing may be viewed as a last resort to other potential forms of aversive
conditioning, prudent planning dictates that mitigation be required to offset the likelihood of future
adverse effects (behavioral habituation and increased mortality rates) when new projects are
approved along the urban interface. Though actual fence construction could be contingent upon
future use by sheep and the ineffectiveness of other potential deterrents, the wherewithal,
responsibilities, and easements for fences should be determined and secured at the time of project
approval". CDFW requests the incorporation of eight additional measures to help protect bighorn
sheep from development effects:
BIO -[XX]: Project activities and infrastructure should be designed to avoid Take of Peninsular
bighorn sheep, a State fully protected species, which has the potential to be present within or
adjacent to the Project area. Peninsular bighorn sheep use Coral Mountain and the surrounding
conserved habitat within the Santa Rosa Wildlife Area for roaming, foraging, and lambing. To
ensure no Incidental Take of Peninsular bighorn sheep, the following measures are required:
1. A biological survey and assessment of year-round habitat use by Peninsular sheep will be
conducted by a qualified biologist, pre -approved by CDFW, prior to Project approval.
2. All recreational infrastructure and activities such as trails, rope courses, and zipline(s) shall
be contained within the development footprint. Trails and other recreational activities will
not lead into or encourage use of adjacent natural areas.
3. No plant species toxic to bighorn sheep, such as oleander (Nerium oleander), lantana
(Lantana sp.) and laurel cherry (Prunus sp.), shall be used for landscaping within or around
the development. Control and do not plant non-native vegetation, including grass, in the
development where it may attract or concentrate bighorn sheep or invade and degrade
bighorn sheep habitat (e.g., tamarisk, fountain grass). Use native vegetation in the
development landscaping. Along fenced sections of the urban interface, ornamental and
toxic plants should not extend over or through fences where they may be accessible to
browsing bighorn sheep. The Project will use Table 4-112: Coachella Valley Native Plants
Recommended for Landscaping of the CVMSHCP as guidance on a landscaping planting
palette.
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4. To prevent sheep from entering the Project site or human intrusion into sheep habitat,
fences will be placed along the western boundary of PA II and PA III including III -G (DEIR
Exhibit 1.2, pg. 1-8), and PA IV; and the southern edge of PA II, PA III, and PA IV development
site (Figure 2). A fencing plan and further avoidance and minimization measure shall be
developed in coordination with the Wildlife Agencies. Fences should be functionally
equivalent or better than fencing designs in the Recovery Plan, which are describes as 2.4
meters (8 feet) high and should not contain gaps in which bighorn sheep can be entangled.
Gaps should be 11 centimeters (4.3 inches) or less.
5. Intentional enticement of bighorn sheep onto private property shall be prohibited and
enforced using fines if necessary, including vegetation, mineral licks, or unfenced swimming
pools, ponds, or fountains upon which bighorn sheep may become dependent for water.
6. Construction of water bodies that may promote the breeding of midges (Culicoides sp.) shall
be prohibited. Water features should be designed to eliminate blue -tongue and other
vector-borne diseases by providing deeper water (over 0.9 meters [3 feet]), steeper slopes
(greater than 30 degrees), and if possible, rapidly fluctuating water levels, or other current
best practices. As needed, coordinate with local mosquito and vector control district to
ensure management of existing water bodies that may harbor vector species.
7. An educational program about the Peninsular bighorn sheep and their associated habitat
shall be implemented and maintained throughout the resort, open space, and low-density
community programs through the use of signage, pamphlets, and staff education. The
Education Program should inform the reason of why specific measures are being taken to
support recovery of Peninsular bighorn sheep. The Education Program should include the
ecology of Peninsular bighorn sheep, what threats this species is currently facing, and how
recovery actions will reduce these threats. This includes information that explains: (1) why
restrictions on toxic plants, fences, and pesticides are needed; (2) how artificial feeding of
coyotes could adversely affect bighorn sheep; and (3) how recreational activities may affect
sheep. The use of interpretive signs is encouraged.
8. Ensure funding for implementation, enforcement, and effectiveness assessment of the
above measures, for the life of the development, to help ensure protection of sheep and to
prevent trespass from the Project site into adjacent sheep habitat.
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Figure 2. Proposed Sheep fencing plan shown in blue outline on the edge of Project site.
Response 13-m:
Please see Responses 13-e through 13-1 above for a thorough discussion of the project features and
restrictions that assure that the project will not have any direct or indirect impacts on PBS. The
additional measures requested by the commenter are addressed individually below:
(1)
Dr. Tom McGill, a qualified biologist with substantial expertise concerning PBS, completed a
further PBS habitat assessment of the Project site and surrounding area, and confirmed that the
Project development site itself contains no suitable habitat for PBS, and also confirmed that PBS
have been tracked on Coral Mountain at times during the year because even though it is not
designated as a conservation area for PBS under the CVMSHCP, it does provide limited foraging
habitat and escape cover. See Dr. McGill Memo dated November 3, 2021, attached in Appendix
D.5 to the Final EIR, at p. 2. Dr. McGill also recommends including the following CVMSHCP
Avoidance and Minimization Measures and Land Use Adjacency Guidelines in the project
conditions of approval:
(i) Avoid use of the toxic or invasive plants listed in Table 4-113 of the CVMSHCP along the
western boundary of the project, adjacent to Coral Mountain and other BLM open space;
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(ii) Stormwater systems and project features that use chemicals or other toxic substances shall
be designed to prevent the release into conservation areas of toxins, chemicals, petroleum
products, exotic plant material or other elements that might degrade or harm biological
resources;
(iii) Lighting shall be shielded and directed toward developed areas to minimize the effect of
lighting adjacent to or on conservation areas;
(iv) Development adjacent to conservation areas that generate noise in excess of 75 dBA shall
incorporate setbacks, berms or walls to minimize the effects of noise on conservation areas;
(v) The project shall incorporate barriers to minimize unauthorized public access, domestic
animals, predators, illegal trespass or dumping in a conservation area, which is accomplished by
the Conceptual PBS Barrier Plan attached as Exhibit 2 to the Dr. McGill Memo; and
(vi) Land development activities, including manufactured slopes, shall not extend into
conservation areas.
Based on this habitat assessment, and the project's incorporation of the additional
recommendations from Dr. McGill summarized above and discussed in Response Nos. 13-e
through 13-1 above, and Nos. 13-q and 13-r below, no further surveys or habitat assessments
are warranted or necessary to determine the potential for impacts to PBS or appropriate
mitigation to avoid potential impacts.
(2) As explained in more detail in Response 13-j above, all recreational infrastructure and activities,
including the on-site portion of the regional trail connection that Desert Recreation District
intends to construct in the area, will all be located on the development side of the sheep barrier,
thus satisfying CDFW's request. These requirements will be incorporated into, and made
enforceable through, the project Development Agreement and/or conditions of approval.
(3)
As discussed in Response 13-d above, and in Dr. McGill's recommendations, the Specific Plan
has been revised to incorporate a restricted plant palette along the western boundary of the
project in full compliance with the Land Use Adjacency Guidelines in the CVMSHCP. This
restricted plant palette will be enforceable through both the Development Agreement and the
CC&Rs recorded against the property to ensure compliance for the life of the project.
(4) Please see Responses 13-e and 13-h, above. The project is incorporating a sheep
barrier/perimeter fence along the boundaries cited by the commenter, that is consistent with
the fencing design specified in the Recovery Plan and CVMSHCP, including a height of 8 feet and
containing no gaps in excess of 4.3 inches to avoid sheep entanglement, with the final location
and design to be approved by the City in consultation with CDFW. This requirement will be
incorporated into the Specific Plan and made enforceable through the project Development
Agreement and/or conditions of approval.
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(5)
Please see Responses 13-e and 13-h, above. The implementation of the sheep barrier along the
west and south property lines will preclude sheep enticement.
(6) To address any concerns regarding mosquitos and vector-borne diseases, Mitigation Measure
BIO -9 has been added to the EIR, which provides as follows: BIO -9: Onsite lakes will be designed
and constructed by industry professionals and will incorporate proper aeration, circulation and
filtration to maintain a balanced lake ecosystem. Lakes will be stocked with beneficial fish and
plant species. Limited chemical applications will be utilized as necessary. Ongoing maintenance
will ensure that onsite lakes function properly to control any invasive species or other nuisance
conditions.
(7)
The applicant is working with the Desert Recreation District on developing an educational
program in connection with the regional trail connection within the project site. To ensure
implementation of the intended educational programming, the EIR is being revised to
incorporate the requested measure as Mitigation Measure BIO -10.
(8) Please see Responses 13-e and 13-h above, as well as the preceding portions of this Response
13-m. The Development Agreement and CC&Rs will be recorded against all private property in
the project to ensure that the plant palette and other restrictions are fully enforceable for the
life of the project. Additional mitigation is not required.
Comment 13-n:
Fuel Modification
The DEIR states that the Project is not within an area mapped as "very high, high, or moderate fire
hazard severity zones, therefore, no impacts are anticipated" by the development. While CDFW
recognizes that the area is not classified as being within a fire hazard area, we are concerned that the
Project's design puts an additional burden on public lands to operate as defensible space rather than
include the defensible space within the development footprint. According to Public Resource Code
4291 the development should include a minimum of 100 feet of defensible space within the
development footprint. Additionally, County of Riverside Ordinance NO. 695, Section 3, states that:
"(1) a one hundred (100) foot wide strip of land at the boundary of an unimproved parcel
adjacent to a roadway; and/or
(2) a one hundred (100) foot wide strip of land around structure(s) located on an adjacent
improved parcel (some or all of this clearance may be required on the unimproved parcel
depending upon the location of the structure on the improved parcel).
The County Fire Chief or his or her designee may require more than a one hundred (100) foot
width or less than a one hundred (100) foot width for the protection of public health, safety
or welfare or the environment."
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As development increases within the area near or adjacent to conservation or public natural lands,
the risk of wildfire increases and the need for defensible space rises. Additionally, climate change has
increased the frequency and duration in which wildfire season occurs (Li and Banerjee, 2021). As the
climate continues to change and development continues to encroach upon natural resources,
wildfires will continue to increase even in areas not designated as high fire risk. Thus, CDFW requests
the incorporation of the following measure to help protect natural resources on public open space
and conservation lands from development effects:
BIO -[XX]: With respect to defensible space and impacts to biological resources, the Project
shall consult with the Riverside County Fire Department and fully describe and identify the
location, acreage, and composition of defensible space within the proposed Project
footprint. Base on the consultation the Project shall be designed so that impacts associated
with defensible space (fuel modification, fire breaks, etc.) shall not be transferred to
adjacent open space or conservation lands.
Response 13-n:
The project is subject to Riverside County Ordinance No. 695. The Notice of Preparation and Notice
of Availability of the Draft EIR were distributed to the Riverside County Fire Department, and they will
continue to be consulted through the development process. No brush clearance requirements have
been requested or imposed on the project because it is not in a fire hazard area. On-site fire hazards
are low, because of the lack of substantial vegetation on the site. The development of landscaped
areas and homes will reduce the potential for on-site fire hazards, especially since homes will be
sprinklered, consistent with the requirements of the Building Code. No significant impact occurs, and
no mitigation measure is required. However, at the request of CDFW, the City will impose a condition
of approval stating that if any brush clearance obligation is imposed on any implementing project
approvals in the future, such brush clearance will not be permitted on BLM property.
Comment 13-o:
Burrowing Owls
A project -specific biology report in the DEIR identifies suitable burrowing habitat within the Project
area. To increase the probability of detecting burrows occupied by burrowing owls, multiple surveys
should be conducted depending on the proposed start of construction activities and how it coincides
with the burrowing owl breeding or non -breeding seasons. To minimize the chance of Project
activities resulting in Take of nesting burrowing owls, CDFW recommends that the City revise MM
BIO -1 and condition the measure to include the following (edits are in bold and strikcthrough):
BIO -1: A -Burrowing owl cl aranco surveys shall be performed by a qualified biologist, pre -
approved by the California Department of Fish and Wildlife, not more than 30 days prior to
any site disturbance activities :. _ _ :, .. _ :, - _ _ _ . A minimum of two
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surveys, occurring at least three weeks apart, shall be completed in advance of any site
disturbance activities. If disturbance activities are expected to start during the burrowing
owl breeding season, three surveys shall be completed. The final burrowing owl survey shall
be completed within three days prior to initiation of any site disturbance activities. The pre -
construction survey shall be conducted following guidelines in the CDFW 2012, Staff Report
on Burrowing Owl Mitigation. Is required to use accepted protocol (as determined CDFW).
Prior to construction, a qualified biologist will survey the construction area and an area up to
500 feet 150 meters outside the Project limits for burrows that could be used by burrowing
owls. If the burrow is determined to be occupied, the burrow will be flagged, and a 160 foot
200 -meter diameter buffer will be established during non -breeding season or a 250 foot 500 -
meter diameter buffer during the breeding season. The buffer area will be staked and flagged.
A list of avoidance and minimization measures such as, but not limited to, the use of hay
bales, daily biological monitoring, and trail cameras shall be provided to CDFW for review
prior to any ground disturbance. No development activities will be permitted within the
buffer until the young are no longer dependent on the burrow and have left the burrow. For#
the burrows+sfound to be unoccupied, the qualified biologist will coordinate with CDFW on
the methods to make the burrows will be made inaccessible to owls, and construction may
proceed. If either a nesting or escape burrow is occupied and impacts to the owl(s) cannot be
avoided, a Burrowing Owl Relocation Plan will be developed and reviewed by the Wildlife
Agencies prior to the relocation of owls. Owls shall be relocated pursuant to accepted Wildlife
Agency protocols. Determination of the appropriate method of relocation, such as
eviction/passive relocation or active relocation, shall be based on the specific site conditions
(e.g., distance to nearest suitable habitat and presence of burrow within that habitat) in
coordination with the Wildlife Agencies. If burrowing owls are observed with the Project site
during construction activities, CDFW shall be notified immediately and provided with
proposed avoidance and minimization measures for CDFW to review.
Response 13-o:
This comment requests revisions to the mitigation measure requiring pre -construction burrowing owl
surveys in excess of the requirements of the CVMSHCP. The requirements of the CVMSCP are those
to which the City has committed as a permittee of the CVMSHCP. As a result, the mitigation measure
has been amended consistent with those requirements, as follows:
Mitigation Measure BIO -1:
Burrowing owl surveys shall be performed by a qualified biologist approved by the City prior
to any site disturbance activities. A minimum of two surveys, occurring at least three weeks
apart, shall be completed in advance of any site disturbance activities. If disturbance
activities are expected to start during the burrowing owl breeding season, three surveys
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shall be completed. The final burrowing owl survey shall be completed within three days
prior to initiation of any site disturbance activities. The pre -construction survey shall be
conducted following accepted protocol and the requirements specified in the CVMSHCP (see
pp. 4-166 & 4-167). Prior to construction, a qualified biologist will survey the construction
area and an area 500 feet outside the project limits for burrows that could be used by
burrowing owls. If the burrow is determined to be occupied, the burrow will be flagged, and
a 160 foot diameter buffer will be established during non -breeding season or a 250 foot
diameter buffer during the breeding season. The buffer area will be staked and flagged. No
development activities will be permitted within the buffer until the young are no longer
dependent on the burrow and have left the burrow.
If the burrow is found to be unoccupied, the burrow will be made inaccessible to owls, and
construction may proceed. If either a nesting or escape burrow is occupied, owls shall be
relocated pursuant to accepted Wildlife Agency protocols. Determination of the appropriate
method of relocation, such as eviction/passive relocation or active relocation, shall be based
on the specific site conditions (e.g., distance to nearest suitable habitat and presence of
burrows within that habitat) in coordination with the Wildlife Agencies. If burrowing owls
are observed within the Project site during construction activities, CDFW shall be notified
immediately and provided with proposed avoidance and minimization measures, consistent
with the requirements of the CVMSHCP.
The amendment to the mitigation measure is provided for clarification of CVMSHCP requirements,
and does not represent new information, as the DEIR described the requirements of the CVMSHCP
and the City's responsibilities in implementing its provisions. The modification also does not represent
any increase in the significance of the impacts on burrowing owls, as these potential impacts were
fully disclosed in the DEIR. As a result, the modification of the mitigation measure does not change
the findings and conclusions of the DEIR, and does not provide new information which requires review
by the public or the City's decision makers, and recirculation is not required.
Comment 13-p:
Nesting Birds
Regarding the protection of nesting birds, it is the Project proponent's responsibility to avoid Take of
all nesting birds. The timing of birds starting and finishing nesting activities is variable from year to
year based on the species, rainfall conditions, shifts in local climate conditions, and other factors.
CDFW recommends that qualified biologist(s) are pre -approved by CDFW to confirm they have the
experience necessary to fulfill their biological monitoring responsibilities. Additionally, biological
monitoring activities are required for the duration of construction activities. CDFW recommends that
at minimum, the City revise MM BIO -6 and conditions the Project to include the following (edits are
in bold and strike -through):
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BIO -6: To ensure compliance with California Fish and Game Code and the MBTA and to avoid
potential impacts to nesting birds, vegetation removal and ground -disturbing activities shall
be conducted outside the general bird nesting season (January 15 through August 31). Any
vegetation removal, ground disturbance, and/or construction activities that occur during the
nesting season will require that all suitable habitats be thoroughly surveyed for the presence
of nesting birds by a qualified biologist that is pre -approved by CDFW. Prior to
commencement of clearing, a qualified biologist shall conduct preconstruction surveys within
14 days and repeated 3 days prior to ground disturbing activities. If any active nests are
detected, a buffer of 300 feet (500 feet for raptors) around the nest adjacent to construction
will be delineated, flagged, and avoided until the nesting cycle is complete. The buffer may be
modified and/or other recommendations proposed as determined appropriate by the
biologist to minimize impacts. During construction activities, the qualified biologist shall
continue biological monitoring activities at a frequency recommended by the qualified
biologist using their best professional judgment, or as otherwise directed by the Wildlife
Agencies. If nesting birds are detected, avoidance and minimization measures may be
adjusted and construction activities stopped or redirected by the qualified biologist using
their best professional judgement as otherwise directed by the Wildlife Agencies to avoid
Take of nesting birds.
Response 13-p:
The commenter's concerns are noted. The revisions to the mitigation measure provide clarification
to the requirements of the MBTA. Mitigation Measure BIO -6 will be revised as requested. The
amendment to the mitigation measure is provided for clarification of the applicable requirements of
the MBTA and the California Fish & Game Code, and does not represent new information, as the DEIR
described these requirements and the City's and applicant's responsibilities. The modification also
does not represent any increase in the significance of the impacts on nesting birds, as these potential
impacts were fully disclosed in the DEIR. As a result, the modification of the mitigation measure does
not change the findings and conclusions of the DEIR, and does not provide new information which
requires review by the public or the City's decision makers, and recirculation is not required.
Comment 13-q:
Noise
The noise study in the CEQA document identifies a significant noise threshold of 85 dBH and finds
that noise levels associated with the construction and operations of the Project would be close to,
but not exceed, the noise threshold. CDFW requests the incorporation of the following measure to
help protect wildlife from development impacts:
BIO -[XX]: To reduce noise -related impacts to wildlife using Coral Mountain, the Project shall
continue taking noise level measurements during both Project construction and post -
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construction operations to determine if noise levels exceed thresholds outlined in the CEQA
document and inform if additional avoidance and minimization measures are required. To
protect wildlife using Coral Mountain, the noise threshold affecting this area shall be
reduced to 75 dBA as determined appropriate in the Land Use Adjacency Guidelines in
CVMSHCP Section 4.5. If noise levels exceed this threshold, the Project shall make changes
to their operations and/or adopt other minimization measures to reduce noise impacts
below 75 dBA to minimize noise -related impacts on wildlife using Coral Mountain.
Response 13-q:
The noise study conducted for the EIR determined that highest construction noise levels on-site in
the location nearest Coral Mountain (P3) could reach 82.3 dBA and could reach up to 68.6 dBA at the
nearest off-site location. See Draft EIR at pp. 4.11-32 through 4.11-35. The distance from Coral
Mountain to the nearest construction area is approximately 100 feet. Construction noise will
therefore not exceed 70 dBA at Coral Mountain. As described in the noise study (Appendices K-1 and
K.2 of the DEIR), and on pages 4.11-44 through 4.11-49 and Table 4.11-25 of the DEIR, operational
noise impacts are not expected to exceed 62 dBA at the on-site location nearest Coral Mountain,
which is Receiver P3, located approximately 400-500 feet away. Based on standard noise attenuation
principles related to noise and distance, as described on page 4.11-33 of the DEIR, the noise level will
not exceed 60 dBA at any of the offsite receiver locations (see Table 4.11-25 on page 4.11-48 of the
Draft EIR) or at Coral Mountain at its nearest point to project activities. Therefore, the project's
operations will be well below the CVMSHCP's 75 dBA threshold at Coral Mountain. Although the DEIR
demonstrates that noise levels during construction will also be below this threshold, in order to assure
that no impact to wildlife utilizing Coral Mountain occurs during the construction period, Mitigation
Measure BIO -7 is added, as follows:
Mitigation Measure BIO -7:
To ensure that the project will avoid any significant construction noise impacts on wildlife
using Coral Mountain, noise monitoring will occur for all construction activities using heavy
equipment within 150 feet of the base of Coral Mountain. If noise levels exceed 75 dBA,
construction operational changes or other project modifications shall be made, as directed
by the project biologist to reduce the noise levels at Coral Mountain to below 75 dBA.
Comment 13-r:
Lighting
The CEQA document includes an analysis of lighting with a focus on impacts to aesthetics. A significant
source of artificial nighttime lighting with the potential to impact wildlife using Coral Mountain (e.g.,
PBS, bats, etc.) comes from lighting associated with the Wave Basin, which includes seventeen, 80 -
foot -high light poles. Further, onsite lightning is planned within PA IV, the open space area adjacent
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to Coral Mountain. Although the CEQA document indicates that all lightning will be shielded and
directed away from wildlife areas, CDFW recommends that additional lightning analysis during Project
construction and operations is needed to determine that lightning impacts to wildlife using Coral
Mountain will be less than significant. To determine if artificial nighttime lighting associated with
Project construction and operations will result in minimal to no glare (500 or less candela) to all areas
of Coral Mountain, CDFW recommends that lighting and glare impacts continue to be evaluated
during both Project construction and operations. CDFW requests the inclusion of the following new
measures in the DEIR:
BIO -[XX]: To reduce nighttime artificial lighting -related impacts to wildlife using Coral
Mountain, the Project shall continue taking lightning measurements during both Project
construction and post -construction operations to determine impacts of nighttime artificial
lightning on Coral Mountain and the wildlife it supports. To protect wildlife using Coral
Mountain, project construction and operations shall result in no to minimal glare (500 or
less candela) to all areas of Coral Mountain. If light or glare impacts to Coral Mountain
exceed this threshold, the Project shall make changes to their operations and/or adopt
landscape shielding, dimming, lighting curfews or other appropriate measures that result in
the Project causing minimal to no glare to all areas of Coral Mountain.
Response 13-r:
In addition to the lighting impacts that were addressed in the aesthetics discussion of the DEIR, an
analysis of the potential impacts of lighting on wildlife was conducted by the project biologist (please
see Appendix D.1 at p. 11 and pages 4.3-18 and 4.3-23) who included a mitigation measure to ensure
that project lighting would not impact bats roosting in Coral Mountain. Mitigation Measure BIO -4
requires a post -construction lighting study be completed prior to issuance of a certificate of
occupancy for the Wave Basin to ensure no overspill of light or glare onto Coral Mountain. Clarifying
edits to Mitigation Measure BIO -4 have been recommended by the project biologist and the revised
measure provides as follows:
Mitigation Measure BIO -4:
To avoid impacts to roosting bats from the installation of new light fixtures associated with
the proposed development, all lighting fixtures shall have light shields or similar devices (i.e.,
dark sky compliant lighting) installed to ensure that there is no light trespass onto Coral
Mountain and surrounding open space. A supplemental light study will be performed to
collect nighttime lighting measurements and confirm that no light trespass onto Coral
Mountain is occurring; this will be submitted for City approval prior to issuance of any permit
for occupancy or use of the Wave Basin.
In addition, the lighting study completed for the proposed Wave Basin lighting system determined
that light levels are cut-off in the immediate vicinity of the Wave Basin planning area, and that light
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levels will drop to 0.01 foot candles or below at least 375 feet from the nearest portion of Coral
Mountain. Please see the Light and Glare Topical Response in Section 2.2.1, above, including the
lighting contour exhibit.
Comment 13-s:
Land Ownership
A portion of the property appears to be owned by the Bureau of Land Management (BLM) and is a
part of the Santa Rosa Mountains Wildlife Habitat Area which is jointly managed by BLM and CDFW
(BLM and CDFG 1980). This is an area having permanent protection from conversion of natural land
cover and a management plan for the preservation of the wildlife resources and their habitats. The
Santa Rosa Mountains Habitat Management Plan was developed and implemented under the Sikes
Act of October 18, 1974 (PL 93-452). Please clarify in the DEIR if a portion of the Project is on or
adjacent to the Santa Rosa Mountains Wildlife Habitat Area, owned by BLM, and identify what
mitigation measures will be implemented to maintain the natural conditions of the area for wildlife
resources. Please provide information in the DEIR on any coordination with BLM and CDFW on use of
the Project site and how that may affect the Santa Rosa Mountains Wildlife Habitat Area.
State Regulatory Environment
In the State Regulatory Environment section (p. 4.3-3), the DEIR fails to identify state regulations that
are applicable to the Project including: Natural Community Conservation Protection Act (Fish & G.
Code Sections 2800 et seq.), Lake and Streambed Agreements (Fish & G. Code Section 1600 et seq.);
Fully Protected Species (Fish & G. Code Section 4700), and CEQA. Please revise the DEIR to identify
the above regulations and how they apply to this Project.
Response 13-s:
No portion of the project extends onto the adjacent BLM land, and all BLM land will be separated
from the project site by the sheep barrier/perimeter fence described in Responses 13-e and 13-h.
Because the project occurs entirely on privately held land, and the project will be physically separated
from federal lands by a barrier fence, and the DEIR requires that the project comply with CVMSHCP
Land Use Adjacency Guidelines, the impacts associated with federal land remain, as described in the
DEIR, less than significant with the implementation of Mitigation Measures BIO -2 through BIO -6.
Those impacts have been thoroughly analyzed, and no additional impacts have been identified by the
commenter.
Comment 13-t:
Drought -tolerant Landscaping
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California is experiencing one of the most severe droughts on record. To ameliorate the water
demands of this Project, CDFW recommends incorporation of water -wise concepts in project
landscape design plans. In particular, CDFW recommends xeriscaping with locally native California
species, and installing water -efficient and targeted irrigation systems (such as drip irrigation). Local
water agencies/districts, and resource conservation districts in your area may be able to provide
information on plant nurseries that carry locally native species, and some facilities display drought -
tolerant locally native species demonstration gardens. Information on drought -tolerant landscaping
and water -efficient irrigation systems is available on California's Save our Water website:
http://saveourwater.com/what-you-can-do/tips/landscaping/
Response 13-t:
The commenter's concerns regarding water efficiency are noted. As shown in the plant palette set
forth in the Specific Plan, the project makes extensive use of native, drought -tolerant landscaping,
consistent with the CVMSHCP Land Use Adjacency Guidelines (compare Specific Plan plant palette
(attached to Dr. McGill Memo in Appendix D.5 to this Final EIR) with the recommended species in
CVMSHCP Table 4-112). In addition, the project is subject to the water use restrictions in the
applicable landscape ordinances adopted by CVWD (Ordinance No. 1302.5) and the City of La Quinta
(see Chapter 8.13 of the La Quinta Municipal Code).
Comment 13-u:
Environmental Data
CEQA requires that information developed in environmental impact reports and negative declarations
be incorporated into a database which may be used to make subsequent or supplemental
environmental determinations (Pub. Resources Code, § 21003, subd. (e)). Accordingly, please report
any special -status species and natural communities detected during Project surveys to the California
Natural Diversity Database (CNDDB). The CNNDB field survey form can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Submitting-Data. The completed form can be submitted
online or mailed electronically to CNDDB at the following email address: CNDDB@wildlife.ca.gov.
Response 13-u:
The City thanks the Department for this information, and will continue to encourage project biologists
to comply with reporting requirements under PRC 21003(e).
Comment 13-v:
CDFW Conclusions and Further Coordination
CDFW appreciates the opportunity to comment on the Coral Mountain Resort Project to assist in
identifying and mitigating Project impacts on biological resources. Our review and analysis of the DEIR
identified a number of significant new Project impacts and provides corresponding mitigation and
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minimization measures, as described above, which would clearly lessen significant project impacts on
the biological resources in the area. Therefore, CDFW requests that the City of La Quinta revise and
recirculate the DEIR, for disclosure to the public, once the requested additional analyses have been
prepared and the additional mitigation and minimization measures have been added to the Project,
and all of these substantial modifications have been documented in the revised Draft EIR for review
and comment by the citizens of California and interested public agencies.
CDFW personnel are available for consultation regarding biological resources and strategies to
minimize impacts. We request a meeting to discuss our comments at your earliest convenience.
Questions regarding this letter or further coordination should be directed to Carly Beck at
carly.beck@wildlife.ca.gov.
Response 13-v:
The City, CDFW and Dr. McGill met on September 29, 2021 and again on January 25, 2022, and
discussed the issues raised in this letter, the analysis conducted by Dr. McGill, and the measures
described above to address those issues. These measures include installation of a sheep
barrier/perimeter fence in conformance with the standards specified in the CVMSHCP, and the
project's compliance with the CVMSHCP Land Use Adjacency Guidelines even though the project is
not adjacent to a conservation area and thus would not otherwise be subject those requirements.
With implementation of these measures, and the inclusion of a sheep barrier in the Specific Plan
document, impacts to biological resources are reduced to less than significant levels, consistent with
the findings of the DEIR.
As explained above, re -circulation of the Draft EIR is not required because the project revisions and
clarifications made to the EIR to address the CDFW comments do not contain any significant new
information as that phrase is defined in CEQA Guidelines Section 15088.5. Specifically, none of the
information added to the Final EIR "deprives the public of a meaningful opportunity to comment upon
a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such
an effect" nor does it show any new or substantially more severe environmental effects than were
disclosed in the Draft EIR. Rather, the CDFW comments, and the responses and Draft EIR revisions
discussed above, demonstrate that the Draft EIR adequately disclosed the project's potential to
impact Peninsular bighorn sheep, and that the project will not have any significant adverse effect on
this federally endangered and California Fully Protected Species. At the request of CDFW, the
applicant has agreed to modify the project to include additional measures to ensure that there will
be no impacts to this species, including an 8 -foot -high sheep barrier along the western boundary of
the project site to separate all project development and activities from Coral Mountain and other
adjacent BLM open space.
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Comment Letter No. 14: Bighorn Institute
Name: James R. DeForge, Executive Director
Date: August 3, 2021
Affiliation: Bighorn Institute
Address: P.O. Box 262
Palm Desert CA, 92261
Comment 14-a:
We are providing comments for the Draft EIR for Coral Mountain Resort (SCH#2021020310), as it
pertains to the endangered Peninsular bighorn sheep (Ovis Canadensis nelsonii). We are primarily
concerned with the likelihood of bighorn sheep being attracted to and accessing Coral Mountain
Resort as a means of artificial food and water if the project is built.
Bighorn Institute has documented 35 known urban -related Peninsular bighorn deaths on or near four
La Quinta golf courses (Traditions, SilverRock, PGA West and The Quarry) and Lake Cahuilla since
2012. These bighorn deaths are a result of sheep being attracted down to the grass and water features
(i.e., artificial food and water sources). Despite the DEIR declaring the project location as non -habitat
for bighorn sheep, there is a real potential for attracting bighorn sheep from adjacent areas,
particularly if and when the required La Quinta fence is constructed and the sheep are pushed back
into their natural habitat. As such, we [Bighorn Institute] strongly recommend this project be fenced
prior to construction with fencing approved in the Recovery Plan for bighorn in Peninsular Ranges
(i.e., an 8 -foot chain-link fence). The City of Rancho Mirage had similar urban -related bighorn issues
and in 2002, a 4 1/2 mile long, 8ft high chain-link fence was built there. It was completely eliminated
urban -related bighorn deaths and is promoting recovery of this species.
Response 14-a:
The City thanks the Bighorn Institute for participating in the review of the Draft EIR. Please see the
Biological Resources Topical Response in Section 2.2.2. The project has been modified to include an
8 -foot sheep barrier to be located along the western and southwestern property boundary, in
addition to the 6 -foot perimeter wall which will surround the project. The sheep barrier is to consist
of 8 -foot -high fencing as shown in the approved Coachella Valley Conservation Commission (CVCC)
"PBS Barrier Project". Please see Figure 13 in the Specific Plan, Conceptual PBS Barrier Plan, which is
copied above at page 2-15. The final design and location of the 8 -foot -high sheep barrier fencing will
be subject to approval by the City, in consultation with CDFW.
Comment 14-b:
We also recommend no vegetation be planted near the project fence to attract the sheep.
Response 14-b:
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The project proposes desert landscape throughout the site. Areas adjacent to Coral Mountain
(southwest portions of the site) will be maintained as open space with native landscaping that is
consistent with the recommended plant species shown in Table 4-112 of the CVMSHCP.
Poisonous or toxic plants (such as dwarf Nerium oleander) have been removed from the landscape
palette for the proposed project. Additionally, "Prohibited Invasive Ornamental Plants" are excluded
from use along the western boundary. These areas will be subject to landscape palette restrictions
consistent with the CVMSHCP Adjacency Guidelines (See Tables 4-112 for recommended species and
Table 4-113 for prohibited species). Consistency with the CVMSHCP Adjacency Requirements will
avoid harm to any bighorn sheep in the area. Project landscape plans will be reviewed by the City of
La Quinta prior to development, and will be enforceable for the life of the project through the
Covenants, Conditions & Restrictions (CC&Rs) that will be recorded against the common areas and
private lots.
Comment 14-c:
Finally, we are concerned about the water usage for this project, particularly the wave pool and other
water features. We are in the grips of another drought year so it seems irresponsible and unnecessary
to build a project so focused on using such a valuable resource. Wildlife, such as Peninsular bighorn,
struggle to have enough available water to survive during droughts and this project could contribute
to the water shortage.
Thank you for the opportunity to provide comments on this project.
Response 14-c:
Please see the topical response on water resource provided in the Water Resources Topical Response
in Section 2.2.3 of this Final EIR above (at pp. 2-16 — 2-27) for a discussion of the project's proposed
water use and the adequacy of water supplies. Additional analysis of water resources is also discussed
in Section 4.9, Hydrology and Water Quality, and 4.15, Utilities and Service Systems, of the Draft
EIR. Please refer to Sections 4.9 and 4.15 for full analysis of project -related water consumption.
Specifically as it relates to bighorn sheep, water sources are found in the mountain ranges up gradient
and to the west of the property. These sources include natural and manmade sources and are located
primarily outside of the Indio Subbasin that serves the project. These water sources will remain
unaffected by the proposed project, and other projects on the valley floor. This project is also required
to contribute fees for groundwater recharge for the Indio Subbasin.
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Public Comments — Area Residents
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Comment Letter No. 15: Anne and Ron Smith
Date: June 21, 2021
Affiliation: Area Resident
Comment 15-a:
I am writing to urge you to please DENY approval of the Wave Park.
We moved here just a year ago because we were impressed by the beauty of La Quinta, and the
tranquility of the neighborhood of Trilogy. We love being able to enjoy the quiet here, and especially
enjoy stargazing from our backyard at night as we have so little light pollution.
Response 15-a:
The commenter's objection to the project is noted. Responses to Comments 15-b through 15-d
address specific environmental issues below.
Comment 15-b:
The Wave Park, with its constant noise and blaring stadium lights at night, threaten to destroy the
very reason we moved to La Quinta. We are already discussing the possibility of putting our home on
the market because of this proposed project. We did not move here to live next to an amusement
park for the very rich that would destroy the reason we moved from a high density area. And we do
feel it would be terrible for our home value.
Response 15-b:
Please see Topical Response Section 2.2.4, Noise, and Section 2.2.1, Light and Glare, above. In
addition, the Draft EIR discusses and analyzed the potential impacts of project -generated noise and
lights in Section 4.11, Noise, and Section 4.1, Aesthetics, respectively. Within Section 4.11, noise
impacts associated with project -related construction and operational activities were discussed.
Findings within this section were based on technical reports completed for the project by a noise
engineer (see Noise Study and Noise Memo), which analyzed the actual noise levels that will be
generated by Wave Basin operations as well as comparable noise levels at other existing resort pool,
recreational park, and commercial uses. Per the findings of the technical reports and Draft EIR,
project -related construction and operational impacts to noise were concluded to be less than
significant with the implementation of mitigation measures. As described above, the project will not
exceed noise thresholds established by the City in its General Plan and Municipal Code. The Draft EIR
correctly determined that impacts of project operation would not exceed those thresholds, as shown
in Tables 4.11-16 (construction noise), 4.11-17-4.11-20 (traffic noise), 4.11-23 (interior noise levels),
and 4.11-25 — 4.11-26 (operational noise).
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Section 4.1 (discussion d.) analyzed the lighting proposed for the project, including the 80 -foot light
fixtures proposed surrounding the Wave Basin. In order to analyze whether these light fixtures would
impact the surrounding area, a photometric plan, which illustrates the foot-candles associated with
the fixtures, was provided by Musco Lighting. As described on page 4.1-62, the lights associated with
the Wave Basin would be limited to the evening hours of dusk to 10:00 p.m., consistent with La Quinta
Municipal Code Section 9.100.150 for sports facilities. This is Mitigation Measure AES -3 in the Draft
EIR. No nighttime activity would occur. The Draft EIR concluded that impacts associated with the light
fixtures are reduced to less than significant levels.
The commenter's concerns regarding changes in the area of their residence is noted. However,
according to CEQA Guidelines Section 15064(e), economic and social changes resulting from a project
are not part of the effects on the environment studied in an environmental document.
Comment 15-c:
Even more important than anything else, though, is the unmistakable, overwhelming evidence of
serious unprecedented drought in the west. It is too scary and serious to ignore. All the lakes and
reservoirs in the state are at disastrously low levels. This proposed man made lake would steal from
our drinking water. It's just a ridiculous and incredibly harmful idea at this time in history. The heat
and winds will evaporate huge amounts of potable water. I know that if I voted to approve something
like this, I would not be able to sleep at night knowing the harm I'd be doing to our environment, and
endangering people -- farmers, animals -- who desperately need that water for real life needs.
Response 15-c:
Please consult the Water Resources Topical Response in Section 2.2.3, as well as Section 4.9,
Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems, of the Draft EIR. The
Coachella Valley Water District (CVWD) approved the project -specific Water Supply
Assessment/Water Supply Verification (WSA/WSV) determining that sufficient water supplies exist,
or will exist based on current water planning assumptions, to meet the projected demands of the
proposed project as well as the current and future projected water demands within CVWD's service
area, including changes in supply associated with long term drought and climate change.
To address the commenter's concern regarding evaporation of water used for the project,
evapotranspiration (Eto) was taken into account when calculating the outdoor water demand for the
project (please see Section 2.2.3 above, pages 22-23 of the WSA/WSV attached to the Draft EIR as
Appendix M. The analysis in the EIR correctly calculated the Eto, and evapotranspiration has been
accurately disclosed.
Operation of the Wave Basin will account for approximately 14.9 percent of the project's total annual
outdoor water, and 12.47 percent of total project water demand. Water conservation methods
implemented by the project include the installation and maintenance of efficient and drip irrigation
systems for project landscape, the use of native plant materials and other drought tolerant plants,
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and the use of low -flush toilets and water -conserving showerheads and faucets. These methods will
reduce indoor and outdoor water consumption by the project.
This comment also asserts that the project would "steal from our drinking water," but in fact, the
water necessary for the Wave Basin operations, and the other uses proposed for the project, are
already included in CVWD's plans to serve future development. CVWD's long-range planning
documents confirm that it has adequate water supplies for all current and planned future uses, as
discussed in more detail in Section 2.2.3, Water Resources Topical Response, above.
Comment 15-d:
I have read that 4 wave parks are in various processes of approval in the Coachella Valley. It seems
preposterous that there would be this much demand for this kind of project. And if there is, why put
it in an area zone for residential development? And what will happen if this project is abandoned mid
project for lack of funds? What an awful eyesore will remain. There's only ever been one other wave
park in the area, and it failed. Four wave parks?!?
Please, please, listen to concerned citizens. Listen to your conscience and do the right thing and DO
NOT APPROVE THIS PROJECT.
Response 15-d:
The commenter's concern regarding 4 potential wave parks is noted. The proposed Wave Basin is not
currently permitted on the project site. In order to allow such a facility, a General Plan Amendment
and Change of Zone have been requested to allow the Wave Basin and other tourist commercial uses
on a portion of the project site, which are policy decisions for the City Council. The proposed General
Plan Amendment and zone change are analyzed in Section 4.10, Land Use and Planning of the Draft
EIR, which concluded that the land use and zone changes proposed for the project would result in
less than significant impacts, in part because the proposed tourist commercial uses are located in the
interior of the project site, surrounded by low-density residential uses, perimeter walls and
landscaping, consistent with the surrounding communities. The commenter's concern regarding
completion of the project is noted but is not an issue under CEQA. (See CEQA Guidelines 15064 and
15131, stating that "economic or social effects of a project shall not be treated as significant effects
on the environment".) The Planning Commission and City Council will consider the policy -related
issues associated with the project, including assurances regarding the completion of the project, as
part of their deliberations on the project.
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Comment Letter No. 16: Dina Stuart
Date: June 21, 2021
Affiliation: Area Resident
Comment 16-a:
The County report that states Significant effect projected to be Tess than zero refer to topics like land
use planning, public services etc....
That has nothing to do with the Significant effects on neighbors and nearby residents!
The effect on us and our lifestyle is very Significant' 1111
Is there a place in the desert for a surf resort?.... Absolutely!' 111
But it is NOT across the street from Andalusia and Trilogy, nor nearby The Quarry and PGA West
developments....
Head out by the Thermal Airport and beyond....
Plenty of locations!
Better yet, improve the Salton Sea and put it out there and make it a destination resort once again!!!!
Response 16-a:
The commenter's concerns regarding land use compatibility are noted. However, according to CEQA
Guidelines Section 15064(e), economic and social changes resulting from a project are not part of the
effects on the environment studied in an environmental document.
An alternative location for the proposed project was discussed in Chapter 7.0, Alternatives, of the
Draft EIR. As described on page 7-4 of the Draft EIR, "CEQA Guidelines requires examination of an
alternative location for the project if such locations would result in the avoidance of or lessening of
significant impacts. The project objectives specifically relate to the existing Coral Mountain Resort
property, which is currently undeveloped and vacant. Additionally, the project applicant has not been
able to locate a suitable alternative location of at least 380 acres that is available for purchase and
that would substantially reduce any of the significant impacts of the proposed project." As a result,
and consistent with CEQA, the alternative location alternative was not further considered.
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Comment Letter No. 17: Monica Harrington
Date: June 22, 2021
Affiliation: Area Resident
Comment 17-a:
Eighty -foot light poles are incompatible with City Code under the approved use of the proposed site
for the Coral Mountain Surf Park, which is now zoned as low density residential, which is the same
zoning that applies to surrounding properties. And yet, in the EIS report, we learn that the illumination
of outdoor recreational facilities is exempt from the requirements of this section and that passage is
slipped in as though it's reasonable to think that the zoning should be easily transformed into
Recreational Use, which is the zoning that applies to amphitheaters, ball parks, etc.
Why doesn't this section just come out and say: "The use of 80 -foot light poles is ILLEGAL under the
current zoning of the property, so one way to get around this and to accommodate 80 -foot light poles
is to quietly change the designation to "Recreational" and thus get the same lighting requirements
that might apply to a huge outdoor stadium or arena. And by the way, by doing this, you can ensure
that the outdoor lights can stay on EVERY DAY until 10:00."
The authors of this study didn't write it that way because they wanted people to come away thinking
that it's reasonable that 80 -foot lights operating until 10:00 pm every night in a low density residential
area is somehow acceptable. It's not.
Response 17-a:
Please see Response 15-d. The General Plan Amendment and Zone Change would remove the golf
course zoning designation from the project and allow for a resort, associated resort amenities, a Wave
Basin facility by assigning these lands a Tourist Commercial (CT) designation. In addition, the project
proposes a Specific Plan, which will apply site-specific standards to the site, as permitted in Municipal
Code Section 9.240.010 and California Government Code Sections 65450 et seq. An analysis of the
proposed changes is included in Section 4.10, Land Use and Planning, of the Draft EIR. For analysis
of the project's impact resulting from the Zone Change, Title 9, Zoning, of the La Quinta Municipal
Code was consulted in order to compare the development standards proposed for the Coral Mountain
Resort project with the existing standards established for the City of La Quinta. Section 4.10
determined that impacts would be less than significant, in part because the proposed tourist
commercial uses are located in the interior of the project site, surrounded by low-density residential
uses, perimeter walls and landscaping, consistent with the surrounding communities. The requested
changes in City standards, including the General Plan Amendment, Change of Zone and Specific Plan,
are part of the allowable changes that can be requested by a property owner or developer, and must
be considered by the Planning Commission and City Council. These policy decisions are not CEQA
issues, but will be considered when the project is considered by these City officials.
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The Wave Basin facility and associated light fixtures would be located in the CT zone, situated in the
southwest portion of the project. Currently, the La Quinta Municipal Code allows 8 -foot pole heights
in this use. The 80 -foot light poles in PA III -B are proposed to surround the 16.62 -acre Wave Basin
feature. The light fixtures will be downward -facing, and oriented to illuminate only the Wave Basin.
For a detailed description of lighting on the property, please see the Light and Glare Topical Response
in Section 2.2.1, above, and pages 4.1-60 — 4.1-70 of the Draft EIR.
As it relates to lighting impacts, please see the Light and Glare Topical Response in Section 2.2.1,
which summarizes the findings of the Draft EIR, references specific exhibits and page numbers in the
Draft EIR, provides a summary of the Lighting Memo, and addresses the concerns of commenters
regarding proposed light.
Comment 17-b:
Sometimes, people agree to tradeoffs on sound/light because the recreational benefits available to
all are perceived to be worth it. E.g., in some municipalities, outdoor summer concerts are allowed a
few times a year in close proximity to residential users, so long as the concerts end before 10:00. The
idea is that for a few nights a year, the tradeoff in noise and light in an otherwise quiet residential
area might be worth it to add to the cultural attractiveness of an area.
Here, there is NO benefit to surrounding communities of 80 -foot light poles or of an event venue that
is active EVERY evening until 10:00 p.m. Surrounding communities get all of the light and noise
intrusion, all of the time, with no benefit.
Response 17-b:
The commenter's opinion regarding the lack of community benefit associated with the project is
noted. As it relates to light and noise, please see the Light and Glare Topical Response in Section 2.2.1,
and Section 4.1, Aesthetics, pages 4.1-60 — 4.1-70 of the Draft EIR, relating to lighting; and the Noise
Topical Response in Section 2.2.4, and Section 4.11, Noise, pages 4.11-44 — 4.11-50 of the Draft EIR
relating to operation noise.
The commenter's concern regarding the appropriateness of the Change of Zone request is noted.
Please also see Response 15-d.
Comment 17-c:
Viewed in this way, the conversion of the existing zoning for the property does not satisfy the zoning
change requirements embedded in La Quinta Municipal Law:
Required Findings: The following findings shall be made by the city council prior to the approval of
any zone map change:
1. Consistency with General Plan. The zone map change is consistent with the goals, objectives
and policies of the general plan.
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2. Public Welfare. Approval of the zone map change will not create conditions materially
detrimental to public health, safety and general welfare.
3. Land Use Compatibility. The new zoning is compatible with the zoning on adjacent properties.
4. Property Suitability. The new zoning is suitable and appropriate for the subject property.
5. Change in Circumstances. Approval of the zone map change is warranted because the
situation and the general conditions of the property have substantially changed since the
existing zoning was imposed.
Response 17-c:
The La Quinta Planning Commission and City Council will review the Draft EIR and its findings, as well
as the findings necessary for all of the entitlements associated with the proposed project. These
findings, however, are policy decisions which will be considered in conjunction with, but separate
from, the CEQA documentation. To the extent that land use compatibility is required to be analyzed
under CEQA, the Draft EIR discussed and analyzed these issues in Section 4.10, Land Use and
Planning. The Draft EIR determined that the proposed project would not cause a significant
environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the
purpose of avoiding or mitigating an environmental effect.
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Comment Letter No. 18: Connie Glavin
Date: June 23, 2021
Affiliation: Area Resident
Comment 18-a:
Please do not allow this development, it will spoil the area as far as lights noise traffic. Animals will
be disturbed also. We have big horn sheep and Bob cats ion the area and we enjoy them. We
purchased our home out here for our retirement for the quiet area and enjoy sitting out at night and
seeing the stars afraid the added traffic and lights will interfere with this nice quiet area please let us
know that this will not occur this was zoned residential correct? Why change it now, we like to bike
and with the added traffic will be hard to exit our development and ride into old town la Quinta. With
drivers coming back here for the wave park development.
Response 18-a:
The commenter's concerns are noted. However, the commenter does not provide specific or
substantial evidence regarding the issues of lighting, noise, traffic or biological resources. As it relates
to light and noise, please see the Light and Glare Topical Response in Section 2.2.1, and Section 4.1,
Aesthetics, pages 4.1-60 — 4.1-70 of the Draft EIR, relating to lighting; and the Noise Topical Response
in Section 2.2.4, and Section 4.11, Noise, pages 4.11-44 — 4.11-50 of the Draft EIR relating to
operational noise. As it relates to traffic, please see the Traffic Topical Response in Section 2.2.5 and
pages 4.13-17 — 4.13-51 of the Draft EIR, and as it relates to biological resources, please see the
Biological Resources Topical Response in Section 2.2.2 and pages 4.3-15 — 4.3-24 Within these
sections of the Draft EIR, the impacts of lights proposed at the project; project impacts to local
wildlife; noise generated from the project; and traffic and safety (i.e., bike safety) related to the
proposed project are analyzed. All topics were determined to result in less than significant impacts
with the implementation of mitigation measures.
As it relates to the commenter's question regarding land use designations, please see Response 15-
d.
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Comment Letter No. 19: Sarah Zappas
Date: July 1, 2021
Affiliation: Area Resident
Comment 19-a:
I want to reach out to you as a resident of Andalusia, 58194 Aracena in La Quinta for the last 8 years.
The proposed plan to put a water park "wave pool" across the street in a zoned residential
neighborhood, seems like the city has sold out in favor of commercial tax revenues.
My husband and I chose this development for its quiet, and remote location. We were not naive to
think that one day this area around us would not be built up, certainly it would be developed.
However the issues that this project brings to the neighborhood are unacceptable.
Response 19-a:
Comment noted. Please see Response 15-d.
Comment 19-b:
First the water that this park (wave pool) will be using on a daily basis is counter to water conservation
efforts here in the Coachella Valley. The fact that recycled water can't be used and that every day the
"wave pool" will be utilizing our drinking water is negligent at best. I read this finding that designates
this issue as insignificant is ridiculous. I understand it is insignificant to the developers that want this
project to move forward, but greed is what their motivation is.
Response 19-b:
Please see the Water Resources Topical Response in Section 2.2.3, as well as Section 4.10, Hydrology
and Water Quality, and Section 4.15, Utilities and Service Systems of the Draft EIR. As it relates to
the use of recycled water from CVWD's wastewater treatment plants, recycled water is not presently
available in the project vicinity, and it is unknown if or when recycled water will be available.
Nevertheless, the project is designed to utilize non -potable water for outdoor common area
irrigation, including the installation of purple piping and one or more on-site storage ponds. These
facilities will support the use of non -potable water for outdoor irrigation purposes and can also
support the use of recycled water if and when it becomes available from CVWD. As stated on page
4.15-16 of the Draft EIR, the use of recycled water will be evaluated in the future if such water
becomes available. As discussed in the water supply projections portion of the Topical Response on
Water Resources in Section 2.2.3 above, including Figure ES -6 copied from CVWD's Indio Subbasin
Water Management Plan Update, recycled water is projected to account for approximately 5% of
CVWD's available water over the next 25 years (approximately 20,000 AFY out of 380,000 AFY).
Comment 19-c:
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The second was the zoning change that allows the project to develop 60,000 square feet for
commercial purposes in a residential neighborhood that was originally zoned residential. In addition
to that is the 23.6 acres of Recreational Open Space what is that? What will be allowed to be
developed under that designation, the ability to bring in off road vehicles?
Response 19-c:
The 60,000 square feet of commercial uses are located in the northeast corner of the project site.
This area is currently zoned for Neighborhood Commercial uses in the General Plan and Zoning maps.
This designation is not changing, but the area is reduced from approximately 8.4 acres to 7.7 acres.
Under both the current and the proposed Neighborhood Commercial designations, up to 60,000
square feet of commercial development could occur on this portion of the project site The existing
and proposed zones are displayed in Exhibit 4.10-2, Existing and Proposed Zoning, in Section 4.10,
Land Use and Planning, of the Draft EIR.
The 23.6 -acre recreational open space area is proposed for low -intensity passive and active
recreational uses, such as hiking, biking and a ropes course, as described on pages 3-22 and 3-23 of
the Draft EIR, and page 57 of the Coral Mountain Resort Specific Plan. Off-road vehicles are not
permitted, and Section 3.4 of the Specific Plan has been revised to expressly prohibit any motorized
off-road vehicles.
Comment 19-d:
The third issue of the lighting poles, 80 feet high that will illuminate the night sky, every evening 365
days a year. It will be like living next to a football stadium but instead of a couple of months out of
the year, it will be every evening. I beg to differ that this is insignificant, who's says that, obviously
they aren't living across the street.
Response 19-d:
Please see Topical Response on Light and Glare in Section 2.2.1, as well as Section 4.1, Aesthetics, of
the Draft EIR. Project -related operational impacts relating to lights were determined to be less than
significant with the implementation of mitigation measures, not insignificant. The lights associated
with the Wave Basin would be limited to the evening hours of dusk to 10:00 p.m., consistent with the
La Quinta Municipal Code Section 9.100.150 for sports lighting. This is indicated as Mitigation
Measure AES -3 in the Draft EIR. As it relates to the lighting orientation and the commenter's
characterization of a football field, please see the discussion under Topical Response Light and Glare
in Section 2.2.1, relating to orientation and control of fixtures, as well as Appendices B.1 and B.2 of
this Final EIR.
Comment 19-e:
I would ask that the city of La Quinta, the City Council and the Mayor reconsider the scope of this
water park, after all you represent us the people who live in the city of La Quinta. I'm sure with the
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demographic of this city that the population here will not be using this "Wave Pool" but a tourist
population coming to this quiet part of town to party and increase the traffic and above all destroy
the land around this beautiful city.
Response 19-e:
The comment is noted. Please see Response 17-c as it relates to the review of the project by the
Planning Commission and City Council.
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Comment Letter No. 20: Kristina Dailey
Date: July 1, 2021
Affiliation: Area Resident
Comment 20-a:
This email is being written in opposition to the proposed surf park at Coral Mountain. It truly dismays
me how money hungry and dollar driven this counsel has become.
Response 20-a:
The comment is noted. As it relates to the approval process for the project, please see Response 17-
c.
Comment 20-b:
Have you read any of the latest articles in the Desert Sun about the water crisis in the west? Research
Lake Powell and the Glen Canyon Damn. I was there recently. The damn is one to two years away
from being declared a "dry" damn. If that happens not only will our water supplies for the Colorado
River and the states that depend upon it be depleted but our electrical grid will be compromised as
well.
The proposed water park will depend on under ground water tables and supposedly will use less
water then a golf course which is also the LAST thing this desert community needs. Build your homes
if you must but do it responsibly and sustainably.
Response 20-b:
Please see Topical Response on Water Resources in Section 2.2.3, as well as Section 4.10, Hydrology
and Water Quality, and Section 4.15, Utilities and Service Systems. The Coachella Valley Water
District (CVWD) has determined that sufficient water supplies exist, or will exist based on current
water planning assumptions, to meet the projected demands of the proposed project as well as the
current and future projected water demands within CVWD's service area, including under long term
drought and climate change conditions.
Comment 20-c:
Why would anyone in their right mind want to purchase a 2.5 million dollar home next to a surf club
especially if there are no member benefits included?
The Coral Mountain area is a beautiful, pristine and sacred area of this valley. Let's treat it as such
and be more responsible in our choices for the future.
Response 20-c:
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The comment is noted. The comment does not address a CEQA issue. As it relates to the approval
process for the project, please see Response 17-c.
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Comment Letter No. 21: Diane Rebryna
Date: July 2, 2021
Affiliation: Area Resident
Comment 21-a:
Please see the following email regarding the DEIR for Coral Mountain Resort.
A PDF of this letter is also attached for your reference, should the contents of the email distort during
transmission.
Response 21-a:
The comment is noted.
Comment 21-b:
We, the La Quinta Residents for Responsible Development, are sending this letter to express our
concerns regarding the Draft EIR that was released for Coral Mountain Resort.
At the outset, we wish to say that this document is beyond comprehension for the average resident
of La Quinta.
The DRAFT EIR (DEIR) is not in keeping with the 2021 CEQA Statute and Guidelines
https://www.califaep.org/docs/CEQA_Handbook_2021.pdf, particularly those laid out in Article 10.
Considerations in Preparing EIRs and Negative Declarations:
The text that follows in black refers to direct excerpts from Article 10. Our concerns are laid out in
RED.
Response 21-b:
Please see Topical Response on Length of the Draft EIR in Section 2.2.6, and Topical Response on
Ability to Comprehend Draft EIR in Section 2.2.7.
Comment 21-c:
15140, Writing
EIRs should be written in plain language and may use appropriate graphics so that decision makers
and the public can rapidly understand the documents.
This document is replete with redundancy - paragraphs and statements, obviously boilerplate, are
inserted and re-inserted throughout the document into various categories, where not necessary or
where summaries might have been acceptable.
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We do see the summary of Environmental Impacts and Mitigation Measures TABLE 1-3. While this
summary is useful, the background information regarding each section MUST be presented in a
manner that a reader can understand.
The DEIR fails in this regard.
Response 21-c:
Please see Topical Response on Ability to Comprehend the EIR in Section 2.2.7. The Draft EIR has was
written to disclose all of the project components and technical methodologies utilized in order to
comply with CEQA standards.
As stated on page 1-14 of the Draft EIR (the page prior to Table 1-3), the Table "identifies the
potentially significant effects of the proposed project, mitigation measures, project features and/or
requirements identified to avoid or reduce the identified potentially significant effects to the
maximum extent feasible, and the effectiveness of the mitigation measures, project features and/or
requirements to reduce the potentially significant effects to a level of less than significant." The
purpose of the table, and the Executive Summary Chapter, is to include the summary of each
environmental topic. Additional discussion, analysis, and conclusions are located in the individual
issue area chapters and sections, consistent with the requirements of CEQA.
Comment 21-d:
15141, Page Limits
The text of draft EIRs should normally be less than 150 pages and for proposals of unusual scope or
complexity should normally be less than 300 pages.
This statement speaks for itself.
The DRAFT EIR is well over 700 pages, not including Appendices.
The document is unnecessarily LARGE, primarily as a result of the way it is written — we refer you back
to 15140 above.
Response 21-d:
Please see Topical Response on Length of the Draft EIR in Section 2.2.6, above.
Comment 21-e:
15145, Speculation
If, after thorough investigation, a Lead Agency finds that a particular impact is too speculative for
evaluation, the agency should note its conclusion and terminate discussion of the impact.
The intrusiveness on the surrounding residential communities with, by way of example but not limited
to, the:
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Lights (including multiple 80 -foot towers and commercial glare from buildings and parking lots)
Noise (during operation, and that associated with Special Events), and
Aesthetics (impacts on the views of Coral Mountain)
As presented in the DEIR with the pretext of supportive "scientific studies/analysis", is difficult to even
read let alone understand, and therefore to allow for our interpretation.
We are of the opinion that the declared "negative" impacts of the above in particular are essentially
speculative and should be acknowledged as such.
The failure to do this greatly concerns us and many residents that we have talked with regarding the
DEIR. The phrase that comes to mind, no disrespect intended, is "smoke and mirrors". This speaks to
our concerns about the credibility of the some of the information presented in the document.
Response 21-e:
The commenter's opinions are noted. As it relates to comprehension of the EIR, please see Topical
Response on the Ability to Comprehend the EIR in Section 2.2.7. As it relates to lighting, the Draft EIR
addressed lighting impacts in Section 4.1, Aesthetics, pages 4.1-60 —4.1-70, and Appendix B. In order
to clarify and expand that discussion, the Light and Glare Topical Response in Section 2.2.1 is provided
above, to further explain the lighting technology associated with the project. These analyses are not
speculative, but based on established professional standards and thresholds of significance. As
described above and in Section 4.1 of the Draft EIR, the analysis correctly concluded that the impacts
associated with lighting will be less than significant with the implementation of mitigation measures.
The project's potential operational noise impacts are addressed in Section 4.11, Noise, of the Draft
EIR, pages 4.11-44 through 4.11-50, and in Appendices K.1 and K.2. In order to clarify and expand
that discussion, Topical Response on Noise in Section 2.2.4 is provided above to further explain how
the operational noise impacts were properly analyzed, including the determinations that the project
will not have any significant operational noise impacts with implementation of mitigation measures.
As it relates to the impacts to views of Coral Mountain, this is analyzed in discussion a) of Section 4.1
in the Draft EIR, pages 4.1-22 — 4.1-45. Additionally, Exhibits 4.1-4 through 4.1-13 provide visual
simulations to demonstrate the project's impact when observed from public viewpoints. The Draft
EIR correctly determined that development on the project site would result in significant and
unavoidable impacts to views of Coral Mountain, even within the implementation of feasible
mitigation measures. Also as correctly determined in the Draft EIR, Findings and a Statement of
Overriding Considerations will be required should the City Council determine that the impacts
associated with the views of Coral Mountain are outweighed by the benefits of the project, as
required by CEQA Guidelines Section 15093.
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To conclude, the technical reports, photometric plans and visual simulations provided by the technical
experts are not speculative, but rather utilize established methodologies to analyze the project
impacts in compliance with applicable CEQA standards and requirements.
Comment 21-f:
15146, Degree of Specificity
The degree of specificity required in an EIR will correspond to the degree of specificity involved in the
underlying activity which is described in the EIR.
An EIR on a project such as the adoption or amendment of a comprehensive zoning ordinance or a
local general plan should focus on the secondary effects that can be expected to follow from the
adoption or amendment, but the EIR need not be as detailed as an EIR on the specific construction
projects that might follow.
We are of the opinion that the "details" of the DEIR obscure the focus on the secondary effects of the
Project — in other words, we as the readers, cannot see the "forest for the trees" and therefore have
trouble understanding exactly what it is that the DEIR is trying to say.
Every attempt should have been made in the DRAFT EIR to ensure, going back to 15140 above, to
ensure that the information contained is "rapidly understood" by the reader.
We would have liked to stand back upon receipt of the EIR and, after reading, say "WE MAY NOT
AGREE... BUT WE DO UNDERSTAND THE SECONDARY EFFECTS".
As the EIR stands now, we are making it known to you that we are unable to do this.
Response 21-f:
The commenter's opinions regarding the specificity and clarity of the Draft EIR are noted. Please see
Topical Response on Ability to Comprehend Draft EIR in Section 2.2.7 and Response 21-c, above. This
is a project level EIR, and not a zoning ordinance or General Plan EIR, and accordingly, the quoted
discussion of secondary effects in CEQA Guideline 15146 is inapplicable.
Comment 21-g:
15147, Technical Detail
The information contained in an EIR shall include summarized technical data, maps, plot plans,
diagrams, and similar relevant information sufficient to permit full assessment of significant
environmental impacts by reviewing agencies and members of the public.
Placement of highly technical and specialized analysis and data in the body of an EIR should be
avoided through inclusion of supporting information and analyses as appendices to the main body of
the EIR.
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Again, to our points noted. The technical data presented in the body of the DEIR is not summarized
or organized in such a manner as to allow for the understanding of the general reader.
Response 21-g:
The commenter's opinions regarding the clarity of the technical data in the Draft EIR are noted. Please
see Topical Response on Ability to Comprehend Draft EIR in Section 2.2.7, and Response 21-c, above.
Comment 21-h:
In summary, from the CEQA Guidelines... "The DEIR serves as a public disclosure document explaining
the effects of the proposed project on the environment, alternatives to the Project, and ways to
minimize adverse effects and to increase beneficial effects".
This is the framework that we looked forward to and expected to receive when the DEIR was released,
nearly two weeks ago.
In essence, the proclamation of "no negative effects" is evident throughout the document, but the
information that is provided within the document to support those conclusions regarding the DEIR
categories is virtually undecipherable to us.
This is not fair. There is a timed "Process" underway and we are the residents who will be impacted
by this Project.
We require transparency please.
We require a complete understanding of exactly what is impacting us and how. Any mitigation
measures presented must make sense.
If we, the general public, cannot understand the DEIR, how can we possibly respond accordingly in
the manner required of us? Conjecture and opinions will carry no weight.
We respectfully request that this DRAFT EIR be retracted and replaced.
The replacement document should be created with the following in mind - it should be reasonable in
length, with clear and concise language, and without unnecessary repetition. This would allow for
"rapid" understanding by readers, and thus it would be in alignment with the CEQA guidelines.
Thank you for your consideration of our request.
Response 21-h:
The commenter's concerns are noted. Responses have been provided in Responses 21-b through 21-
g, above.
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Comment Letter No. 22: Derek Wong/Bridgette & Phil Novak
Date: July 3, 2021
Affiliation: Area Resident
Please note that this comment letter was originally addressed to members of the City Council, in
response to a newspaper article in the Desert Sun. However, because the letter was received during
the EIR comment period, it has been treated as a comment on the EIR, and a response is provided
below. Please also note that the allegations and accusations made by the commenter regarding the
professionalism of project consultants and the applicant are not a subject for this Response to
Comments, and will not be addressed here.
Comment 22-a:
As concerned Andalusia homeowners, we were very disappointed in the July 1 Desert Sun article by
Sherry Barkas, "Study: Surf park would have little noise impact".
Response 22-a:
The comment is noted. The commenter's additional comments are addressed in the following
responses.
Comment 22-b:
Please consider these concerns and plan future articles accordingly.
1. Please do not state one side's opinion as a headline (it misleads readers...who will think it is a
conclusion...instead of a self -promoting opinion based on highly questionable information by the
developers and their consultants).
Response 22-b:
The commenter's opinions are noted. Please see Response 19-b as it relates to recycled water use.
Comment 22-c:
2. We have concerns about the neutrality of the firm — MSA Consulting in Rancho Mirage — hired to
conduct the EIR. They seem to have an extremely close relationship with Meriweather, the developers
of the proposed Coral Mountain project. Shouldn't the Sun be certain that there is no conflict of
interest going on here before becoming an unwitting spreader of their biased, profit -motivated
position? Please research MSA to see if they have ever produced EIRs with findings unfavorable to
the developer's side.
Response 22-c:
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The Draft EIR analyses and findings are based on technical studies prepared by technical experts. The
methodologies used in the technical reports and EIR analysis are based on established professional
standards and thresholds established to satisfy CEQA requirements. The Draft EIR was prepared under
the direction of the City of La Quinta which is the Lead Agency. The EIR has been prepared to meet
the City's requirements, regardless of the preparer.
Comment 22-d:
3. The "findings" your reporter cites from the EIR are curiously similar to/almost mirror reflections of
Meriweather's pro -development, pre-EIR claims. Therefore, we suggest you (or a Sun reporter) ask
the City Planner Nicole Sauviat Criste for copies of the incredibly well -researched and well-informed
complaints about the project that dozens of local citizens have submitted. These letters should help
you gain a more critical, less naive stance toward the EIR's contentions and expose you to the
seriousness of many of the issues surrounding this project. The letters will also provide you with the
names of some local citizen experts you can contact for further elucidation.
Response 22-d:
The commenter's opinions are noted. Public comments, both opposing and supporting the project,
are included in the Notice of Preparation (NOP) as Appendix A of the Draft EIR. Letters received by
the City during the EIR comment period are presented herein, along responses as required by CEQA.
Comment 22-e:
4. PLEASE ASK QUESTIONS whenever Meriweather or MSA make claims (don't just take their word
for everything). For instance:
a. Meriweather/MSA claims the project will use "less water than a golf course". Really? Most desert
golf courses use recycled or gray water. A surfpark/wave basin must use fresh water since human
beings will be swimming in it. And are they honestly including the amount of water that will be used
by the project's planned single-family homes, villas/hotel rooms, restaurants, planned grocery store,
spa/fitness facilities, showers/stalls for surfers, landscaping, continuously needing to refill the wave
basin, etc.? We have NOT seen any of those figures. So their "comparisons" of their project vs. a golf-
course/home project should not be trusted.
Response 22-e:
Please see the Topical Response on Water Resources in Section 2.2.3. Contrary to the commenter's
assertions, Section 2.0, Water Demands, on pages 20 to 24 of the WSA/WSV provides a full discussion
and associated tables listing the water use for all project components. The WSA/WSV is included as
Appendix M of the Draft EIR.
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Additional analysis of water resources is also provided in Section 4.9, Hydrology and Water Quality,
and 4.15, Utilities and Service Systems, of the Draft EIR. Sections 4.9 and 4.15 provide a complete
and thorough analysis of project -related water consumption.
Comment 22-f:
b. Meriweather/MSA claims that the project will have "less than significant" impacts on water quality,
usage and depletion of groundwater supplies. DID YOU ASK ABOUT EVAPORATION...from an 18 -
million gallon wave basin sitting in the desert sun...and how much water they will have to use to
continuously refill it?
Response 22-f:
Please see the Topical Response on Water Resources in Section 2.2.3, and Response 15.c, above.
Comment 22-g:
c. Meriweather/MSA claims the wave basin's LIGHTS will "only impact a small area of the scenic vista".
Really? Have you seen the video from one of the night events held at Kelly Slater's Surfpark in
Leemore? Look here - BEST Wave Pool Experience EVER! Kelly Slater Surf Ranch w/ Casey Neistat—
(START AT 34:25) - and then tell us that Coral Mountain's seventeen 80 -foot -tall light towers will not
be intrusive! PLEASE GET SERIOUS ABOUT THE LIGHT POLLUTION THIS PROJECT WILL CREATE. They've
already admitted the wave basin will operate until 10pm year-round...and probably later during their
special events. How would you like that kind of lit -up amusement feature in your backyard...every
day...from 7am to 10pm?!?!? It will be a MAJOR DISRUPTOR to all the nearby residents...who bought
homes in surrounding communities for the peace and quiet currently afforded here. La Quinta prides
itself on its starry, desert night sky!!! These outrageous light poles will create too much light...and
negatively impact the night sky... for all the surrounding communities. And will be a MAJOR blight
against the nearby mountains!
Response 22-g:
The commenter's opinions are noted. The discussion on pages 4.1-22 — 4.1-44 and 4.1-60 — 4.1-70
(Section 4.1, Aesthetics) of the Draft EIR analyzes the impacts of the proposed 80 -foot light fixtures.
In addition, please see the Topical Response on Light and Glare in Section 2.2.1.
Comment 22-h:
d. Local experts claim that the proposed development — specifically the carving out of an 18 -million
gallon wave basin and the constant shaking created by the wave -making motors and the continuous
hard pounding into the earth of the waves as they crash -- could have geologically and seismologically
negative effects on the soil around Coral Mountain. There are also concerns about the damage an
earthquake could cause to an 18 -million gallon wave basin and the surrounding communities. PLEASE
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COVER THIS ANGLE. You will see scientific data about these concerns in the letters submitted to the
City that we referenced above. We can also provide you with experts to talk to about these issues.
Response 22-h:
The commenter's concerns are noted. The commenter does not, however, provide any substantial
evidence that the proposed project will result in either a greater number of earthquakes or geological
impacts. The commenter defers evidence to unnamed experts. As stated in the Draft EIR, page 4.6-
16, the proposed Wave Basin will be constructed to meet all seismic standards of the Uniform Building
Code in force at the time that building permits are secured. These impacts are analyzed in Section
4.6, Geology and Soils, and include specific discussion of a number of seismic hazards and soils
hazards, including groundshaking, subsidence, lateral spreading, ground failure (including
liquefaction), soil erosion, unstable soils, and expansive soils. The Draft EIR also analyzed the potential
hazards associated with seismically induced tsunami or seiche in Section 4.6. This analysis, supported
by a comprehensive analysis by a registered geologist provided in Appendix G of the Draft EIR,
resulted in a determination that impacts associated with geological hazards will be mitigated to a less
than significant level with the implementation of Mitigation Measures GEO-1 through GEO-3.
Impacts associated with earthquakes are correctly analyzed in the Draft EIR to be less than significant
with the implementation of these mitigation measures.
Comment 22-i:
e. Meriweather claims NOISE impacts will be "less than significant during construction...and once the
project is completed and the wave basin is operating". Oh really?!? Ask any resident of Andalusia
about the amount of noise that is heard from minor construction projects at the IID building on
Avenue 58 — e.g., repaving their parking lot, putting on a new roof. All their projects reverberate and
are heard loudly...along with the back-up beeping of all the trucks involved...throughout the
Andalusia community. And these are MINOR projects — nothing like the building of homes,
restaurants, a hotel, a huge wave basin, and surrounding support facilities. GET SERIOUS PLEASE!
f. And what about NOISE once the project is completed? How was "less than significant" determined?
This is crazy! The wave basin will operate NON-STOP from 7am to 10pm DAILY! LOUD MECHANICAL
NOISE is part of the wave -producing machines...along with the constant back & forth of jet skis to
transport surfer -customers... and the PA system announcing the next waves and playing music. GET
SERIOUS PLEASE! This project will be a MAJOR NOISE PRODUCER!
g. Another consultant obviously in cahoots with Meriweather is called Urban Crossroads. They
submitted this ludicrous claim to the EIR — "The mountain is more likely to absorb rather than deflect
sounds from the wave basin during normal use and special events". Again...ARE YOU KIDDING ME?
Coral Mountain is a natural rock amphitheater...sounds that are made in its environs bounce off its
walls and echo into surrounding communities. JUST ASK THE HOMEOWNER who lives at Avenue 60
and Madison. She can hear hikers at the base of Coral Mountain...and you don't think noises created
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by a major machinery -driven wave -pounding water -sports basin...with loudspeakers all around...and
jet skis revving... will be heard? This has not been studied properly!!! And again...we ask...since you
are the community's journalistic outlet...to investigate Urban Crossroads. ALL of its clients are cities
and homebuilders. They are NOT going to say anything that would derail the development or upset
their clients. WHO IS WORKING on behalf of the surrounding taxpaying homeowners? Clearly not the
City... which obviously wants this development!
Response 22-i:
The commenter's questions are noted. The commenter, however, provides opinion and not
substantial evidence that the project will result in substantially greater noise impacts than those
analyzed. Please see the Noise Topical Response in Section 2.2.4. Discussion a. in Section 4.11, Noise,
of the Draft EIR analyzes the impacts of construction -related and operational noise generated by the
proposed project. Impacts of project -generated noise was analyzed by a professional noise engineer,
and the findings are thoroughly discussed in Section 4.11. The level of impact has been correctly
identified, and mitigation measures provided to reduce these impacts to less than significant levels.
Comment 22-j:
h. Meriweather says it will hold four events per year attracting approx. 2,500 attendees each. And
they have the chutzpah to say that the project will have "no significant impact on surrounding
intersections"?!? Really?? So they do not plan to make any changes to the existing
intersections...which are rural/low-density/residential...at Avenue 58 and Madison...or Avenue 60
and Madison? There are just Stop signs at all these surrounding intersections. And the developer is
not planning to make any contributions to improving traffic control or noise issues that will result
from the project or their large events? We repeat...this is a LOW-DENSITY, RESIDENTIAL
neighborhood...which should NOT be changed.
Response 22-j:
The comment is incorrect. As provided in Section 4.13, Transportation, of the Draft EIR, pages 4.13-
29 — 4.13-38, a number of intersection improvements are required at each phase of development to
address deficits in acceptable Levels of Service (LOS) both with and without the project. As correctly
identified in the Draft EIR, at pages 4.13-42 — 4.13-49, the traffic impacts associated with special
events are fully disclosed, and mitigation measures included to assure that the impacts of special
events are reduced to less than significant levels. It is also noted, on Tables 4.13-19, 4.13-21, and 4.13-
23 and pages 4.13-28 through 4.13-42 of Section 4.13, that a number of intersections currently or in
the future will operate at unacceptable LOS without the project, indicating that current development
and planned future development other than the proposed project have impacted and will continue
to impact area roadways, regardless of whether the proposed project is constructed. The needed
improvements are provided in the City's Capital Improvement Program, as discussed on page 4.13-
50, which is the appropriate mechanism used by cities throughout California to plan for and
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implement traffic improvement. Finally, and consistent with professional practices in the analysis of
traffic impacts associated with specific projects, the Draft EIR analyzes and discloses that the project
will be directly responsible for:
Phase 1 Improvements: Improvements to Avenue 58, Madison Street, Avenue 60, and project access
points, and the project's fair share contributions toward planned traffic signals and related
improvements at 5 area intersections as identified in Table 4.13-20 (see pages 4.13-29 — 4.13-33 of
Draft EIR).
Phase 2 Improvements: Same physical improvements as specified for Phase 1, plus increased fair
share contributions toward planned traffic signals and related improvements at 6 area intersections
as identified in Table 4.13-22 (see pages 4.13-34 — 4.13-37 of Draft EIR).
Phase 3 Improvements: Same physical improvements as specified for Phase 1, plus installation of a
traffic signal at the intersection of Madison St. and Avenue 58, and increased fair share contributions
toward planned traffic signals at nine other intersections as identified in table 4,13-24 (see pages
4.13-37 — 4.13-41 of the Draft EIR.
Therefore, the Draft EIR has analyzed and identified intersection improvements required with and
without the proposed project, quantified the level of impact, and proposed mitigation measures
which will effectively mitigate those impacts, whether these measures are the City's or the project's
responsibility.
Comment 22-k:
Once again, the Coral Mountain property is zoned for "neighborhood commercial, low-density
residential and golf course" for a reason. And this zoning is part of the La Quinta General Plan...so any
change should require much broader buy-in...from taxpaying homeowners and businesses...instead
of just Meriweather and its consultants! Please do your due diligence for ALL future stories on this
topic!
Response 22-k:
This commenter's opinions are noted. Please see Responses 15-d, 17-a and 17-c.
Comment 22-1:
You should also push back when told...or when you come across language...that refers to something
as "less than significant"... or "more likely". Meriweather/MSA/Urban Crossroads use incredibly
VAGUE language. This is NOT ACCEPTABLE when discussing such serious, life -changing concerns for
those of us who live next door to this property! And the City/citizens/journalistic outlets should NOT
let them get away with it! What do those terms mean? Compared to what? Show us the
numbers/actual measurements!
Response 22-1:
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The commenter's opinions are noted. He does not, however, provide substantial evidence of a
deficiency in the El R's analysis or conclusions in any environmental issue area.
Comment 22-m:
And while you're at it... please talk to Air, Noise, Water, Planning experts about the ridiculousness of
FOUR Water/surf parks being constructed in the middle of the desert! These are incredibly non -
sustainable projects - in an era of water restrictions, air -health quality concerns, traffic issues, etc!
Please start covering this issue more seriously. The Coachella Valley does NOT need four of these
parks! And shouldn't the desert cities get together to support the one or two that will be OPEN TO
THE PUBLIC and provide income to all the communities...instead of supporting one that will be highly
exclusive/private and JUST benefit the developer (as Coral Mountain would)!!
Response 22-m:
The commenter's opinions are noted. Discussions regarding cumulative impacts are provided in the
Draft EIR on pages 4.2-41— 4.2-42 as they relate to air quality, pages 4.15-34 — 4.15-35 as they relate
to water supplies, pages 4.10-30 — 4.10-31 as they relate to planning, pages 4.11-51— 4.11-54 as they
relate to noise, and pages 4.13-57 — 4.13-61 as they relate to traffic.
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Comment Letter No. 23: Bobbie Fleury
Date: July 6, 2021
Affiliation: Area Resident
Comment 23-a:
Contrary to what some may believe, I am not anti -development concerning the Coral Mt. Resort. In
fact, I have no issues with this parcel of land being approved for homes, a hotel and restaurant, hiking
and biking trails, and perhaps even have the developer throw in a 9 hole putt -putt course for fun - on
fake grass!
Response 23-a:
Comment noted.
Comment 23-b:
However, I am extremely opposed to the current request for a zoning change to accommodate what
amounts to an amusement park for out-of-towners in the middle of residential communities, and
especially a park whose main feature is an 18 million gallon water guzzling ditch that will continuously
be draining our fresh water from the aquifer due to evaporation in our hot, dry, climate. I also have
to wonder if anyone at Meriwether realizes that the water in the wave pool will be uncomfortably
hot for about 4 months out of the year and therefore not much fun to surf in. It's why many don't use
their pools in the summer.
Response 23-b:
The commenter's opinion is noted. Regarding water consumption, please see the Topical Response
on Water Resources in Section 2.2.3, as well as Section 4.9, Hydrology and Water Quality, and
Section 4.15, Utilities and Service Systems, of the Draft EIR. Project -related water consumption is
determined to result in less than significant impacts as stated in the Draft EIR because there are
adequate water supplies available for the project and all other existing and planned future uses in the
subbasin area, and because the project will not interfere with CVWD's ongoing groundwater
management efforts. These conclusions were made pursuant to the project -specific Water Supply
Assessment/Water Supply Verification (WSA/WSV) approved by CVWD, as required by the State law.
The WSA/WSV is included in the Draft EIR as Appendix M. The commenter's opinion regarding the
temperature of the water in the summer months is noted.
Comment 23-c:
This According to the recently released draft EIR, most of what is planned for the site won't have any
"significant" impact on the surrounding environment. That's like saying someone is "slightly"
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pregnant! The developer - Meriwether Co. - hired the people who did the DEIR. Are we supposed to
believe that their report is totally OBJECTIVE?
Response 23-c:
The commenter's opinion is noted. The Draft EIR is a document prepared by the City of La Quinta,
since they are the lead agency under CEQA. It is based on professionally prepared technical reports
and analyses which meet the requirements of CEQA. Please also see Response 22-c.
Comment 23-d:
The developer continues to cite that the wave won't use more water than a golf course, while ignoring
the fact that more and more courses have now gone to non -potable water, something that cannot be
done with the surf park. For our City Council to approve the rezoning so this can proceed is
unconscionable especially in light of La Quinta's own land and water use guidelines. Just like Slater
did in Lemoore, where the wave park is in the middle of empty land, that's where this should go - and
not in our desert where water use is of critical importance.
Considering that California is back into a drought situation, if the developer has a conscious, or any
inkling of being environmentally sensitive, they should pull back their request for the wave portion of
their plans.
Response 23-d:
Please see the Topical Response on Water Resources in Section 2.2.3, as well as Section 4.9,
Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems, of the Draft EIR. Also
see Response 19-b as it relates to the use on potable vs. non -potable water. As it relates to the
proposed change of zone, please see Responses 15-d, 17-a and 17-c. The commenter's opinion
regarding the location and components of the project is noted.
Comment 23-e:
And I would hope, that when it comes before you for a vote, your answer will be "no."
Thank you for your consideration.
Response 23-d:
This comment is noted. Please see Responses 15-d and 17-a.
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Comment Letter No. 24: Agnes Collins
Date: July 7, 2021
Affiliation: Area Resident
Comment 24-a:
We, the La Quinta Residents for Responsible Development, are sending this letter to express our
concerns regarding the Draft EIR that was released for Coral Mountain Resort.
At the outset, we wish to say that this document is beyond comprehension for the average resident
of La Quinta.
The DRAFT EIR (DEIR) is not in keeping with the 2021 CEQA Statute and Guidelines
https://www.califaep.org/docs/CEQA_Handbook_2021.pdf, particularly those laid out in Article 10.
Considerations in Preparing EIRs and Negative Declarations, as laid out here:
Response 24-a:
The comment is noted. The contents of the letter are virtually identical to comment letter number
21. Where the letters are the same, reference is made to the appropriate Response in comment
letter 21.
Comment 24-b:
15140. Writing
EIRs shall be written in plain language and may use appropriate graphics so that decision makers and
the public can rapidly understand the documents.
This document is replete with redundancy - paragraphs and statements, obviously boilerplate, are
inserted and reinserted throughout the document into various categories, where not necessary or
where summaries might have been acceptable.
We do see the summary of Environmental Impacts and Mitigation Measures TABLE 1-3. While this
summary is useful, the background Information regarding each Section MUST be presented in a
manner that a reader can understand.
The DEIR fails in this regard.
Response 24-b:
Please see Response 21-c.
Comment 24-c:
15141. Page Limits
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The text of draft EIRs should normally be less than 150 pages and for proposals of unusual scope or
complexity should normally be less than 300 pages.
This statement speaks for itself.
The DRAFT EIR is well over 700 pages, not including Appendices.
This document is unnecessarily LARGE, primarily as a result of the way it is written - we refer you back
to 15140 above.
Response 24-c:
Please see Response 21-d.
Comment 24-d:
15145. Speculation
If, after thorough investigation, a Lead Agency finds that a particular impact is too speculative for
evaluation, the agency should not its conclusion and terminate discussion of the impact.
The intrusiveness on the surrounding residential communities with, by way of example but not limited
to, the:
Lights (including multiple 80 -foot towers and commercial glare from buildings and parking lots)
Noise (during operation, and that associated with Special Events), and
Aesthetics (impacts on the views of Coral Mountain)
As presented in the DEIR with the pretext of supportive "scientific studies/analysis", is difficult to even
read let alone understand, and therefore to allow for our interpretation.
We are of the opinion that the declared "negative" impacts of the above in particular are essentially
speculative and should be acknowledged as such.
The failure to do this greatly concerns us and many residents that we have talked with regarding the
DEIR. The phrase that comes to mind, no disrespect intended, is "smoke and mirrors". This speaks to
our concern about the credibility of the some of the information presented in the document.
Response 24-d:
Please see Response 21-e.
Comment 24-e:
15146. Degree of Specificity
The degree of specificity required in an EIR will correspond to the degree of specificity involved in the
underlying activity which is described in the EIR.
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An EIR on a project such as the adoption or amendment of a comprehensive zoning ordinance or a
local general plan should focus on the secondary effects that can be expected to follow from the
adoption or amendment, but the EIR need not be as detailed as an EIR on the specific construction
projects that might follow.
We are of the opinion that the "details" of the DEIR obscure the focus on the secondary effects of the
Project — in other words, we as the readers, cannot see the "forest for the trees" and therefore have
trouble understanding exactly what it is that the DEIR is trying to say.
Every attempt should have been made in the DRAFT EIR to ensure, going back to 15140 above, to
ensure that the information contained is "rapidly understood" by the reader.
We would have liked to stand back upon receipt of the EIR and, after reading, say "WE MAY NOT
AGREE... BUT WE DO UNDERSTAND THE SECONDARY EFFECTS".
As the EIR stands now, we are making it known to you that we are unable to do this.
Response 24-e:
Please see Response 21-f.
Comment 24-f:
15147. Technical Detail
The information contained in the EIR shall include summarized technical data, maps, plot plans,
diagrams, and similar relevant information sufficient to permit full assessment of significant
environmental impacts by reviewing agencies and members of the public.
Placement of highly technical and specialized analysis and data in the body of an EIR should be
avoided through inclusion of supporting information and analyses as appendices to the main body of
the EIR.
Again, to our points noted. The technical data presented in the body of the DEIR is not summarized
or organized in such a manner as to allow for the understanding of the general reader.
Response 24-f:
Please see Responses 21-g.
Comment 24-g:
In summary, from the CEQA Guidelines... "The DEIR serves as a public disclosure document explaining
the effects of the proposed project on the environment, alternatives to the Project, and ways to
minimize adverse effects and to increase beneficial effects".
This is the framework that we looked forward to and expected to receive when the DEIR was released,
nearly two weeks ago.
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In essence, the proclamation of "no negative effects " is evident throughout the document, but the
information that is provided within the document to support those conclusions regarding the DEIR
categories is virtually undecipherable to us.
This is not fair. There is a Imed "Process" underway and we are the residents who will be impacted
by this Project.
We require transparency please.
We require a complete understanding of exactly what is impacting us and how. Any mitigation
measures presented must make sense.
If we, the general public, cannot understand the DEIR, how can we possibly respond accordingly in
the manner required of us? Conjecture and opinions will carry no weight.
We respectfully request that this DRAFT EIR be retracted and replaced.
The replacement document should be created with the following in mind - it should be reasonable in
length, with clear and concise language, and without unnecessary repetition. This would allow for
"rapid" understanding by readers, and thus it would be in alignment with the CEQA guidelines.
Thank you for your consideration of our request.
Response 24-g:
Please see Response 21-h.
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Comment Letter No. 25: Maggie Hamilton
Date: July 8, 2021
Affiliation: Area Resident
Comment 25-a:
I am a concerned citizen of the desert and am opposed to building the Coral Mountain Resort. We are
in a drought emergency and not only will water be necessary to build this Resort, but adding an 18
million gallon wave pool, too? Water evaporates. Where is this water coming from—the underground
aquifer? We are in the middle of climate change. Temperatures are getting hotter every year. The
2014 Sustainable Groundwater Management Act—SGMA was adopted during California's last
drought. The law states that groundwater is a shared resource. I don't believe sharing a finite resource
with more million dollar homes, a four story hotel, and another wave pool in the desert is sustainable.
I conserve water but yet see projects like these springing up all over the desert and wonder why I
should do my part?
Response 25-a:
Please see the Topical Response on Water Resources in Section 2.2.3, as well as Section 4.9,
Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems, of the Draft EIR for
discussion of project -related water consumption. Information on evaporation is provided on pages
22-24 of the WSA/WSV, attached as Appendix M to the Draft EIR. Information on the source of water
for the project is provided on page 26 of the WSA/WSV and pages 2-22-2-23 of the Topical Responses
above. Information on climate change planning is provided in the Topical Response on pages 2-23 —
2-26, which is directly taken from the document that CVWD prepared in response and as required by
the Sustainable Groundwater Management Act. The commenter's concerns are noted.
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Comment Letter No. 26: Ilona Sala
Date: July 8, 2021
Affiliation: Area Resident
Comment 26-a:
I concur with the letter written to the planning committee of the ridiculous length and unfriendly
wording in the Coral Mountain proposal. If the people cannot who are going to be most affected by
this super project are not given a document that can be understood by them, it ought not be written
as such. Don't make this similar to what the Washington bourgeoisie do and write a book size
document filled with legaleze and vote before the document has been decimated and understood by
the proletariats who pay taxes but stand to lose.
Response 26-a:
Please see the Topical Response on the Ability to Comprehend Draft EIR in Section 2.2.7.
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Comment Letter No. 27: Judy Carey
Date: July 9, 2021
Affiliation: Area Resident
Comment 27-a:
I am a full time desert and La Quinta city resident, and have been here 37 years.
I am Opposed to the building of the Coral Mountain Resort with it's proposed 18 million gallon wave
pool, 4 story hotel, and many new homes.
We are living in a drought Again, and with climate change happening it seems irresponsible to think
that such a project which would require so much of an Important resource would even be considered.
According to the 2014 Sustainable Groundwater Management Act, groundwater is a "shared
resource", and therefore this finite resource needs to be used appropriately. Water from our aquifer
needs to be used in a sustainable and justifiable manner. Drinking water, water for crops, plants and
gardens seems more important than a wave pool! Think of the evaporation factor alone.
I do my part with water conservation, shouldn't we ALL be doing the same?
Response 27-a:
Please see the Topical Response on Water Resources in Section 2.2.3, and Response 25-a.
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Comment Letter No. 28: KeIIy Welton
Date: July 10, 2021
Affiliation: Area Resident
Comment 28-a:
My name is KeIIy Welton and my fiance and I live in Trilogy. We moved here in Feb 2020.
Tired of Los Angeles and Orange counties' traffic and noise, we were lured to La Quinta by the open
mountains, sightings of Bighorn sheep, and the quiet beauty of all the visible stars.
Response 28-a:
The comment is noted.
Comment 28-b:
We are VERY opposed to the proposed "Coral Mountain" wave park. We strongly urge you not to
approve any zoning variances that would allow this project to go forward. The proposed variances
effectively allow the equivalent of commercial -scale traffic, noise, lights, and pollution in a high
density residential area. We understand the property will be developed someday, but when we
considered and ultimately purchased our retirement home, we never dreamed the zoning could
change from residential with golf course to amusement park so quickly and so quietly.
Response 28-b:
The commenter incorrectly characterizes the proposed General Plan Amendment and Change of Zone
as variances. No variances are proposed. As it relates to the processing of the General Plan
Amendment and Change of Zone, please see Responses 15-d, 17-a and 17-c.
The comments opinion regarding additional lights, noise and traffic, are noted, but not supported by
evidence or fact. However, it is correct that when compared to the existing condition of the site, which
is undeveloped and vacant, the proposed project will introduce light, noise, and vehicular traffic into
the area. The Draft EIR analyzes project -related impacts to lights, noise, and traffic, in compliance
with CEQA. These topics are discussed in Section 4.1, Aesthetics, Section 4.11, Noise, and Section
4.13, Transportation, (respectively) in the Draft EIR. Findings and conclusions regarding project
impacts were based on technical studies and plans prepared by topic experts. Please also see the
Topical Responses on Light and Glare at Section 2.2.1, Noise at Section 2.2.4, and Traffic at Section
2.2.5, above.
Comment 28-c:
Why jeopardize our "Gem of the Desert" reputation?
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And, to be frank, the Environmental Impact Report seems to have been prepared by the developers
rather than by neutral third parties. This truly is the wrong project in the wrong place.
I believe you have a responsibility to the residents of La Quinta, at the very least to acknowledge our
efforts and listen to our concerns.
We seem to have been 'brushed aside' whenever voicing our concerns for this project.
Please, we urge you to fully consider the impact this development will have on La Quinta, all of La
Quinta, to the ends of the city limits.
Response 28-c:
The commenter's concerns are noted. Please see Response 22-c as it relates to the preparation of the
EIR, and Responses 15-d, 17-a and 17-c as it relates to the approval process for the project.
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Comment Letter No. 29: Mike Charles
Date: July 11, 2021
Affiliation: Area Resident
Comment 29-a:
Please make MSA redo the Draft EIR so we can all understand what is being said as it pertains to the
Wavepark proposal. Personally, I have spent hours trying to come to some understanding of what is
being said or referenced. I simple cannot understand their research or early conclusions. I have given
up as well as many others who have sought out help for same reason. The general public has a right
to understand this document. The city has a similar obligation per Ca statute to make this document
readable and understandable to the average resident. I personally have asked two land use attorneys
for help in the matter and they have reached the same conclusion.
If the goal by MSA is to complicate and confuse the general public then they have succeeded. In order
to move forward this document needs to be understood. Unbelievable that this even needs to be
brought forward.
Response 29-a:
Please see the Topical Response on the Ability to Comprehend Draft EIR in Section 2.2.7.
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Comment Letter No. 30: Dorothy Dupree
Date: July 12, 2021
Affiliation: Area Resident
Comment 30-a:
I am writing to let you know my objection to the proposed development of the Coral Mountain Resort.
I have lived in La Quinta since 1972 and have seen some good development in La Quinta and some
bad. Unfortunately highway 111 has some terrible and unnecessary development, ie car lots and big
box stores.
Response 30-a:
Comment noted.
Comment 30-b:
There are many things to consider when planning a city. It is extremely important to consider the
environmental impact of a development. With global warming and droughts in California it is
responsible for the city to consider how a development would impact our water resources.
The idea of having an 18 million gallon wave pool, a four story hotel and million dollar homes is not
environmentally responsible.
Please deny the application of this development and save our water resources.
Response 30-b:
Please see the Topical Response on Water Resources in Section 2.2.3, as well as Section 4.9,
Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems in the Draft EIR.
Climate change and drought is addressed in Water Resources Topical Response in Section 2.2.3, which
describes the CVWD's long range planning in conformance to SGMA. That analysis shows that CVWD
has included both climate change and drought in its water planning, and has concluded that it has
sufficient resources under these conditions.
As it relates to the City's review and approval or denial of the project, please see Responses 15-d, 17-
a and 17-c. The commenter's opinions are noted.
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Comment Letter No. 31: Kenneth Jones
Date: July 12, 2021
Affiliation: Area Resident
Comment 31-a:
I send this letter to express significant objections regarding the Coral Mountain Resort Draft EIR.
Response 31-a:
Comment noted.
Comment 31-b:
In brief, the subject document fails to comport with CEQA 2021 Guidelines:
https://www.califaep.org/statuteandguidelines.php
The subject document is 5x the volume stated in CEQA guidelines. As such the purpose and intent of
the guidelines are rendered impossible of performance.
Response 31-b:
Please see the Topical Response on Length of Draft EIR at Section 2.2.6.
Comment 31-c:
The current document is - in my opinion - an affront to the audience for which it is intended. A
reasonable person may ask why the developer and its agents sought to avalanche the audience with
such a grossly over -written, unnecessarily complicated document.
Response 31-c:
Please see the Ability to Comprehend Draft EIR Topical Response in Section 2.2.7. The Draft EIR was
written to disclose all of the project components and technical methodologies utilized in order to
comply with CEQA standards.
Comment 31-d:
Redundancies are pervasive throughout the document. Such writing techniques are experience -
proven methods to confuse, obfuscate and discourage the audience from accomplishing a complete
read. One wonders why the developer and its agents would adopt this communications approach for
a project they know to be controversial and objectionable to many.
Response 31-d:
The Draft EIR is a document published by the City of La Quinta, as the CEQA Lead Agency, for public
review. The purpose of the Draft EIR is not meant to confuse, obfuscate, or discourage the public. The
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purpose of the Draft EIR is to provide the public with project components, facts, and analysis of the
proposed project and its potential impacts on the environment, per CEQA Guideline thresholds.
Redundant language throughout the Draft EIR is required to comply with formatting suggested by
CEQA and to ensure that all potentially significant impacts and measures to reduce or avoid those
impacts are fully analyzed and disclosed to the public.
Comment 31-e:
I respectfully request the subject DRAFT EIR be withdrawn. Further, I ask that the City of La Quinta
respect and observe CEQA guidelines in publishing a replacement DRAFT EIR. In doing so, readers
would have opportunity to absorb and comprehend contents presented in clear, concise, everyday
terms - as intended by CEQA. A corollary benefit would accrue to the City of La Quinta in the form of
reader audience appreciation for transparency.
Your consideration of my request is appreciated. Thank you.
Response 31-e:
The commenter's request is noted. However, as described in the Length of the Draft EIR Topical
Response in Section 2.2.6, and the Ability to Comprehend the EIR Topical Response in Section 2.2.7,
the document is correctly written and its length is required to address all of the potential impacts
associated with a complex project.
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Comment Letter No. 32: Brenda Vatland
Date: July 12, 2021
Affiliation: Area Resident
Comment 32-a:
I am sending this letter to express my concerns regarding the Draft EIR that was released for Coral
Mountain Resort.
Response 32-a:
Comment noted.
Comment 32-b:
This document is not in keeping with the CEQA 2021 Guidelines
https://www.califaep.org/statute_and_guidelines.php
It is too long. The CEQA guidelines stipulate that the document for a project should be no more than
300 pages.
Response 32-b:
Please see the Length of the Draft EIR Topical Response in Section 2.2.6.
Comment 32-c:
It is not "rapidly understood" as required by the CEQA guidelines, again due in part to its length, but
particularly due to redundancy and repetition.
Response 32-c:
Please see the Ability to Comprehend the Draft EIR Topical Response in Section 2.2.7.
Comment 32-d:
I respectfully request that this DRAFT EIR be retracted and reissued.
The replacement document should be created with the following in mind - it should be reasonable in
length, with clear and concise language, and without unnecessary repetition. This would allow for
"rapid" understanding by readers, and thus it would be in alignment with the CEQA guidelines.
Thank you for your consideration of my request.
Response 32-d:
Please see Response 31-e.
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Comment Letter No. 33: Dave Wiezel
Date: July 12, 2021
Affiliation: Area Resident
Comment 33-a:
We are sending this email to express our concerns regarding the Draft EIR that was submitted for
Coral Mountain Resort recently.
Response 33-a:
Comment noted.
Comment 33-b:
The document, as currently submitted, is not in keeping with the CEQA 2021 Guidelines, as specified
at: https://www.califep.org/statute_and_guidelines.php.
Most significantly:
-It is too long. The CEQA guidelines stipulate that the document for a project should be no more than
300 pages.
Response 33-b:
Please see the Length of Draft EIR Topical Response in Section 2.2.6.
Comment 33-c:
-It is not "rapidly understood" as required by the CEQA guidelines, again due in part to its length, but
particularly due to redundancy and repetition.
Response 33-c:
Please see the Ability to Comprehend the Draft EIR Topical Response in Section 2.2.7.
Comment 33-d:
We respectfully request that this DRAFT EIR be retracted and reissued in compliance with the CEQA
2021 Guidelines. Additionally, the consultants and report preparers should be required to provide
clear and verifiable supporting data for every issue of concern.
Thank you for your consideration of our request.
Response 33-d:
Please see Response 31-e.
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Comment Letter No. 34: Diane Rebryna (2)
Date: July 13, 2021
Affiliation: Area Resident
Comment 34-a:
Thank you for your email of this morning, July 13, 2021 with your explanation as to why the current
DEIR (also "the Document") will not be retracted and reissued, and advising us that accordingly there
would be NO extension beyond the August 6, 2021 date for comments.
Perhaps the City has "carefully and thoroughly reviewed the proposed Project", but I believe that you
are missing the point of my request.
Please understand that while a complex Project such as this requires analysis from the City's
perspective, it must also be presented in such a manner to allow for a detailed analysis by the public
and also allow for "rapid understanding".
I would again like to state that the document in its present format does not provide for this, mostly
due to its length, repetitiveness and redundancy. I will not repeat again the reasoning behind our
initial request of July 2, 2021.
I gather from your email that you feel that the document is "not unduly scientific or complex". For
reasons that I will not go into, I respectfully disagree; however the purpose of my response herein is
not to argue.
Response 34-a:
The commenter's opinions are noted. Please see the Ability to Comprehend the Draft EIR Topical
Response in Section 2.2.7.
Comment 34-b:
I do propose a compromise please, particularly with respect to the Sections in Chapter 4.
Environmental Impact Analysis. I would like to see the 5 following items considered:
Response 34-b:
Comment noted. Please see Responses 34-c through 34-h, which directly address the commenter's
individual requests.
Comment 34-c:
1. An expanded Table of Contents for Chapter 4.
***These 15 Sections are essential the "meat and potatoes" of the DRAFT EIR
As the document stands, the Table of Contents for a 700 plus page Document is not at all helpful.
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By way of example, in the Section regarding Aesthetics (4.1) which comprises 73 pages (4.1.1- 4.1.72),
I note 6 Subsections. These are:
4.1.1 Introduction,
4.1.2 Existing Conditions,
4.1.3 Regulatory Setting,
4.1.4 Project Impact Analysis
4.1.5 Cumulative Impacts, and
4.1.6 Mitigation Measures
However, when I go to the Table of Contents, I see ONLY "4.1 Aesthetics" referencing the entire 73
page.
I ask please - why would the Sections relevant to each Chapter not be included? - please see 2. below.
Response 34-c:
The commenter's suggestion is noted. Including the subsection page numbers in the Table of Contents
is not required under CEQA, nor would it change the findings within the Draft EIR.
Comment 34-d:
2. Inclusion of the Subsections and Tables in the Table of Contents - with numbers, letters and bullets
as appropriate and appropriately cross referenced to pages in the Document.
It is the subsections that pose an issue for the average reader such as myself.
For instance, when I proceed to go through Section 4.1.4 Project Impact Analysis, I note
the following "Subsections"
Thresholds of Significance
Methodology
Proposed Project
Character and Development Standards
PAI
PA II
PA III
PA IV
Circulation
Design Guidelines
Planning Area I - Neighborhood Commercial
Materials
Planning Area II - Low Density Residential
Materials
Massing and Scale
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Architecture
Planning Area III - Tourist Commercial
Materials
Massing and Scale
Architecture
Planning Area III - Tourist Commercial
Offsite Infrastructure
Project Impacts
a. Have a substantial adverse effect on a scenic vista?
Location "A"
Location "B"
all in different fonts, different sizes, some italics, some not, non indented, etc.; and these are in
only the first 25 pages of the 73 for this Section!
I believe that you can see where I am going with this "illustration" above. This is not an easily readable
document, but in particular it is not an easy document to reference and therefore understand.
My example refers to just Section 4.1.4 - the layout therein is the same throughout the entire
Document.
From my particular perspective as I conduct my review, I found that I am required create my own
"table of contents" for my ability to cross reference to allow for my understanding.
Additionally, an expanded Table of Contents might allow me to gather data on a particular item - for
instance, the lighting. In one sub - section, its says that towers are 80 feet high, in another it says that
they will be lit from 7 AM - 10 PM, in another it says that there will be 17 - 80 foot towers. etc. If this
data is NOT provided in one sub- section, then at least a Table of Contents as requested might be of
help going forward.
I can assure you that this is no easy task to begin to gather and assimilate this data - as I attempt to
provide an intelligent response to the Draft EIR. An expanded table of Contents with corresponding
"lists" within the document itself would go a long way to helping me do this.
Response 34-d:
The commenter's opinions regarding the document format are noted. Please see Response 34-c, as
well as the Ability to Comprehend the Draft EIR Topical Response in Section 2.2.7.
Comment 34-e:
3. If it is possible, I would like the Document re -issued as a "searchable" PDF with hyperlinks as
required to the Appendices. Modern technology easily allows for this.
Response 34-e:
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The commenter's opinions are noted. The documents are searchable. All of the Appendices, as well
as the Draft EIR, were available on the City's website, at:
https://www.laquintaca.gov/our-city/city-departments/design-and-development/planning-
division/the-wave-at-coral-mountain
Comment 34-f:
4. I would like to see the entire Document proof read with respect to page numbers please. For
instance, I see that Section 4.1 has pages marked 4.1 ... whereas 4.2 has pages also marked 4.1, ... -
instead of 4.2.X.... Simple proof reading would have caught this error - I'm asking please that you have
someone do this. That way, when I make my own notes to refer to, I am not going back through the
document and unable able to find what I am looking for because I am dealing with errors in the page
numbering system.
Response 34-f:
Section 4.2, Air Quality, in the Draft EIR was incorrectly paginated. The commenter is correct, and
the City apologizes for the error. The pagination of Section 4.2 is hereby corrected — please see
Chapter 3.0, Revisions to the Draft EIR. This revision does not result in changes to the findings of the
Draft EIR.
Comment 34-g:
5. I would like to see sub -sections entitled CONCLUSIONS limited to ONE per Section, please. Too
many of these have lead to my confusion on the topics therein.
Response 34-g:
The commenter's opinion is noted. Sections within the Draft EIR may include multiple conclusions
due to the various components within the threshold discussion. For example, analysis of threshold c)
in Section 4.1, Aesthetics, includes discussions of each Planning Area proposed for the project and
their impact on scenic quality in the area. For this discussion topic, analysis of each Planning Area's
impact requires a conclusion to summarize the level of impact for that Planning Area. Therefore, this
discussion results in multiple "conclusion" discussions, as do other topics with multiple components
within a threshold discussion. The structure is appropriate and consistent with the requirements of
CEQA for thorough analysis.
Comment 34-h:
In closing, I wish to say that this Project is very complex and potentially impactful to the residents
around it on so many levels.
There are many aging residents who reside in retirement communities near this proposed Project.
Many have invested their life savings in their forever homes and feel very afraid because they cannot
fully understand what this Project entails. Many can no longer concentrate to the extent that they
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once could and are easily overwhelmed. Many are not computer savvy. Some have told me that they
feel inadequate and even "stupid" when they admit that they cannot "understand" the DEIR when
they try to read it.
My reply to them as been that "I feel inadequate as well" when faced with such a lengthy and
redundant document. You have indicated in your email today that redundancy "is required" for the
completeness of the document. Thank you for this explanation as I now understand and accept that.
However, and to that I would say ... there should be extra attention on the City's part then to ensure
that as much detail is provided for the benefit of all readers in such a manner as to allow for complete
understanding. The acknowledgement and implementation of my 5 comments above would go a long
way to providing for this.
Thank you for your kind consideration of my request.
I look forward to hearing back from you.
Response 34-h:
The commenter's opinions and characterizations are noted. Please see the Ability to Comprehend the
Draft EIR Topical Response at Section 2.2.7, and the Length of the Draft EIR Topical Response at
Section 2.2.6.
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Comment Letter No. 35: George Koenig
Date: July 14, 2021
Affiliation: Area Resident
Comment 35-a:
18 years ago my wife and I moved to La Quinta and have been delighted over these years for the
move. During this time La Quinta has developed its commercial base in a logical and geographic
manner and has maintained a wonderful residential environment. I was surprised at the proposed
project of a water park at Coral Mountain, as discussed nicely in a recent article in the Desert Sun.
I read the article, perused the project on-line, obtained a bigger printout at City Hall, and drove to the
site to view it. I was left with a number of questions.
Response 35-a:
Comment noted. The commenter's questions are addressed in Responses 35-b through 35-g below.
Comment 35-b:
I believe the site was once part of the initial plans for Andalusia but was spun off as economically
unfeasible. In fact I understand the developer — Drummond, a corporation with enormous financial
reserves — has subsequently sold Andalusia as well. The site is roughly six miles from Citrus Plaza
(Jefferson and 50) at the very end of Madison, a long way if one has forgotten a grocery item. If
Andalusia failed to flourish one must wonder about the new proposal. The rationale for a new
development of expensive homes is puzzling.
Response 35-b:
The commenter's opinions are noted. The comment does not raise any questions or concerns
regarding environmental effects of the project, and for that reason, no further response is provided.
Comment 35-c:
The entire length of Madison Avenue is full of high-end residential developments. A major resort
would be in sharp contrast to the environment surrounding it. Independent of the wave a hotel of
any viable size would be completely out of place; issues to include building height and traffic.
Response 35-c:
Please see Responses 15-d, 17-a and 17-c. Project consistency with the General Plan is analyzed in
Section 4.10, Land Use and Planning, of the Draft EIR.
Section 4.1, Aesthetics, of the Draft EIR analyzed the project's impacts on the surrounding scenic
vistas when viewed from public viewpoints. For this discussion, line of sight exhibits and visual
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simulations were generated in order to determine the project components that may impact the
public's views of scenic resources. As shown on Exhibits 4.1-4 through 4.1-13, on pages 4.1-29
through 4.1.38, and analyzed on pages 4.1-22 through 4.1-28, it was determined that the proposed
hotel would not be visible from outside the project site.
Section 4.13, Transportation, of the Draft EIR fully analyzes project -related traffic impacts of the
proposed project, and provides mitigation measures proposed to reduce impacts to less than
significant levels. Findings were generated based on technical studies performed by professional
traffic engineers, and are included as Appendix L.1 and L.2 in the Draft EIR. Please also refer to the
Topical Response on Traffic at Section 2.2.5. The commenter does not provide further detail regarding
his traffic concerns, so it is not possible to provide additional detail in response to the comment.
Comment 35-d:
This plan calls for a golf course. I think a number of golf courses are experiencing a decrease in use.
The area is also surrounded by a number of courses — PGA, Silver Rock, and others. Who would be
the market target for a new distant course is unclear.
Response 35-d:
The commenter's opinion is noted. The project allows potential use of golf facilities (e.g., par 3 course
or putting green), however, the development of a full-size golf course is not proposed for the project.
Comment 35-e:
Although the proposal for WAVE phenomenon's sound abatement is discussed, it seems likely that
such a feature is likely to be noisy — whatever good intentions of the builder. Since it is unlikely that
the immediate neighborhood would use the structure, one must assume that the users would not be
local, more likely a youthful and loud group. How this would sit with the owners of expensive homes
immediately adjacent would surely affect their sales prospects.
Response 35-e:
The commenter's opinions regarding the users of the Wave Basin and the marketability of the project
are noted. Please see the Topical Response on Noise at Section 2.2.4, and Section 4.11 of the Draft
EIR. In addition, a Noise Study was complete for the proposed project by a professional noise engineer
using state and local methodologies to determine whether project development and operation would
result in significant impacts. The findings concluded that impacts would be less than significant with
the incorporation of mitigation measures. As described on pages 4.11-47 to 4.11-50, the noise levels
during operation of the Wave Basin are estimated at 64.5 dBA at receptor location P10, located
immediately adjacent to the Wave Basin in the Tourist Commercial planning area. The combined noise
level from the project and ambient noise levels at the off-site location nearest the Wave Basin
(location R7) are estimated at 58.2 dBA, which reflects an increase of 0.3 dBA over existing ambient
noise levels (see Table 4.11-26 on page 4.11-49 of the Draft EIR). These noise levels will not exceed
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City standards or the thresholds of significance described on pages 4.11-47 through 4.11-49, and
shown on Tables 4.11-25 and 4.11-26, and explained in greater detail in Section 4 of the Noise Study
attached as Appendix K.1 of the Draft EIR. The conclusion of the Draft EIR that the noise impacts of
daily operations will be less than significant are correctly characterized in the Draft EIR.
Comment 35-f:
The Desert Sun noted 3 other water park developments underway or about to begin development.
All three would not only compete for a limited market but would be located in far more convenient
locations for prospective customers — remembering the really isolated site under consideration. How
the Coral Mountain wave would attract customers is surely unclear.
Response 35-f:
The commenter's opinions are noted. The comment does not raise any questions or concerns
regarding environmental effects of the project, and for that reason, no further response is provided.
Comment 35-g:
If one considers all the headaches and frustrations with Silver Rock, certainly a better conceived and
eventually successful undertaking I would understand if the City would approve what looks like an
even less viable undertaking with profound concern. If it were to proceed and then fail who would be
left holding the bag? The City? Who would want to acquire an isolated development with a water
park?
The "Wrong Project in the Wrong Place" certainly seems an appropriate comment. Personally I would
not invest my money in it.
Thank you for the opportunity to comment.
Response 35-g:
The commenter's opinions are noted. As it relates to the approval or denial of the project, please see
Response 15-d, 17-a and 17-c.
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Comment Letter No. 36: Sandra Stratton
Date: July 15, 2021
Affiliation: Area Resident
Comment 36-a:
WATER SUPPLIES:
Please take into serious consideration the Mega Drought that the Western US is experiencing. I do
not believe that the reports on water available from our aquifer accurately address the water sources
to replenish our aquifer to keep it at safe levels for the foreseeable future.
I am a resident of Trilogy La Quinta and a California native. The drought is severely impacting farmers
and ranchers here and the western US. One newspaper article in Oregon highlights forward thinking
errors.
"It was predicted that Prineville Reservoir would fill. It was predicted there would be natural flow for
us with our water right in the Crooked River. It was predicted there would be natural flow for us in
the Deschutes (river). NONE OF THOSE THINGS HAPPENED." - Marty Richards, board chair for North
Unit, said the drought conditions this spring and summer forced the irrigation district to reevaluate
its water supplies." Farmers/ranchers are losing their water supplies. The Wickiup Reservoir will be
empty by August 18.
My point being, why are we relying on the Colorado River without question for our precious water
supply here in the desert. "The Colorado River is drying up faster than federal officials can keep tract.
Mandatory water cuts are looming. Plummeting reservoir levels at Mead and Powell solidify Arizona
cutbacks next year and near -future threats to all Compact states from Colorado to California" (source:
The Colorado Sun)
Response 36-a:
Please see the Topical Response on Water Resources at Section 2.2.3, as well as Section 4.9,
Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems in the Draft EIR.
As explained in more detail in the Water Resources Topical Response discussion in Section 2.2.3 of
this Chapter, CVWD's long-range planning and groundwater management efforts take into account
the risks associated with climate change, including extended drought conditions and potential
reductions in water deliveries from the Colorado River and State Water Project exchange. Even taking
into account these risks, CVWD has projected that groundwater storage in the Indio subbasin will
increase by a cumulative total of 1,394,000 acre-feet over the 50 -year period it modeled, taking into
account both climate change and future CVWD planned projects, and projects an increase of more
than 600,000 acre-feet of groundwater storage by 2045 (see Topical Response on Water Resources
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at Section 2.2.3, at pages 2-23 — 2-26 and Figure ES -6). As also described in the Water Resources
Topical Response at Section 2.2.3 and the Indio Subbasin Water Management Plan Update (Chapter
11), CVWD has considered the challenges to long-term reliability of Colorado River and State Water
Project allocations, including climate change and extended periods of drought, and has identified a
combination of source substitution and improved conveyance and storage projects, as well as
conservation measures, to ensure the long-range successful management of the Indio Subbasin
without causing overdraft conditions. Based on the foregoing, CVWD determined that there are
adequate supplies of water to serve the proposed project and all other existing and planned future
uses in the area, as confirmed in the project -specific WSA/WSV approved by CVWD.
Comment 36-b:
LIGHT POLUTION:
Every morning and evening I sit outside and enjoy the beautiful Coral Mountain and it's changing
colors at sunrise and sunset. Seventeen 80 foot tall light towers will permanently ruin everyone's
views of the Coral Mountain.
Response 36-b:
Please see the Topical Response on Light and Glare in Section 2.2.1, as well as Section 4.1, Aesthetics,
of the Draft EIR. As analyzed on pages 4.1-60 through 4.1-70, the potential impacts of the light fixtures
were demonstrated to have potential impacts (please see also the specific discussion of light levels
surrounding the lights in the Light and Glare Topical Response above). As shown in these two
documents, light levels will conform to the City's standards, and no light will be generated at the
property line. Further, the lighting demonstration results described on pages 2-9 and 2-10 above,
shows that no light from the proposed Wave Basin lighting will reach Coral Mountain (see light
contour exhibit on page 2-10 above, which shows that light levels drop to the imperceptible level of
0.01 foot candles at approximately 375 feet from the nearest portion of Coral Mountain. The Draft
EIR provides mitigation to reduce impacts to less than significant levels. Section 4.1 also analyzed the
line -of -site and visual simulations of the light poles at the Wave Basin. As demonstrated in Exhibits
4.1-4 through 4.1-13, and in the text on pages 4.1-22 through 4.1-18, the poles will not be visible from
most off-site locations and will not block views of Coral Mountain. From Trilogy, where the
commenter lives, line -of -sight E on Exhibits 4.1-12 and 4.1-13, and the discussion on pages 4.1-27 and
4.1-28 provides analysis of the views from the southeast. As described in that discussion the light
poles will not significantly disrupt views toward Coral Mountain from this location due to the distance
from the poles, the limited scale of the poles and light fixtures, and existing off-site trees that obstruct
views from this location.
Comment 36-c:
STVR's:
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The city of La Quinta has suspended permits for STVR's in residential zones. The impact of 600 STVR's
will impact the surrounding communities far more that[than] allowing them in residential zones.
Response 36-c:
The commenter's opinion on short-term vacation rentals (STVR) is noted. However, he does not
provide substantial evidence to indicate how STVRs would impact the communities more than
residential communities. All short-term rentals will be centrally managed within the project, and will
be subject to the City's noise ordinance and the Short -Term Vacation Rental restrictions set forth in
Chapter 3.25 of the La Quinta Municipal Code. Please also see Response 52-g.
Comment 36-d:
ZONING CHANGE:
This area is not appropriate for Tourist Zoning. Having special events will cause more traffic, noise,
rowdy parties at the STVR's. This will turn 58th and 60th and Madison into major traffic arteries. We
already have car races on 60th and cars doing doughnuts at the corner of Madison and 60th. Look at
the tire marks! Was this in a report? This will only encourage more traffic problems.
To call this project a PRIVATE COMMUNITY is a joke. Only a small amount of lots, roughly 24, are
private. 24 private homes vs 600 STVR's? That proportion makes absolutely no sense. The few private
lots are just a way to make the whole project look private. It's a PUBLIC VENUE!!
Response 36-d:
Project consistency with the General Plan is analyzed in Section 4.10, Land Use and Planning, of the
Draft EIR. Please also see Responses 15-d, 17-a and 17-d as they relate to the required change of zone,
and the review process for the project.
To address traffic concerns, please consult the Traffic Topical Response at Section 2.2.5, above, and
Section 4.13, Transportation, of the Draft EIR. Potential traffic impacts from Special Events are
analyzed on pages 4.13-42 through 4.13-46. As shown in Table 4.13-27, a traffic signal is required at
the intersection of Madison Street and Avenue 58 to maintain acceptable levels of service, while an
all -way stop intersection is sufficient at the intersection of Madison Street and Avenue 60. As
confirmed on page 4.13-41 of the Draft EIR, the project is required to install the traffic signal at the
intersection at Madison/Avenue 58, and pursuant to Mitigation Measure TRA -9, if any special events
are proposed prior to installation of this signal, the required temporary use permit will be denied
unless the City finds that the event -specific traffic and parking plan demonstrates that the event will
not cause any significant traffic or parking impacts (see Draft EIR p. 4.13-62). Please also see the Noise
Topical Response at Section 2.2.4, above, for a description of the noise analysis completed for the
project which determined that noise levels will not exceed the City's established limits and will not
have any significant impacts on the surrounding communities, including from special events.
Compliance with the City of La Quinta Municipal Code will further assure that the proposed zone
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change and special events at the project will not impact the surrounding communities, including from
noisy or rowdy parties. The comment does not include any substantial evidence of any potential
impacts that could result from the proposed zone change to allow tourist commercial uses on a
portion of the site or from the proposed special events.
As it relates to the commenter's description of the project, the project could result in up to 600
privately owned residential units. As shown in Table 2 of the Specific Plan, up to 104 privately owned
residential units will be located in the Tourist Commercial portion of the project (Planning Area III),
and the remaining 496 residential units will be located in the low-density residential areas (Planning
Area II). As it relates to the project being private, as stated on page 3.5.3 of the Draft EIR project
description, the project will be private (with the exception of the 60,000 square feet of neighborhood
serving commercial near Madison St. and Avenue 58), with access to the homes, the hotel and its
amenities, and the Wave Basin open only to residents, their guests and hotel guests (also see Section
1.2 of the Specific Plan, confirming same).
Comment 36-e:
This entire project is totally irresponsible. This is California with 700+ miles of coastline. A surfing
venue does not belong in the desert! This would be a permanent disruption to our quiet life in the
desert, ruin our views, destroy our quiet evenings, just so promoters and surfers can make money on
Special Events.
Response 36-e:
The commenter's opinion regarding the location of the project is noted.
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Comment Letter No. 37: Connie Glavin
Date: July 16, 2021
Affiliation: Area Resident
Comment 37-a:
Wave park please no attached photos are a big horn crossing 58 where would he go if not killed by a
car coming to a wave park where he lives.
Response 37-a:
The photo provided by the commenter is acknowledged, and assumed to be of Avenue 58 west of
Madison Street. As described in the Topical Response on Biological Resources at Section 2.2.2, the
project has been modified to provide a barrier on its west boundary to protect PBS from the site. In
addition, a 6 -foot wall will surround the project. Finally, the CVCC, as described in Comment and
Response 13-h, is currently planning a barrier along the eastern toe of the Santa Rosa Mountains
extending south from the existing sheep barrier along the Silver Rock property (also see Response 13-
d above and Appendix D.5 to this Final EIR). The barrier is designed to prevent the current access by
PBS onto private property in this part of La Quinta. Together, these measures will provide protection
from human activity, and prevent sheep from accessing local streets.
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Comment Letter No. 38: Dan Rendino
Date: July 18, 2021
Affiliation: Area Resident
Comment 38-a:
Who came up with this insane idea to turn our town into a Disneyland in the middle of a drought. The
traffic and noise will be an Eyesore in the desert. Send this proposal down.
Response 38-a:
The commenter's opinion is noted. He does not, however, provide substantial evidence or facts
regarding his objections. As it relates to traffic concerns, Section 4.13, Transportation, of the Draft
EIR analyzed traffic generated by the project. Impacts resulting from the project as well as the
proposed special events are discussed and analyzed, and mitigation measures are provided on pages
4.13-61— 4.13-63 to reduce impacts to less than significant levels.
As it relates to noise concerns, Section 4.11, Noise, of the Draft EIR address impacts resulting from
the project as well as the proposed special events. Additionally, mitigation measures are provided on
pages 4.11-54 — 4.11-55 to reduce impacts to less than significant levels.
As it relates to the review process required for the project, please see Responses 15-d, 17-a and 17-
c.
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Comment Letter No. 39: JoAnne Thompson
Date: July 18, 2021
Affiliation: Area Resident
Comment 39-a:
We will make this short and sweet. Please do the right thing about the proposed Wave Park in La
Quinta. We are in the worst drought in 1000 years. Do you think this Wave Park makes sense on any
level?
We strongly oppose this development and hope you will hear our voices.
Response 39-a:
The commenter's opinion is noted. Analysis of water supply is provided in the Topical Response on
Water Resources at Section 2.2.3, as well as Sections 4.9, Hydrology and Water Quality, and Section
4.15, Utilities and Service Systems, of the Draft EIR. These sections contain a thorough analysis and
explanation of the project's projected water use and the available water supplies to serve the project
and other existing and planned uses in the short and long term. CVWD, as the water supplier of the
project evaluated and approved water use for the project based on compliance with its standards and
requirements, and consistent with California Water Code Section 10910. The EIR and WSA/WSV
clearly demonstrate that CVWD has adequate water supplies to meet the needs of the project and all
other existing and planned future uses, including under extended drought conditions.
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Comment Letter No. 40: Carol and Richard Strop
Date: July 19, 2021
Affiliation: Area Resident
Comment 40-a:
Let me start by saying my husband, Richard, and I love everything about La Quinta, how is was
designed and how it is managed. Of course we know that additional growth leading to increased
revenue is important for any city. When the builder first introduced this Coral Mountain project to
the homeowners at Trilogy La Quinta las February I thought, as presented, it sounded reasonable.
The La Quinta city planners obviously thought so, too. Videos were shown to the residents of the
Wave in Lemoore, CA and each was conveniently orchestrated with music overlays as are all videos
on the Surf Ranch website.
There are various resident complaints and concerns on many fronts in all the surrounding
communities. I would like to focus mine on the Wave, its level of noise, water usage and proposed
popularity, I think the most important things I learned in my Internet research are these:
Response 40-a:
The comment is noted. Specific responses to the commenter's concerns are addressed individually
below.
Comment 40-b:
1. Kelly Slater's Wave in Lemoore (now owned by WLS Holdings) is in the middle of nowhere, set in
wide open farmland of cows and agricultural fields in Central California. And that is where it belongs,
not in an upscale residential community where the residents who moved to this end of the Coachella
Valley came for a quiet, peaceful lifestyle. Many are retired and home all day, with no escape from
the sounds of the wave.
2. The wave is pulled by a locomotive engine. This will not be the sound of an occasional train passing
through, but a constant sound throughout the day and evening. My husband and I have lived in the
mountains and know firsthand how the sound bounces off them. Months ago I read reviews by surfers
related to noise of the Wave but those reviews have magically disappeared from the Internet.
Response 40-b:
The commenter's opinion of the location of the Wave Basin is noted. As it relates to noise levels, the
Draft EIR provided a complete analysis of the daily noise levels in Section 4.11, Noise. As described in
Table 4.11-26 and in the analysis on pages 4.11-44 — 4.11-50, noise levels at the boundary of the
project will range from 48.7 dBA to 62.6 dBA, including existing ambient noise, which is consistent
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with the City's noise standards for residential areas (please also see the Topical Response on Noise at
Section 2.2.4, which further describes the noise standards upon which the analysis was based).
Based on the findings of the technical study and the Draft EIR, noise levels at the Wave machine would
range from 62.6 dBA to 75.7 dBA at 212 feet from the wave machinery. With distance, this will be
reduced to 63.3 dBA at 50 feet, and 59.3 dBA at the nearest off-site location, which is well within the
City's standards (see Draft EIR pages 4.11-23 and 4.11-45 — 4.11-46). Impacts associated with the
Wave Basin and associated machinery would be less than significant when compared to the City's
established thresholds, which is consistent with the requirements of CEQA. In addition, to reduce
impacts of noise levels to the greatest extent feasible mitigation was included to restrict the
operational hours of the proposed Wave Basin to the hours of 7:00 a.m. to 10:00 p.m., compliant with
the La Quinta Municipal Code (NOI-6) for sports facilities.
The Noise Memo provided by Urban Crossroads, Inc. (Appendix K.2 of the Draft EIR) addressed the
concern regarding noise of the Wave Basin echoing off of Coral Mountain. The noise engineer
explained that based on Federal Highway Administration guidance and studies, noise bouncing off a
hard surface can cause noise increases of no more than 1-2 dBA, which is not perceptible to the
human ear. Given the distance between the Wave Basin and Coral Mountain (approximately 650
feet), the soft surfaces over that distance that absorb sound, and the maximum, worst-case noise
levels generated at the Wave Basin (75.7 dBA), the Wave Basin will not cause significant noise levels
or noise impacts at Coral Mountain or in the surrounding communities. Again, as explained above,
the noise levels will not exceed the City's standards, and impacts were correctly determined to be
less than significant.
Comment 40-c:
3. The Wave Pools require enormous amount of water to pump out artificial waves. According to
Wired, the Surf Ranch in Lemoore is filled with 15 million gallons of UV -and chlorine -treated water —
250,000 of which can evaporate form the lagoon on an extremely hot day. Really, here in the desert?
And on June 21, 2021 a major water tank exploded in Lemoore —just mentioning it...
Response 40-c:
Please see the Topical Response on Water Resources at Section 2.2.3, as well as Section 4.9,
Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems in the Draft EIR. As
described on pages 2-16 through 2-18 above, and taking into account evapotranspiration factors
specific to the Coachella Valley and established based on CVWD data and criteria, the Wave Basin will
use approximately 120 AFY, which amounts to approximately 14.9 percent of the project's total
annual outdoor water demand, and 12.47 of total project water demand. CVWD has established a
formula for calculating water lost to evaporation based on an established evapotranspiration rate for
the project area (64.22 inches per year for this portion of La Quinta), an evapotranspiration factor of
1.2 for a moving body of water to account for the increased evaporation rate over a lake in the area,
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and the surface area of the water body. In this case, the calculations assumed the entire Wave Basin
of 18.72 acres would contain water. However, the water body itself occupies only approximately 12.5
acres, thus resulting in a conservative calculation of evaporation from the Wave Basin (see page 2-18
above and pages 3-19 and 3-20 of the Draft EIR).
The Draft EIR correctly analyzed that CVWD has determined that there are adequate supplies of water
to serve the proposed project and all other existing and planned future uses in the area, as confirmed
in the project -specific WSA/WSV approved by CVWD.
Finally, in response to the reference to an explosion at a water tank in Lemoore, that water tank was
a public works project having nothing to do with the Kelly Slater wave basin in Lemoore, California. It
raises no environmental or safety issues relating to the proposed project. (Also see
https://www. msn.com/en-us/news/us/massive-lemoore-blast-why-was-there-gas-in-water-tank-
before-deadly-explosion/ar-AALrFo8.)
Comment 40-d:
4. Last year the quarantine prevented me finding many surfer reviews but just today I found that
there had been a Jeep Surf Ranch contest in Lemoore in June, 2021. The Wave may not be the
economic boom the city hopes for. Here is an excerpt regarding that contest —
https://beachgrit.com/2021/06/why-did-surf-ranch-fail-as-wave-pool-tech-and-as-a-contest-so-
The gap between the rhetoric, that tubs were going to loose a tsunami of radical innovative surfing,
and the reality, conservative surfing, is becoming clearer every day. It's become what Orwell termed
the "inadmissible fact." It's put us in upside down world, where Chris Cote, when he hears the train
says, "This never gets old" means "there's something deeply wrong here but 1 can't dare acknowledge
it.
On a recent post featuring the seven -time world champion Stephanie Gilmore at the tank, World Surf
League fans wrote,
Snooze, Throw in the air section.
Most uninteresting event on tour. Every time I see this wave I keep scrolling.
Good for training, horrible for contest. RIP WSL.
S000000000 b0000ring.
Same commentary on every wave... stick to mother ocean.
And so on.
5. Attendance at the Wave is costly. Who is really the market for it and how large can it be to support
this? From site December 27, 2018
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This autumn Big Dog got an invite from a group of friends pitching in to buy a day at the Kelly Slater
Surf Ranch. For $32,000 off-season rate (peak season is $50K), surfers get 15 waves per hour during
an 8 -hour day to share. This means the glorious locomotive wave -maker will run along the tracks 120
times during your session. So for example, if you bring 16 surfers for an off-season day, that works out
to $2,000 a surfer. Each one will get 7 -to -8 priority waves.
Response 40-d:
The comment is noted. The popularity of the project is not a topic relevant under CEQA.
Comment 40-e:
The La Quinta draft Environmental Impact Report for the Coral Mountain Resort considered noise to
be "less than significant with mitigation measures". Below is an excerpt from the operational noise
impact report prepared by Urban Crossroads.
Quoted from section recreational pool (wave basin) EIR Urban crossroads.
OPERATIONAL NOISE ANALYSIS Using reference noise levels to represent the expected noise sources
from the Coral Mountain Specific Plan site, this analysis estimates the Project -related stationary -
source noise levels at nearby sensitive receiver locations. The normal activities associated with the
proposed Coral Mountain Specific Plan are anticipated to include wave basin/wave machine activity,
outdoor pool/spa activity, outdoor activity, and neighborhood commercial land use activity. The
operational noise analysis shows that the Project -related stationary -source noise levels at the nearby
sensitive receiver locations will satisfy the City of La Quinta daytime exterior noise level standards,
with no planned nighttime activities. Therefore, the operational noise impacts are considered less
than significant at all existing off-site receiver locations.
What are the mitigation procedures to which you refer to in the EIR? And what about nighttime noise?
The advertising includes evening hours. Has someone from the City of La Quinta actually visited
Lemoore to assess the level of noise? Maybe this is a big deal about nothing! But the utilization of
energy and water resources needed to run this Wave is not.
Response 40-e:
Please see Response 40-b. As it relates to nighttime hours, and as described on page 4.11-9 of the
Draft EIR and page 14 of the Noise technical report (Appendix K.1), nighttime hours are defined as
the period 10:00 p.m. to 7:00 a.m. by the City of La Quinta, based on well-established federal and
state standards. The mitigation referenced in the EIR is provided to limit operations so that there will
be no Wave Basin activity between 10 PM and 7 AM (Mitigation Measure NOI-6 on page 4.11-55). As
operation of the Wave Basin will not be permitted during nighttime hours, it will not contribute to
noise levels during nighttime hours., and the Draft EIR correctly determined that impacts will be less
than significant.
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City staff have not made any formal visits to the Lemoore site to assess the level of noise; however,
technical noise experts from Urban Crossroads, Inc. visited the Lemoore site on April 13, 2020 to
measure noise at various locations for their analysis of operational noise at the proposed project.
Please see the Topical Response on Noise in Section 2.2.4, Section 4.11, Noise, of the Draft EIR, and
the Noise Study and Noise Memo (Appendix K.1 and K.2 of the Draft EIR) for further discussion of
their visit to the Lemoore site.
Finally, the energy required to operate the Wave Basin is analyzed and discussed on pages 4.5-25 and
4.5-28, which determined that while the project will result in a long-term increase in demand for
electricity, the project will comply with Title 24 and CALGreen energy efficiency requirements and will
not have any significant environmental effects.
Comment 40-f:
We hope you and the builder will consider one of the other scenarios that exclude the Wave as shown
in the Urban Crossroads appendix SCH# 2021020310 for trip generation comparison. I have to say,
the traffic analysis report, in itself, is mind-boggling. Hotel revenues are great for the City, but there
two exclusive hotels already being built just up the road across from PGA West.
Please take care of your year round residents; there are more and more of us. And in an economic
downturn, we are your revenue base. The builder will be long gone, along with the hotel guests.
Response 40-f:
The commenter's concerns are noted. The commenter, however, does not provide sufficient
information regarding the traffic study to provide a response.
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Comment Letter No. 41: Alena Callimanis
Date: July 20, 2021
Affiliation: Area Resident
This comment is referring to a PowerPoint presentation to be presented at the City Council meeting
held on July 20, 2021.
Comment 41-a:
Monika, I created this file 'without video' so it is very small. This way I respectfully request that it can
be now distributed to the Council and staff. I still hope we can show my version with the videos. [This
comment is referring to a PowerPoint presentation to be presented at the City Council meeting held
on July 20, 2021.]
"Impact of Coral Mountain Surf Resort." [Presentation by Alena Callimanis]
Response 41-a:
Comment noted. The presentation was made by the commenter at the Council meeting.
Comment 41-b:
Right after Sunset Looking at Coral Mountain from Lisa Castro's house on 60th. Night sky panorama
on 60th from Guillermo's house across Coral Mountain to Lisa's House July 19 at 8:38 pm.
Video of Night Sky and sound: Coral Mountain from Guillermo's house to Lisa's house.
Video removed due to size. This video shows the dark Coral Mountain and features only the sound of
crickets. Request copy of video from acallimanis@gmail.com.
Video removed due to size. This video shows the dark Coral Mountain area and the sound of a car
on Madison. Madison is further from this point than from this point to the Wave Basin. Request copy
of video from acallimanis@gmail.com.
Picture from the 58th St near Madison — what is that light?
Bagdouma Park in Coachella — Light is always diffused and visible due to particulates in our air (the
light on the right is 60 feet).
Please don't let the developer insult us by saying there will be no light and noise impact to the
surrounding developments.
This will be physically impossible considering the location with quiet nights in this area of the desert,
plus the proximity to Coral Mountain with sound echoing and reverberation off the mountain and
light reflection and dispersion.
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Response 41-b:
The Draft EIR does not state that there will be no impacts from lights and noise as a result of the
project. Please refer to Section 4.1, Aesthetics, and Section 4.11, Noise, of the Draft EIR and the
Topical Response on Light and Glare at Section 2.2.1, above. Due to the vacant condition of the site,
the project property does not currently contribute to the existing light in the City or to the existing
noise environment. Any development on this site would introduce light and noise to the area. The
existing condition of the site is stated throughout the Draft EIR. As discussed on pages 2-5 through 2-
11 in the Topical Response on Light and Glare above demonstrates that the project will not have any
significant light or glare impacts on the surrounding communities because the lights are shielded and
oriented to effectively light the Wave Basin while avoiding any light spillage off the project site. Please
see lighting contour exhibit on page 2-10 that shows the outer extent of any perceptible light from
the Wave Basin lighting system. Likewise, the noise analysis summarized on pages 2-27 through 2-31
of the Topical Responses above demonstrates that the project will not generate any significant noise
impacts on the surrounding communities. In addition, mitigation measures are presented in the Draft
EIR, on pages 4.1-72 — 4.1-73 for light and on pages 4.11-54 and 4.11-55 for noise to reduce impacts
to the greatest extent feasible. The Draft EIR correctly analyzed these impacts and whether the
impacts required mitigation.
As it relates to noise echoing or reverberating off Coral Mountain, please see pages 2-30 and 2-31 in
the Topical Responses above, and Appendix K.2 in the Draft EIR.
Comment 41-c:
Excerpts from La Quinta General Plan 2035 — Land Use
Policy LU -3.1
Encourage the preservation of neighborhood character and assure a consistent and compatible land
use pattern.
GOAL LU -4
Maintenance and protection of existing neighborhoods.
Policy LU -4.1
Encourage compatible development adjacent to existing neighborhoods and infrastructure.
GOAL SC -1: A community that provides the best possible quality of life for all its residents.
GOAL OS -3: Preservation of scenic resources as vital contributors to the City's economic health and
overall quality of life.
Response 41-c:
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The Draft EIR analyzes project compliance and consistency with the City General Plan in Section 4.10,
Land Use and Planning, which concludes that the proposed project is consistent with the City of La
Quinta's goals and policies established for the City in the La Quinta General Plan. Per Section 4.10 of
the Draft EIR (page 4.10-17), the implementation of the Tourist Commercial land use designation and
the associated development of a recreational facility and hotel will promote the continued growth of
the tourism and resort industries in La Quinta by providing resort, recreational, commercial, and
residential land uses on the 386 -acre property. Additionally, the residential uses will incrementally
increase demand for commercial goods and services in the region, thus enhancing the economy. This
is consistent with Policy LU -5.2, Goal LU -6, and Policy LU -6.3 of the General Plan.
With respect to the specific General Plan policies and goals identified in the comment, the project is
considered consistent with these policies for the following reasons:
Policy LU -3.1: the project preserves the neighborhood character and assures a consistent and
compatible land use pattern by maintaining low-density residential development on approximately
232 acres around the northern, eastern and western perimeters of the site where similar residential
and golf resort communities already occur, and by requiring perimeter walls and landscaping that are
consistent with the surrounding communities and will screen the tourist commercial uses in the
internal portion of the site.
Goal LU -4: the project does not interfere with the maintenance and protection of any existing
communities, and as discussed in the Topical Responses above, will not cause any light, glare, noise
or traffic impacts that would affect existing neighborhoods in the area.
Policy LU -4.1: the project encourages compatible development adjacent to existing neighborhoods
and infrastructure for the reasons described above under Policy LU -3.1. The project site is surrounded
on two sides by existing arterial roads with utilities in place, as well as residential communities.
Goal SC -1: the project promotes the quality of life for all residents of the City by providing needed
sales and transient occupancy tax revenues to the City to fund police, fire and other public facilities,
which is particularly important in this portion of the City because the City will not receive property
tax revenue from the land in this area until 2035.
Goal OS -3: the project preserves the City's scenic resources by requiring substantial setbacks from
Madison Street and Avenue 58 for the perimeter walls and residential structures, in excess of the
City's existing requirements, to further reduce impacts on views of Coral Mountain and the Santa
Rosa Mountains, as required under Mitigation Measures AES -1 and AES -2.
Please also see Responses 83-w through 83-hh, below, for a detailed discussion of the project's
consistency with the General Plan's goals and policies.
Comment 41-d:
We want Low Density Residential at this site and not 100 percent STVRs and a Wave.
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Preserve this beauty and serenity for the five developments around Coral Mountain and for the new
100% low density residential development that should be on this magnificent this property.
Please no Zoning Change!
Response 41-d:
The commenter's preferences and request are noted. As they relate to the City's review of the project,
please see Responses 15-d, 17-a and 17-c.
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Comment Letter No. 42: Lisa Castro (sent by Alena Callimanis)
Date: July 20, 2021
Affiliation: Area Resident
Comment 42-a:
Here is the document that Lisa Castro will be using while speaking during the public comment period
at today's City Council meeting at 4pm.
Lisa will be in person.
Thank you very much.
Response 42-a:
The comments included in this presentation and responses to these comments are provided below.
Comment 42-b:
Good Afternoon Honorable Mayor Evan, Council Members and Staff. My name is Lisa Castro and I am
a resident at [removed for privacy]. First I would like to thank Alena for the pictures and videos she
showed you from my house. The videos just record the lack of noise from my house and that you can
slightly hear a car on Madison. Think of HOW many cars will come and go through the night in a
rezoned area.
Response 42-b:
The project -specific Traffic Impact Analysis (TIA) and VMT Evaluation prepared by Urban Crossroads,
Inc., calculated trips generated by the proposed project, and determined that the project will not
have any significant traffic impacts to the surrounding roads and intersections. Specifically, traffic
levels at Madison Street and Avenue 60, near the commenter's residence, are shown in Table 4.13-
23, page 4.13.39, to be at LOS B during both the AM and PM peak hour at build out of the project.
See Section 4.13, Transportation, of the Draft EIR and Appendices L.1 and L.2. The traffic analysis is
also summarized in the Traffic Topical Response in Section 2.2.5 of this Chapter.
Increases in noise levels generated by traffic on streets in the vicinity of the project site, including
Madison Avenue, are analyzed in Section 4.11 of the Draft EIR, at pp. 4.11-35 —4.11-41. The projected
increase in noise at adjacent land uses generated by traffic on Madison Street north of Avenue 60, as
shown in Table 4.11-19, EAC 2026 Off -Site Project -Related Traffic Noise Impacts, in the Draft EIR, is
0.6 dBA, an increase in noise that is small and would not be perceptible. The noise generated by
traffic would increase from 65.2 dBA to 65.8 dBA with the project at the portion of Madison Street
closest to the commenter's residence. As shown on Table 4.11-8 on page 4.11-21, increases in off-
site traffic noise of less than 1.5 dBA are not considered significant and are not audible to the human
ear. Please also see the Topical Response on Noise, in Section 2.2.4, above.
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Comment 42-c:
The point is that the Wave Basin is closer to me than Madison so if I can hear the car, just think of the
noise every night - not just the waves crashing as the promo for the developer says and the noise of
the wave machinery, but the people noise - surfing, jet skis, music etc, etc.... the "people noise" that
a rezoning change will allow. And the people noise at night will increase exponentially in the summer
because it will be too hot for them to "surf" during the day!!
Response 42-c:
Noise generated from the operation of the Wave Basin, associated machinery, and outdoor activities
was analyzed in the project -specific Noise Study (Appendix K.1 of the Draft EIR). Operational noise
generated from the project was determined to result in less than significant impacts. Noise levels at
sensitive land uses in the project vicinity were studied, including location R7, which is the residential
home located north of Avenue 60 about 37 feet to the east of the project (see Draft EIR pp. 4.11-22
— 4.11-23). As shown in Table 4.11-25, noise levels from project operations at this location are
projected to be 46.0 dBA, which is substantially below the City's significant noise threshold of 65 dBA
(see p.4.11-48). As shown in Table 4.11-26, the ambient noise level at location R7 is 57.9 dBA, and
the addition of project noise will raise this noise level to 58.2 dBA, or an increase of 0.3 dBA, which is
well below the threshold of significance. In fact, as noted on page 4.11-13 of the Draft EIR, noise
increases of 1dBA cannot be perceived in normal conditions, and increases of 3 dBA are considered
"barely perceptible." The findings of the project -specific Noise Study are discussed and analyzed in
Section 4.11, Noise, of the Draft EIR, and summarized in the Noise Topical Response in Section 2.2.4
of this Chapter.
Comment 42-d:
Also, water will be so hot during the summer months because it is only six feet deep at its maximum
on a concrete pool. And the evaporation alone is enormous.
Response 42-d:
With regard to the temperature of the water in the Wave Basin, the opinion is noted, but not
substantiated. The water in the basin will circulate regularly and, for this reason, water in the
shallower portion of the basin will remain substantially below ambient air temperatures and will not
be harmful to surfers (see Appendix M.2 of this Final EIR).
Please see the Topical Response on Water Resources, in Section 2.2.3of this Chapter, as well as
Section 4.9, Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems, of the
Draft EIR for analysis of the project's water use and hydrology impacts. Evapotranspiration was
analyzed in the project -specific WSA, using a factor established by CVWD for moving water bodies, as
described above in Section 2.2.3, and on pages 20 -24 of the WSA/WSV included as Appendix M to
the Draft EIR. Please also see Response 65-d regarding water evaporation.
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Comment 42-e:
I am a little more than halfway up the unpaved Avenue 60 toward Coral Mountain. I have lived there
for 30 years.
Guillermo and I are the closest houses to this development. It is fair to say the driveway into the
development as well as parking areas are right next to my house.
Response 42-e:
This location of the commenter's home in relation to the project site is noted, but the comment
misstates the location of the nearest project access, which is a secondary access to the project located
approximately 280 feet to the west of the adjacent residential property line (see Draft EIR Exhibit 3.9,
Vehicular Circulation Plan, showing the 24 -foot -wide secondary access entrance on Avenue 60, and
the description of project vehicular access on page 3-25, which states that a secondary entrance is
provided from Avenue 60). The project area closest to the adjacent residence is part of PA III -G —
Back of House, which will be graded as level, largely open land south of the Wave Basin. While parking
may be permitted in this area, no permanent parking lots or other improvements are proposed for
the area adjacent to this property line.
Comment 42-f:
I have spoken to Garrett Simon, the developer, many times at my house.
During the latest meeting he told me that I will not be impacted by light and noise.
I asked Garrett to please sign a document to that effect and he said no. I told him that I would be
severely impacted by the dust and dirt during construction, that I have asthma, and that my pool and
air conditioners would get clogged with dust and dirt.
His colleague with him told me to move away during construction. How insulting is that! Garrett told
me that the grading on the property would be done in six weeks. I know that it is closer to six months.
My family was in the grading business. Is he thinking he can push me around because I am alone?
Response 42-f:
The Draft EIR, including its analysis of construction -related air quality impacts, assumed that the
grading for all of Phase 1 would take 110 days, or 5 months (see pp. 4.2-20 - 4.2-21, which were
inadvertently misnumbered pages 4.1-20 and 4.1-21 but appear in Section 4.2 — Air Quality). As
shown in Table 4.2-6, the SCAQMD regional thresholds of significance will not be exceeded for any
criteria pollutants including PM10 and PM2.5 particulate matter. In addition, the potential for
localized air quality impacts at the commenter's residence were analyzed (location R7 was specifically
analyzed because it is the nearest sensitive receptor to grading activities), and with implementation
of Mitigation Measure AQ -2, no SCAQMD localized significance threshold will be exceeded at the
commenter's residence (see Draft EIR pp. 4.2-36 — 4.2-39).
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The City of La Quinta has adopted a Fugitive Dust Control Ordinance in the City Municipal Code
(Chapter 6.16). This Chapter establishes the minimum requirements for construction and demolition
activities and other specified sources in order to reduce man-made fugitive dust and the
corresponding PM10 emissions. Under the City's dust control regulations, a Local Air Quality
Management Plan (LAQMP) must be prepared and approved by the City for all phases of the project,
prior to any grading, earth -moving, demolition, or building operation. The Plan must include methods
to prevent sediment track -out onto public roads, prevent visible dust emissions from exceeding a 20
percent opacity, and prevent visible dust emissions from extending more than 100 feet (vertically or
horizontally from the origin of a source) or crossing any property line, thus avoiding any fugitive dust
impacts on off-site properties.
In addition, all project construction activities will be required to comply with the South Coast Air
Quality Management District (SCAQMD) Rules 403 and 403.1, which are enacted to reduce or prevent
man-made fugitive dust sources with their associated PM10 (particulate matter 10 micrograms)
emissions. The Final 2003 Coachella Valley PM10 State Implementation Plan (CVSIP) establishes
updated planning assumptions, fugitive dust source emissions estimates, mobile source emissions
estimates, and attainment modeling with control strategies and measure commitments. The CVSIP
established the controls needed to demonstrate expeditious attainment of the standards such as
those listed below:
- Additional stabilizing or paving of unpaved surfaces, including parking lots;
- A prohibition on building new unpaved roads;
- Requiring detailed dust control plans from builders in the valley that specify the use of more
aggressive and frequent watering, soil stabilization, wind screens, and phased development
(as opposed to mass grading) to minimize fugitive dust;
- Designating a worker to monitor dust control at construction sites; and
- Testing requirements for soil and road surfaces.
As stated in Section 4.2, Air Quality, of the Draft EIR, the project is required to adhere to applicable
measures contained in Rule 403. This requirement is included as Best Available Control Measures
(BACM) AQ -1, which requires adherence to all rules specified in Table 1 of Rule 403, including
watering disturbed areas at least three times per day during dry weather and ceasing all grading
activities if winds exceed 25 mph. With the implementation of BACM AQ -1, the Draft EIR determined
that project -related impacts from dust during construction activities are reduced to less than
significant levels. Please consult Section 4.2 of the Draft EIR for additional discussion regarding air
quality, fugitive dust, and project compliance with state and local requirements for dust control.
Please see the Topical Response Light and Glare in Section 2.2.1, for a summary of the analysis in the
Draft EIR regarding the potential for significant light and glare impacts from the proposed Wave Basin.
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As shown on the Exhibit on page 2-10 above, the light levels at the commenter's residence will be
below 0.01 footcandles. This analysis determined the project will not result in significant light and
glare at the commenter's location. As it relates to noise impacts at the commenter's residence, please
see Response 42-b.
Comment 42-g:
I am also concerned about the constant vibrations caused by the waves due to the tremendous weight
and force of 18 million gallons of water. I am only around 600 feet from the wave pool. All the seismic
records were done at the wave pool at Lemoore California which has totally different soil
composition. We are above the aquifer on sandy soil. So the developer has no idea of the impact of
the wave motion to our area.
Response 42-g:
As explained on page 4.6-17 of the Draft EIR, the Wave Basin will incorporate the necessary structural
concrete design features to address the pressure and drainage associated with the wave generation.
In addition, Mitigation Measure GEO-1 requires the Wave Basin designs to be prepared by a qualified
engineer in compliance with all seismic requirements and to incorporate all recommendations of a
qualified soils engineer. Finally, the proposed Wave Basin will be constructed to meet all engineering
standards of the Uniform Building Code in force at the time that building permits are secured. These
measures will ensure that seismic activity will not cause any structural failures in the Wave Basin and
will also ensure that the Wave Bason operations do not cause any vibration or other off-site effects.
In addition, an accelerometer test for seismic force was conducted at the Lemoore facility, which
confirmed that at the edge of the Basin, changes in seismic force during wave activity varied by less
than 0.0001g (levels below .0017 cannot be felt). Please see Appendix M.2 of this Final EIR for
additional information.
Comment 42-h:
I can attest to the fact that I am in a wind tunnel. The wind whips around from the Quarry and I have
clocked the wind at 60 mph. When I mentioned this to Garrett he acted like he didn't believe me.
That will also add to extreme evaporation.
Response 42-h:
Please refer to Response 42-d for a discussion on how local climate conditions that could affect
evapotranspiration were accounted for in the water supply analysis conducted by CVWD. As
summarized in Response 42-d, the WSA/WSV prepared by CVWD takes into account local climate
conditions, including wind, that will affect evapotranspiration.
Comment 42-i:
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Maintenance and construction trucks will be lined up outside my house because of the restrictions
that they can't start working until 7AM. Since the wave is operating from 7AM to 10PM every day,
365 days a year, they will probably need to do maintenance during the night. And what about the
heavy chlorination they will need to do during the heat? I will be exposed to chlorine in the air
everyday.
Response 42-i:
Mitigation Measure TRA -8 requires submission and City approval of Construction Traffic Control
Plans prior to any construction activities to ensure that construction trips will not cause traffic or
staging problems (see Draft EIR p. 4.13-62). Although construction access will need to be finalized
and approved in the Construction Traffic Control Plans, it is anticipated that construction access will
occur on Madison Street to avoid existing residences on Avenue 60. This plan will require compliance
with the construction -related noise mitigation measures identified in Section 4.11, Noise, of the Draft
EIR. These mitigation measures ensure project construction activities comply with the City of La
Quinta Municipal Code requirements (NOI-1); locate construction equipment and staging areas at the
greatest distance from sensitive receivers (NOI-2 and NOI-3); additionally, the contractor is required
to design delivery routes to minimize the exposure of sensitive land uses or residential dwelling to
delivery truck -related noise (NOI-4). These measures were established to reduce impacts to less than
significant levels.
Maintenance of the Wave Basin will occur during normal operational hours of the Wave Basin and
will not occur after 10 PM, consistent with the City's requirements under Municipal Code Section
6.08.050. Maintenance of the Wave Basin is not projected to result in impacts to surrounding
properties.
As it relates to the use of chlorine, the operation and maintenance of the Wave Basin will comply with
applicable State and County standards for the transport, storage and use of hazardous materials,
including obtaining a permit from the Riverside County Department of Environmental Health and
submitting a business emergency plan to the Statewide Informational Management System in
compliance with Chapter 6.95 of the Health & Safety Code (see Draft EIR at pages 4.8-18 and -19).
Compliance with applicable state laws and County health regulations precludes the emission of
hazardous levels of chlorine or other chemicals, and the comment does not include any substantial
evidence to the contrary. The analysis in the Draft EIR correctly characterizes the use of disinfectants
for the Wave Basin, including sodium hypochlorite and sulfuric acid, and correctly determines that
impacts will be less than significant.
Comment 42-j:
This project is a disaster for me as well as for our neighbors.
Please do not approve the zoning change that will allow all of this to happen.
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Response 42-j:
The commenter's opinion and request are noted.
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Comment Letter No. 43: Catherine Giles
Date: July 20, 2021
Affiliation: Area Resident
Comment 43-a:
As a resident of Andalusia, next to the proposed wave park, I am concerned about the noise and light
that the proposed development would bring to our community. I don't think it should be tourist zoned
and really don't want the disruption that a wave park will bring to our peaceful community.
Response 43-a:
The commenter's concern is noted.
Please see the Topical Responses on Light and Glare in Section 2.2.1, and Noise in Section 2.2.4 in
Section 2.2 of this Chapter for a summary of the analysis in the Draft EIR regarding the potential for
significant light and glare and noise impacts from the proposed Wave Basin and other components of
the project. This analysis determined the project will not result in significant light, glare, or noise
impacts on existing and planned land uses located in the vicinity of the project site, including the
Andalusia community.
The comment does not raise any specific questions or concerns regarding the proposed zone change,
but the zone change and the project's consistency with the goals and policies of the City's General
Plan are analyzed in detail in Section 4.10, Land Use and Planning, in the Draft EIR. Impacts were
determined to be less than significant. Please also see Responses 15-d and 17-a, above.
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Comment Letter No. 44: Richard Holub
Date: July 20, 2021
Affiliation: Area Resident
Comment 44-a:
I have been a LQ resident for over 15 years. My letter to you regarding the proposed Coral Mountain
Resort development is based upon over 20 years of successful real estate development experience in
the Temecula Valley— an area very similar to the economic and social environment found in La Quinta.
Response 44-a:
This comment is included for public record.
Comment 44-b:
The proposed Coral Mountain Resort with its massive wave feature and disruptive presence (lighting,
overall use, traffic impacts, etc.) are ill-suited for that specific area and this community. Not to
mention the grossly abusive water use. The mere appearance of that issue alone should be off-putting
and give Counsel pause in the re -zoning of that area.
Considering all those factors, and in my professional opinion, this proposed development is not in the
best interest of the La Quinta community — in fact, it is "irresponsible development" personified.
Please, listen to your constituents from the LQRRD and acquiesce to their demands.
Thank you for reading and for your consideration of my opinion.
Response 44-b:
The commenter's opinions are noted. Please see the Topical Responses on Light and Glare in Section
2.2.1, and Traffic in Section 2.2.5 of this Chapter for a summary of the analysis in the Draft EIR
regarding the potential for significant light, glare and traffic impacts from the project. The amount of
water needed for the project and the WSA/WSV prepared by CVWD are addressed in the Topical
Responses Section 2.2.3, Water Resources. These analyses determined the project will not result in
significant light and glare; that traffic impacts on existing and planned land uses located around and
near the project site can be mitigated to less than significant levels, and that sufficient water supplies
exist to meet the project's water demands and all other existing and planned future water demands
in the basin.
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Comment Letter No. 45: Rob Michiels (1)
Date: July 20, 2021
Affiliation: Area Resident
Comment 45-a:
I would like to voice my strong opposition to the wave park project at Coral Mountain.
My wife and I have been homeowners at Andalusia for the past 11 years. I believe I am also speaking
on behalf of many of my neighbors.
We joined this beautiful Andalusia community because:
We love the peace and quiet;
We love the immaculately dark and clear night skies;
We were told the patch of wild and untamed desertscape across from us would eventually be
developed into a similarly quiet and uncrowded golf/low density residential community.
Response 45-a:
The comment is included for public record.
Comment 45-b:
So, imagine our dismay when that property was sold to another developer, who has quickly, and
under the radar, moved to change the zoning from low density residential to high impact commercial.
We do not understand why the city of La Quinta would have given the initial permission for that
zoning change so this ill-conceived project could move forward to this stage of planning?
Response 45-b:
The comment is incorrect, insofar as the City has not permitted the zone change. The applicant has
filed applications with the City and City Staff has been processing those applications as required by
the City Municipal Code and State law. Please see Responses 17-a and 17-c for additional information
related to the processing of the proposed General Plan Amendment and Zone Change.
Comment 45-c:
Do our city leaders really want to tie their political legacy to the desecration of one of the last truly
unique and peaceful tracts of La Quinta land by unscrupulous developers who want to change it into
a circus like attraction every day all year round? Why go forward and spend untold dollars on
investigations when any person with common sense knows this can and should be stopped right now
by the city simply holding fast to the original zoning?
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Response 45-c:
This comment is included for public record. However, it does not raise any specific environmental
issues or concerns, and therefore, no further response is provided.
Comment 45-d:
Why waste millions of gallons of drinking water when we are in the midst of a drought?
Response 45-d:
Please see the Water Resources Topical Response in Section 2.2.3 of this Chapter, as well as Section
4.9, Hydrology and Water Quality, and Section 4.15, Utilities and Service Systems in the Draft EIR.
As explained in detail in the Water Resources Topical Response in Section 2.2.3, CVWD's long-range
planning and groundwater management efforts take into account the risks associated with extended
drought conditions and potential reductions in water deliveries from the Colorado River and State
Water Project exchange. CVWD has determined that there are adequate supplies of water to serve
the proposed project and all other existing and planned future uses in the area, as confirmed in the
WSA/WSV approved by CVWD.
Comment 45-e:
The so-called expert reports submitted in support of this project are at best theoretical re -do's of
earlier reports (from other projects). No real science or experiments are behind these reports. They
should be refused and refuted.
Response 45-e:
The commenter's opinions regarding the technical studies included in the Draft EIR are noted, but
those opinions have not been substantiated with any substantial evidence of inaccurate assumptions
or technical inadequacies. Contrary to the stated opinions, the technical studies included in the Draft
EIR were prepared by experts in their fields in compliance with the requirements of CEQA.
Comment 45-f:
Is the only underlying agenda that wants to allow this permitting process change the pursuit of a few
extra dollars promised for your city coffers? As my grandmother rightly said: beware of promises!
If you go forward, I believe future generations will not look kindly on your legacy.
Thank you for your consideration.
Response 45-f:
The commenter's opinions are noted.
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Comment Letter No. 46: Rob Michiels (2)
Date: July 20, 2021
Affiliation: Area Resident
Comment 46-a:
Good afternoon and thank you for allowing me to voice my strong opposition to this project.
My wife and I have been homeowners at Andalusia for the past 11 years. I believe I am also speaking
on behalf of many of my neighbors.
We joined this beautiful Andalusia community because:
We love the peace and quiet;
We love the immaculately dark and clear night skies;
We were told the patch of wild and untamed desertscape across from us would eventually be
developed into a similarly quiet and uncrowded golf/low density residential community.
So, imagine our dismay when that property was sold to another developer, who has quickly, and
under the radar, moved to change the zoning from low density residential to high impact commercial.
We do not understand why the city of La Quinta would have given the initial permission for that
zoning change so this ill-conceived project could move forward to this stage of planning?
Do our city leaders really want to tie their political legacy to the desecration of one of the last truly
unique and peaceful tracts of La Quinta land by unscrupulous developers who want to change it into
a circus like attraction every day all year round? Why go forward and spend untold dollars on
investigations when any person with common sense knows this can and should be stopped right now
by the city simply holding fast to the original zoning?
Why waste millions of gallons of drinking water when we are in the midst of a drought?
Response 46-a:
This letter is a duplicated of Comment Letter No. 45. Per CEQA, this comment letter is included for
public record. Please see Comment Letter No. 45 responses.
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Comment Letter No. 47: Eva Parker
Date: July 20, 2021
Affiliation: Area Resident
Comment 47-a:
We want to express our strong opposition to the planned Coral Mountain Development and Wave
Park. My husband and I moved to La Quinta and purchased our retirement home here in a 55 and
over community so we could enjoy our final years in peace and quiet. We specifically purchased in
Trilogy La Quinta as it was far away from the hustle and bustle and traffic of the downtown area. We
anticipated other housing developments and hotels would eventually be built in the surrounding open
spaces, but we never imagined a Tourist/Commercially-zoned mega resort with a Wave Machine,
professional competitions, and entertainment stages would be built a few blocks from our quiet
retirement community. This is so unfair to the surrounding homeowners who moved here expecting
a quiet and peaceful environment.
We ask that you please put yourself in our place and recommend against this project.
Thank you for your consideration.
Response 47-a:
This comment does not include an accurate description of the proposed Project. Please see Chapter
3.0, Project Description, of the Draft EIR for a complete description of the project components. The
project will include 600 low density residential units and 60,000 square feet of neighborhood
commercial component, as currently permitted. The project also proposes a 150 -room boutique
resort, with up to 57,000 square feet of associated resort commercial amenities, as well as an
approximately 16 -acre Wave Basin, and 23.6 acres of open space which will permit active and passive
recreation. Impacts of the proposed project, including impacts of special events proposed for the
project are discussed in the Draft EIR, and, where necessary, mitigation measures are provided to
ensure project impacts are reduced to less than significant levels to the greatest extent feasible.
Special events with professional surfers are contemplated at the Wave Basin up to four times per
year, but these events are limited to a total of 2,500 guests per day and are subject to issuance by the
City of a temporary use permit to ensure compliance with the City's noise ordinance and to avoid
creating a nuisance to residents in the Coral Mountain community and the surrounding residential
communities. Neither entertainment stages nor amplified music are proposed.
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Comment Letter No. 48: Robert Stowe
Date: July 20, 2021
Affiliation: Area Resident
Comment 48-a:
I built a home directly across the street from this proposed project in 2004 and have lived in the desert
full time for 28 years. I have 5 Surf boards hanging in my garage right across the street waiting for me
to pull one down to make the 6 hour round trip to San Onofre just to surf for 2 hours. One might think
I would be the greatest proponent of the surf park, but no I am not. I must admit I was super excited
when I heard the news about the surf park. Kelly Slater is one of my hero's and I actually had the
chance to meet him in Hawaii not to long ago. I will probably become a member of one of the surf
parks in the desert for sure. But This is definitely not the area for one. The impact on the beautiful
environment nestled up against the BLM Santa Rosa Range is much more important than an
Amusement Park aka Surf Park.
Whenever I get a chance, I tell all my friends and visitors about the Ancient Lake Cahuilla and the
Waterline. I show them proof with all the tiny sea shells I have collected that I found in my yard. I tell
them about the story of the misnomer of Conchilla Valley vs Coachella Valley
(www.coachella.org/about-us/history). I remember when there was talk about a nature park slated
next to Lake Cahuilla, I was so excited. I am sorry that never transpired. People from all over come up
here to hike and camp at Lake Cahuilla to enjoy the serenity we offer. Clients, Visitors and Residents
all tell me how nice it is to come here and actually see the stars, something they do not see anymore
where they come from.
Some local homeowners speculate it will increase property values other think it will decrease. I
believe the values will increase either way with or with out the amusement park. I didn't build here,
raise my family, and stay here because of property values. I bought and built here because of the
beauty and serenity. So did everyone else.
Response 48-a:
This comment is noted but does not include any specific comments regarding the information and
analysis in the Draft EIR.
Comment 48-b:
La Quinta does not need the money that bad. We (The City, Business Owners, and Residents) do not
need this development bad enough to destroy such a historic and serene area. Another country club,
resort home community with minor commercial at this location would be ideal, not an Amusement
Park aka Surf Park. I raised two children in La Quinta, right across the street. I have owned a business
in the desert for 31 years. I know there is not much for young people to do here other than Golf or
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Tennis. A surf park is a great idea, just not next to the waterline and Multi Million Dollar Homes,
really?
Response 48-b:
The commenter's opinions regarding the project and the City's finances are noted. As explained on
pages 4.4-12 — 4.4-13, the project will not have any significant impacts to historical resources.
Although the remains of a partially collapsed adobe house on the project site have been identified as
eligible for listing in the California Register of Historic Resources and considered a historic resource
because it may be a remnant of one of the earliest settlements in the area, Mitigation Measure CUL -
1 requires preparation of a comprehensive recordation program and preservation of the remaining
adobe structure, which will avoid any significant impacts to historic resources. Please also see Section
4.1, Aesthetics, as well as Section 4.4, Cultural Resources, of the Draft EIR for a further discussion of
the potential impacts of the proposed project's impacts on historic resources. All project -related
impacts to historic resources would be less than significant with the implementation of the identified
mitigation measures.
The commenter's opinion regarding an alternative location is noted. An alternative location for the
proposed project was considered, as described in Chapter 7.0, Alternatives, of the Draft EIR, was
determined infeasible, and was therefore not considered for further analysis, as allowed under CEQA.
Comment 48-c:
There is plenty of vacant land around the desert. Just because they got a good deal on the land doesn't
make it right. They do not have the right to destroy our scenic night skies and bring thousands of daily
visitors to a quiet neighborhood.
Response 48-c:
Please see the Light and Glare Topical Response in Section 2.2.1 of this Chapter for a summary of the
analysis in the Draft EIR regarding the potential for significant Light and Glare impacts from the
project. Based on the analysis of the proposed lighting plan for the Wave Basin, no significant light
and glare impacts on surrounding and nearby uses are identified.
Full buildout of the project would permit construction of up to 600 total dwelling units and 150 hotel
rooms, along with 60,000 square feet of neighborhood serving commercial uses that will be open to
the general public, and 57,000 of private resort -serving commercial uses that would only be available
to residents and hotel guests (see Table 3-2 on page 3-10 of the Draft EIR). Assuming 4 persons per
home and 2 persons in each hotel room would generate a total of 2,700 people on the project site, in
addition to visitors of the neighborhood serving commercial development at the corner of Madison
St. and Avenue 58. In addition, there may be up to four special events at the Wave Basin per year
which could bring up to 2,500 additional people to the project site. Table 4.13-26 on page 4.13-43 of
the Draft EIR shows the total and peak hour estimated daily trips to and from the project site during
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a special event. Traffic and noise generated by development and operation of the proposed project
are discussed in Section 4.13 and Section 4.11, Noise, of the Draft EIR. Please also see Topical
Responses on Noise in Section 2.2.4, and on Traffic in Section 2.2.5, of this Chapter for a summary of
the analysis in the Draft EIR regarding the potential for significant noise and traffic impacts from the
project.
Comment 48-d:
You at the city are our last defense. You must make a difficult decision I know. You cannot let these
developers snowball you to think this is a good idea, it's not! Let them move over to the other side of
Monroe and let Indio have this one. Indio needs this more than La Quinta. It will be just like the
Festivals, they will visit the Amusement Park then dine and stay in all of our nice restaurants, hotels
and rentals. We do not need this in La Quinta. It is not good for La Quinta. It will change the
neighborhood in a very negative way. After the excitement of the new project wears off it would go
down as one of the worst decisions the City La Quinta has ever made. Attached you will see a painting
I have hanging in my foyer right across the street from the proposed project. Feel free to zoom and
take a close look at it. I had this commissioned back in 2004. I asked the painter to paint that land/
waterline like it looked years ago so my grandchildren would know what it looked like knowing it
would be developed someday. Let it be a responsible development please. I never thought it would
end up being a surf park! Really? Please do not let this happen. Thank you!
Response 48-d:
The commenter's opinion is noted.
Comment 48-e:
This letter is a duplicate of Comment 48, resubmitted shortly after the original submittal.
Response 48-e:
This comment letter is included for public record. Please see Responses 48-a through -d.
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Comment Letter No. 49: Sheila Warren (sent by Alena Callimanis)
Date: July 20, 2021
Affiliation: Area Resident
Comment 49-a:
Here is the document that Sheila Warren will be using during today's City Council meeting. Sheila will
be at City Hall in person.
Thank you very much.
Response 49-a:
This comment is noted. Please see the responses to specific comments below.
Comment 49-b:
Good day Honorable Mayor Evans, Council Members and Staff. My name is Sheila Warren and I am a
Trilogy Resident. I have two quick things to cover with you today.
The first is that we are getting tired of the developer justifying his water use for the Wave Basin by
saying that he will use only 25% of the water used by a golf course. What he fails to mention is that
golf courses can use gray or recycled water and that he must used potable water from our aquifer. If
you haven't read it, there was an excellent article in the July 18 Desert Sun, Golf Courses prepare for
water shortages. I would like to highlight just a few of the key points of that article:
There is a 15% voluntary request in reduction of water use across the state,
New level of drought emergency declaration will be coming by 2022.
Unlike many golf courses elsewhere in the State which rely heavily on groundwater, Coachella Valley
golf courses have sought to reduce reliance on the local aquifer.
Protecting that groundwater, the main source of water for households and businesses in the desert
is a focus of the Golf and Water Task Force.
"Because the aquifer is literally the lifeblood of everything that happens in the desert, as important
as it is reducing the overall water usage footprint over time, we do put more emphasis on the health
of the aquifer. Desert courses have been moving away from aquifer water in the last decade.
Desert courses have been removing turf.
"We have to recognize that we are in a desert and the aquifer isn't endless.
So how will the wave pool move away from use of the aquifer? It can't.
How can a wave pool cut water use by 15%? It can't because it will not be able to operate.
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And what about evaporation? When we asked the developer, they tried to compare evaporation at
the Kelly Slater pool in Lemoore California with this one. Once we reminded them that Lemoore had
40 days over 100 in 2020 and we have 143 days over 100, that their high was 107 and our high was
124, that their lows were mostly in the 60s with a few 70s during those hot days, and our nights were
always in the 100s, or high 90s and 80s, they stopped comparing evaporations.
Response 49-b:
Please see the Topical Response on Water Resources in Section 2.2.3 of this Chapter for a summary
of the analysis in the Draft EIR regarding the amount of water needed for the project and the water
supply analysis prepared by CVWD and additional information related to the analysis of these topics.
The water demand estimate for the project, including the proposed Wave Basin, takes into account
the local climate. As explained in the Water Resources Topical Response in Section 2.2.3, CVWD's
water demand calculations for the project include the local area's evapotranspiration rate (64.22
inches per year). Accordingly, the water demand calculations in the WSA/WSV are specific to the
project site conditions and considered more accurate than comparisons to the Wave Basin in
Lemoore. Concerning climate change and drought conditions, CVWD's long-range planning and
groundwater management efforts take into account climate change, including extended drought
conditions and potential reductions in water deliveries from the Colorado River and State Water
Project, as explained in detail in the Topical Responses, Section 2.2.3 above.
With respect to the availability and use of tertiary treated wastewater, such recycled water is not
available in the project area and is not being used on the golf courses in the project vicinity. However,
the project is planning to use non -potable canal water for all outdoor landscaping in commercial and
common areas, and those irrigation systems will be constructed to use recycled water if and when
such water becomes available in the future. As shown in Table 2.0-3 on page 2-17 above, the Wave
Basin itself only uses approximately 15% of the project's total outdoor water use, so the use of
recycled and other non -potable water sources for outdoor landscaping will substantially reduce the
project's total demand on groundwater resources.
Comment 49-c:
And finally, I would just like to mention about the 7AM to 10PM operation of the Wave Basin, 365
days of the year. Up to and including our face to face meeting with the developer on June 16, when
asked, the developer always told us that it would be 12 hours of operation, 7AM to 7PM so we had
nothing to worry about with noise or light at night. Two days later on June 18, the draft of
environmental impact report that had the hours of 7AM to 10PM, 365 days of the year.
Seems awfully strange they did not know that two days earlier...
But who is going to be surfing during the day in this heat? With water temperatures in the 90s and air
temperatures in the 100s, that is a recipe for heat stroke.
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This project is in the wrong place at the wrong time.
Response 49-c:
The Draft EIR analyzed the maximum hours of operation for the Wave Basin allowed under the City's
Municipal Code for a recreational facility to ensure that the worst-case scenario for potential impacts
like light, glare and noise was fully analyzed and disclosed. Please see Topical Responses Light and
Glare in Section 2.2.1, and Noise in Section 2.2.4 of this Chapter for a summary of the analysis in the
Draft EIR regarding the potential for significant light and glare and noise and impacts from use of the
Wave Basin during evening hours. This analysis determined use of the Wave Basin will not result in
significant light and glare or noise impacts on existing and planned land uses.
The commenter's opinions regarding summer daytime use are noted.
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Comment Letter No. 50: Carolyn Winnor (sent by Alena Callimanis)
Date: July 20, 2021
Affiliation: Area Resident
Comment 50-a:
Carolyn Winnor, Trilogy resident at 81134 Barrel Cactus Road, LQ will be speaking over Zoom about
Coral Mountain Resort during the public comment session.
This is Carolyn's document.
Thank you very much.
Response 50-a:
This comment is noted. The comments and responses associated with the presentation are provided
below.
Comment 50-b:
Good Afternoon Honorable Mayor Evans, Council Members & Staff.
My name is Carolyn Winnor, I live in Trilogy La Quinta moved here in August 2005.
I am opposed to the Coral Mountain Wave Project and the Re Zoning of this property for many
reasons:
Response 50-b:
This comment is noted. Please see the responses to Comments 50-c through 50-f.
Comment 50-c:
Water Usage — Couple of weeks ago on the news I heard a representative from Coachella Valley Water
District, speak regarding the water they currently have in reserve. I believe it was 6 billion gallons.
How did CVW get this large reserve? From homeowners and businesses, conserving water since last
drought that affected the Coachella Valley. Also due to water efficient toilets, faucets & appliances.
The residents of the Coachella Valley is the reason CVWD has a large reserve and I am against using
the reserve to fill a Wave Pool with 18 Million Gallons of Drinking Water, for People to surf on. We
changed our habits to be assured the residents of the Coachella Valley would have water for the
future.
Response 50-c:
Please see the Water Resources Topical Response in Section 2.2.3 of this Chapter for a summary of
the analysis in the Draft EIR regarding the amount of water needed for the project and the water
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supply Analysis prepared by CVWD and additional information related to the analysis of these topics.
As described on page 15 of the WSA, CVWD estimates that the aquifer contains approximately 39.2
million acre-feet water, which is capable of meeting the long-term water demands of the Coachella
Valley. Further, as described in the Topical Responses, Section 2.2.3 above, CVWD and the other
water agencies in the Coachella Valley actively manage the basin's groundwater supplies, and project
that through conservation, source substitution and replenishment efforts, the basin will have more
water, not less, in 2045, even taking into account the project and other planned growth. Since 2009,
the groundwater stored in the Indio subbasin alone has increased by approximately 840,000 acre-
feet (see page 2-20 above and see the 2022 Indio Subbasin Water Management Plan Update, adopted
in December 2021, at page ES -4).
Consistent with the requirements of the City of La Quinta's water -efficient landscape ordinance
(LQMQ Chapt. 8.31), CVWD's Landscape Ordinance No. 1302.4, and the California Building Code and
Green Building Code, the Project includes both indoor and outdoor water conservation measures,
including a drought tolerant and native plant palette, efficient outdoor irrigation systems utilizing drip
irrigation and moisture detection, and low -flush toilets and water -conserving showerheads (see
WSA/WSV in Appendix M of the Draft EIR at p. 25).
Comment 50-d:
Lights/Lighting — 17 80' Poles with 70 fixtures on each Pole. Be like living next to LQ High School
football field or the Indian Wells Tennis Garden, the lights will be on until 10 pm, 365 days a year.
Response 50-d:
Please see the Topical Response on Light and Glare in Section 2.2.1 of this Chapter. The Wave Basin
lighting system has a total of 17 poles with 2-4 shielded and directed light fixtures on each pole (for a
total of 70 fixtures) to effectively illuminate the Wave Basin itself while avoiding light spillage onto
adjacent properties. This analysis determined that the project will not result in significant light and
glare impacts on existing and planned land uses located around and near the project site, as
demonstrated by the lighting contours shown on page 2-10 above, which shows that light levels from
the Basin will be less than 0.01 footcandles in the immediate vicinity of the Wave Basin. The Exhibit
on page 2-7 above also shows the stark contrast between the TLC for LED lighting system designed
for the Wave Basin and the typical outdoor lighting historically used at stadiums and the Indian Wells
Tennis Garden.
Comment 50-e:
Noise, Traffic - If La Quinta City Council approves the Coral Mountain Wave Project, the residents of
South East L Q will be living near or next door to an amusement park.
Response 50-e:
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The commenter's opinion is noted, but no substantial information regarding noise or traffic impacts
are provided. Please see Topical Responses on Noise in Section 2.2.4, and Traffic in Section 2.2.5. As
described in detail in the Project Description Section in the Draft EIR, at pages 3-19 — 3-22, Planning
Area III allows for the construction of a private resort including the Wave Basin, a boutique hotel, a
residential village, a low -intensity recreation and fitness complex, and a private community
clubhouse. These private facilities are available only to residents and hotel guests and function like a
private country club, not an amusement park. The project may also hold up to four special events
per year, which are limited to a maximum of 2,500 guests and require issuance of a temporary use
permit from the City. These special events are a tiny fraction of the approximately 75,000 daily guests
at Disneyland/California Adventure (according to TEA/AECOM estimates).
Comment 50-f:
My biggest fear: in 3 to 5 years no one is interested in surfing in a Wave Pool and the Wave will close
down. What will the City of La Quinta and the neighbors near Coral Mountain be left with a BIG HOLE,
measuring in length over 12 football fields?
Response 50-f:
The commenter's opinion is noted. This comment addresses the economic characteristics of the
project and does not address any potential impacts of the project on the environment. Section 15131
(a) of the CEQA Guidelines preclude the analysis of economic effects unless that economic effect
would have a physical impact on the environment. This comment does not provide any information
or evidence on how the long-term economic viability of the proposed Wave Basin could result in
physical changes that would constitute significant environmental impacts.
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Comment Letter No. 51: July 20th City Council Meeting Transcribed Presentations
Date: July 20, 2021
Transcribed presentations at the July 20th City Council Meeting
Comment 51-a:
This comment letter compiles and transcribes presentations made during the July 20th City Council
Meeting at La Quinta City Hall. The meeting consisted of both in-person comments and a comment
over teleconference (i.e., Zoom). The comments were under the meeting's "public comment on
matters not on the agenda". The link to the video recording is included in this comment, as well as
the commenter's name and time that the presentation appears in the video. Some of the speakers
also submitted the same presentations to the City via email, and those are presented above as
Comment Nos. 41 (Callimanis), 42 (Castro), 49 (Warren), and Winnor (50). Where the comments
transcribed below are the same as the comments submitted via email, the responses will refer back
to those prior responses.
Speakers discussing the Coral Mountain Resort Project and time of appearance in video linked above.
In -Person Comments
Alena Callimanis (Transcribed); 0:45 — 6:25 minutes
Lisa Castro (Transcribed); 6:40 — 9:00 minutes
Sheila Warren (Transcribed); 9:00 — 13:36 minutes
Francine Roy (Transcribed); 13:40 — 15:00 minutes
Verbal Comments via Teleconference
Carolyn Winnor (Transcribed); 19:50 — 22:10 minutes
Response 51-a:
This comment is noted. Responses to the comments in the individual presentations are provided
below.
Comment 51-b:
City Council Meeting 7-20-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/b8db2190-d39c-4f0d-b9ad-
cd3b449dc821
Located at: 0:45 — 6:25 minutes
Speaker: Alena Callimanis
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Callimanis: Honorable Mayor Evans I am vaccinated may I take this [indicating mask] off?
Mayor: You may.
Callimanis: Thank you. So um, Mayor Evans, Council members. I especially want to, and staff, I
especially want to thank Monika and Nicole who helped me get my presentation up and going
because I have videos in this presentation. So, I'm very excited. And of course, I am speaking about
the Coral Mountain surf resort if you haven't figured that out yet. So, the first —
Mayor: You should have your own clicker there, right?
Response 51-b:
This comment is noted. Responses to the comments in the individual presentations are provided
below.
Comment 51-c:
Callimanis: Yes, yes. Hopefully I will do it better this time. So, this is a picture that is right after sunset
last night, I took these pictures from Lisa Castro's house which is on 60th, on the um, on the single
lane, dirt, 60th road. So um, with beautiful dark sky. This is hard to see [indicating new slide with
photo], but what I tried to do here is do a panorama on my iPhone from the left is Guillermo's house,
I went across Coral Mountain and the right side where the light is back to Lisa's house. So just to show
you what the night sky and what it looks like at night. So um, this and, will you folks get this going?
Great. So um, be very quiet. [Plays video]. You hear the crickets? Okay, that's Lisa's house, so it started
from Guillermo's to Lisa's house again. And this second one is after I heard a car going on Madison.
So, this might be more difficult to hear. [Plays second video].
So, the significance of that video is, there was the car on Madison and that's what we heard. Madison
is further from where I took this than the surf pool. So that was the sound that we heard. So um, and
I guess you can hear, you can see that it really was very, very quiet there. Uh this next one was as I
was at 58th right by Coral Mountain, I saw that light, and I said oh what is that light? So, I followed the
light. I went in and out of tra- you know the roads, and this is what I came to, Bagdouma Park in
Coachella, those were the lights I saw from 58th from Coral Mountain. And the light pole on the right
is 60 feet. The light pole that are going to be at this development will be, excuse me, 80 feet. So, they
will be 20 feet higher than the one on the right. Like, I can't even imagine lights being held up on a
pole that high. So that's what going to be surrounding that. And if I go back to the prior picture, oops,
oh I'm not going backwards. Oh, this way, sorry. If I go back to this picture here, the reason we see
that is because the particles in our air, there's dust and sand, all these small particles diffusing the
light and they will be doing the same thing by Coral Mountain. So that light will be seen. So, what I
wanted to say is please don't let the developer keep insulting us, and you, by saying there will be no
light and no noise impact to the surrounding developments. This will be physically impossible
considering the fact that the location has quiet nights in this area, the proximity to Coral Mountain,
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sound echoing and reverberation off the mountain, and the light reflection and dispersion. I think
these prior charts show that very clearly.
Response 51-c:
This comment is noted. Please consult Comment and Response 41-b for comments related to light
and noise made during Callimanis's presentation at City Council and the responses thereto. As it
relates specifically to the lighting at Bagdouma Park, please see Appendix B.1 to this Final EIR, which
explains and shows the difference between the TLC for LED lights proposed for the Wave Basin and
the lights at Bagdouma Park. As explained in that memo from Musco Lighting (who also provided the
lights for Bagdouma Park), the Wave Basin lights will have almost no direct light (7 candela) at 100
feet from the edge of the Basin, whereas the lights at Bagdouma have candela ratings at that distance
of 11,858 (for the 2005 lights) and 21,400 (for the older 1989 lights). Accordingly, the lighting at
Bagdouma Park give off more than 1,000 times more light to the surrounding area and provide no
meaningful information on the proposed Wave Basin lighting. However, a physical test of the actual
lights that are proposed for the Wave Basin was conducted at the project site in November 2021
following requests to do so by members of the City Council and the public. The results of that test
are described in another technical memorandum from Musco Lighting and the Kelly Slater Wave
Company, which is attached as Appendix B.2 to this Final EIR. As described and shown in Appendix
B.2, the lighting proposed for the Wave Basin is directed and shielded to light only the intended area
with virtually no illumination outside the immediate vicinity of the Wave Basin (see, e.g., the lighting
contour exhibit included in Appendix B.2 and also on page 2-10 of the Topical Responses above).
Comment 51-d:
Now this is your City of La Quinta General map, and I circled the land use areas where we are and it's
very compatible to the developments that are around. And on the next page, I wanted to say these
are excerpts from the La Quinta General Plan 2035 Land Use. Policy LU -3.1, encourage the
preservation of neighborhood character and assure a consistent and compatible land use pattern.
Next one, maintenance and protection of existing neighborhoods. Next one, encourage compatible
development adjacent to existing neighborhoods and infrastructure. A community that provides the
best possible quality of life for all its residents. And preservation of scenic resources as vital
contributors to the City's economic health and overall quality of life. So that's from the master plan.
We want Low Density Residential at this site. We want development. We're not saying no
development. And we're - but we're saying not 100% STVRs and a Wave. Preserve the beauty and
serenity for the five developments around Coral Mountain, and for the new 100% low density
residential development that should be on this magnificent property. Please do not approve, when it
comes up, a zoning change that will take away all of that. Thank you very much.
Response 51-d:
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Please see Response 41-c above for a detailed response to this comment and the project's consistency
with the General Plan policies and goals described in this comment.
Comment 51-e:
New Speaker: Lisa Castro
Yes, I am the neighbor; I am closer to this wave park than anybody. I've been there 30 years, um, first
of all, thank you for hearing this, thank you for the video and everything that Alena did.
Mr. Garrett and I have met several times in my home, and he's a wonderful gentleman, but I'm just
not sure that things he tells me, every time he tells me something, things change.
Response 51-e:
This comment letter has been transcribed from the City Council meeting. Video recording from this
meeting is located at the City website. The link is also provided on the comment letter. In addition, a
written version of Ms. Castro's comments were emailed to the City and included in this Chapter as
Comment Letter 42.
This comment is noted. Responses to the comments in this presentation are provided in the
Responses to Comment Letter 42 above and are augmented in the responses below because the oral
comments are not exactly the same. Where appropriate, references to the specific responses are
provided below.
Comment 51-f:
But um, I'm worried about the water evaporation, I'm worried about our aquifer, you know, every
day on the news all we hear about is the drought.
Response 51-f:
Please see Response No. 42-d above, the Water Resources Topical Response in Section 2.2.3 of this
Chapter, as well as Section 4.9, Hydrology and Water Quality, and Section 4.15, Utilities and Service
Systems, of the Draft EIR for analysis of the project's water use and hydrology impacts.
Comment 51-g:
I'm worried about the light and the noise. I'm worried about traffic. I am going to be right next door
to the secondary entrance, and I don't believe they are even aware of the 7 am entrance that most
of our country clubs have. People are going to be lining up down the street even after development,
after its completed to get in. I don't think they're going to allow me to get in and out of my own home.
Response 51-g:
See Responses 42-c, 42-d, and 42-f above.
Comment 51-h:
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So um, I'm worried about, like I said, the light, and the noise and the wave impact, the motion of that
water. Is that going to have - create cracks in my foundation? I'm east to it. I'm going to be closest to
the end. Is that going to affect my home? My pool? Um, I'm concerned, very concerned.
Response 51-h:
With respect to light and glare, please see Response 42-b and the last paragraph of Response 42-f,
and also see Response 41-b. With respect to the concern that the Wave Basin will cause vibration -
related harm to the commenter's property, please see Response 42-g above. This analysis, supported
by a comprehensive analysis by a registered geologist, resulted in a determination that no significant
impacts related to geology or soils will result from the project, inclusive of the proposed Wave Basin.
In addition, Section 4.9, Hydrology and Water Quality, addresses the design characteristics of the
Wave Basin. As discussed on pages 4.9-27 and 28 of the Draft EIR, the mechanical waves generated
in the Wave Basin may be 6 feet tall or greater and the dissipation of the energy generated by theses
waves is calculated into the design of the sloped edges of the Wave Basin. The facility will include
sufficient freeboard such that no water will escape the edges of the Wave Basin. As the energy
generated by the waves will be dissipated and contained in the Wave Basin, the waves will not
generate a level of energy outside the basin that will result in vibrations that will have any effect on
uses around the project site, as described on page 4.9-27 of the Draft EIR.
Comment 51-1:
I've been there forever, before anything else was out there, and I know the quality of life that I have
now will be destroyed. That quiet is why we built out there. And with a surf park, a private community
that no one else can access to, is going to destroy that. So please consider, reconsider, or consider
not changing the zoning.
Response 51-i:
The commenter's opinions are noted. As it relates to the approval process for the Zone Change, please
see Responses 15-d and 17-a above.
Comment 51-j:
New Speaker: Sheila Warren
Good afternoon Mayor Evans, City Council Members and Staff. My name is Sheila Warren and I'm a
resident of Trilogy in La Quinta. I have two things to cover with you today.
The first is, we're getting tired of the developer justifying the water use for the Wave Basin by saying
that he -it will use only 25% of the water used by golf courses. What he fails to mention is that golf
courses use gray water or recycled water, and that the Wave Basin must use potable water from our
aquifer. If you haven't read it, there was an excellent article in the July 18th Desert Sun, stating that
golf courses are preparing for water shortages. I would like to highlight just a few of the points:
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- There is a 15% voluntary request in reduction of water use across the state;
- A new level of drought emergency declaration will be coming in 2022.
Unlike many golf courses elsewhere in the State which rely heavily on groundwater, Coachella Valley
golf courses have sought to reduce reliance on the local aquifer.
Protecting that groundwater, the main source of water for households and businesses in the desert
is a focus of the Golf and Water Task Force.
Quote: "Because the aquifer is literally the lifeblood of everything that happens in the desert, as
important as it is reducing the overall water usage footprint over time, we do put more emphasis on
the health of the aquifer. Desert courses have been moving away from aquifer water in the last
decade."
Desert courses have been removing turf.
We have to recognize that we are in a desert and the aquifer is not endless.
So how will the wave pool move away from use of the aquifer? It can't.
How can a wave pool cut water usage by 15%? It can't because it will not be able to operate.
And what about evaporation? When we asked the developer, they tried to compare evaporation at
the Kelly Slater pool in Lemoore California with this one. Once we reminded them that Lemoore had
40 days over 100 degrees in 2020 and we had 143 days over 100; that their high was 107 and our high
was 124; that their lows were mostly in the 60s with a few 70s during those hot days, and our nights
were always in the 100s, or high 90s and 80s, they stopped comparing evaporation.
And finally, I would just like to mention about the 7AM to 10PM operation of the Wave Basin, 365
days of the year. Up to and including our face-to-face meeting with the developer on June 16, when
asked, the developer always told us that it would be 12 hours of operation, 7AM to 7PM so we had
nothing to worry about with noise at night or light at night. Two days later on June 18, the draft of
environmental impact report listed hours of operation as 7AM to 10PM, 365 days of the year.
Seems awfully strange they did not know that two days earlier...
But who is going to be surfing during the day in this heat? With water temperatures in the 90s and air
temperatures in the 100s, that is a recipe for heat stroke.
This project is the wrong place and the wrong time. Thank you very much.
Response 51-j:
This comment is noted. Please see Responses 49-b and 49-c for responses addressing Warren's
presentation at City Council.
Comment 51-k:
New Speaker: Francine Roy
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Hello, I just had some general questions. I am kind of new to this project and I just moved here a year
ago. One question is when was the current zoning established for this parcel?
Mayor: So, this is the part of public comment where you are able to address, but we will not respond
per se to every question. So, you can rattle off your questions, you're welcome to do that and
probably a lot of that is covered in the EIR or it could be in the General Plan that's available on our
website. But feel free. I would like to hear your questions, so we have an understanding.
Roy: And exactly what she was talking about was what I was going to mention. And thirdly, I was
curious that with all the climate change and drought conditions that are going on and the future I
think we can expect this to continue. There's a lot of emphasis on the aquifer as already discussed.
Wouldn't it be a good time to maybe reconsider a change in the zoning that might not allow a golf
course even? Which is taking water. Something to think about. So that's it.
Response 51-k:
This comment letter has been transcribed from the City Council meeting. Video recording from this
meeting is located at the City website. The link is also provided on the comment letter.
The zoning for the project site has been included in various specific plans for the area, starting in
1988, with the Rancho La Quinta Specific Plan approved by the County of Riverside prior to annexation
of the site into the City of Indio. The site is currently included are part of the Andalusia at Coral
Mountain Specific Plan, and the history of the project site is more fully described on page 3-6 of the
Draft EIR. The existing General Plan land use designations and zoning of the project site call for a
combination of neighborhood commercial, low density residential and open space -recreation (golf)
uses, and no substantial changes to the proposed uses on the 386 -acre project site have been made
since approximately 2003 (see Draft EIR at pp. 3-6 — 3-10). With respect to the proposed General
Plan and zoning changes proposed for the project, and the comment that the City might consider a
change to prohibit golf uses, these are discretionary policy decisions to be made by the City Council,
as discussed in more detail in Responses 15-d and 17-a above.
Comment 51-1:
New Speaker: Carolyn Winnor
I am unmuted. Can you hear me? Good afternoon Mayor Evans, Council Members & Staff. My name
is Carolyn Winnor, I live in Trilogy La Quinta. My husband and I moved here in August 2005.
I am opposed to the Coral Mountain Wave Project and the Re Zoning of this property for many
reasons:
Water Usage — which you've heard multiple times this afternoon. A couple of weeks ago on the news
I heard a representative from Coachella Valley Water District, speak regarding the water they
currently have in reserve. I believe it was 6 billion gallons. How did Coachella Valley Water get this
large reserve? From homeowners and businesses, conserving water since last drought that affected
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the Coachella Valley. Also due to water efficient toilets, faucets and appliances. The residents of the
Coachella Valley is the reason the Coachella Valley Water District has a large reserve and I am against
using the reserve to fill a Wave Pool with 18 million gallons of drinking water, for people to surf on.
We changed our habits to be assured the residents of the Coachella Valley would have water for the
future.
Response 51-1:
Please see Response 50-c above for the responses to these water use comments to the City Council.
Comment 51-m:
Another one of my concerns is the lighting. The project is proposing 17, 80 -foot light poles with 70
fixtures on each pole. Be like living next to La Quinta High School football field or the Indian Wells
Tennis Garden, the lights will be on at the Coral Mountain Wave until 10 pm, 7 days a week, 365 days
a year.
Response 51-m:
Please see Response 50-d for the response to this lighting comment to the City Council.
Comment 51-n:
Noise and Traffic - If La Quinta City Council approves the Coral Mountain Wave Project, the residents
of southeast La Quinta will be living near or next door to an amusement park.
Response 51-n:
Please see Response 50-e for the response to this noise and traffic comment to the City Council.
Comment 51-o:
And what happens in 3 to 5 years that no one is interested in surfing in a Wave Pool in the desert and
the Wave would close down. What will the City of La Quinta and the neighbors near Coral Mountain
be left with? A big hole, measuring in length over 12 football fields?
Thank You.
Response 51-o:
Please see Responses 50-f for the response to this comment to the City Council.
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Comment Letter No. 52: Rob Michiels (3)
Date: July 21, 2021
Affiliation: Area Resident
Comment 52-a:
I would like to remind the City leaders that the 2035 La Quinta General Plan is the (long) existing plan
for our communities. This plan was supposed to be legally binding and now it appears that the City
mayor and council are going to use loopholes to invalidate it?
I would also like to add to my previous comments (email dated 07/20/21) by adding the following
specific questions that need to be addressed by the review process:
Response 52-a:
This comment is noted. Responses to the comments in this email are provided below.
Comment 52-b:
1. First, the legal record should clearly reflect that this proposed development is not in compliance
with the existing 2035 zoning plan for La Quinta.
a. Why does the City even consider this project?
Response 52-b:
The City is required to accept and process proposed projects for City Council consideration, including
any proposed amendments to the City's General Plan or zoning changes, which is the process
occurring with respect to this project now. Please see Responses 15-d and 17-a above for a further
explanation of this process and the respective roles of City staff and the City Council.
Comment 52-c:
b. To clarify the process, the city should provide its residents with a written and public
justification of its intent, so there can be no misleading facts, history and responsibilities if the
future brings lawsuits.
Response 52-c:
In connection with the approval of any amendment to the General Plan, the City Council is required
to make certain findings justifying the approval. In addition, to the extent the EIR determines that
the project will have any significant and unavoidable impacts, the City Council is required to make
specific findings and identify the project benefits that outweigh those unavoidable environmental
impacts. These will be prepared for, and available to the public prior to public hearings on the project.
Comment 52-d:
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c. The rezoning process requires a rigorous investigation of all factors and a specific justification of
communal benefits. The current reports submitted by the developer are anything but that.
d. Neutrality of reporting is paramount. So why are these 3rd party studies, instead of experts hired
by the developer?
e. DEIR documents are meant to be read and understood by the average person and are supposed to
follow a specific format and size requirement. The currently submitted documents are anything
but that and are full of vague and subjective language, which of course is not inconsistent with
having been written by people being paid by the developer. Why can the City not commission new
studies and reports from non -conflicted independent experts?
Response 52-d:
In response to item c., the City is required to consider proposed projects, including any proposed
amendments to the City's General Plan or zoning changes. The City Council is required to make
certain mandatory findings before approving the General Plan Amendment. This information will be
included in the Staff Report and publicly available before the City Council meeting to consider the
project.
In addition, the project proposes a Development Agreement (DA 2021-0002) as part of the
entitlement process. "Communal benefits" described in proposed DA 2021-0002 include ensuring
that the project has a net positive fiscal impact on the City despite a lack of property tax revenue to
the City through 2035, ensuring the timely completion of infrastructure to serve the project and
surrounding area, and ensuring that the project design features, and mitigation measures identified
in the EIR are enforceable by the City as project requirements. The net positive fiscal impact generated
by the project would provide the City with additional funds for its general fund for police, fire and
other City services for the benefit of the entire City. Also see Response 52-e.
In response to items d. and e., the technical reports were prepared by technical experts in their
respective fields. All technical reports and information included in the Draft EIR was reviewed by the
City of La Quinta prior to release of the Draft EIR to ensure that all information represents the
independent judgment and analysis of the City, as required by Section 15090 of the CEQA Guidelines.
Please also see Response 90-b and Topical Responses 2.2.6 and 2.2.7 above.
Comment 52-e:
2. The City is being asked to rezone based on grounds of (doubtful) benefits and (undefined)
developer promises to local government officials (DEIR 3-18).
a. The proposed amusement park is private. How does that benefit La Quinta residents?
Response 52-e:
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Page 3-18 of the Draft EIR contains a portion of the detailed project description and does not describe
developer promises or an amusement park. The proposed Low Density Residential, Tourist
Commercial, and Open Space Recreational land uses will be private; however, the project also
proposes 7.7 acres of Neighborhood Commercial uses in the northeast corner of the property which
will provide public access to goods and services in an area of La Quinta which is underserved for retail
and services. Additionally, as stated on page 3-8 of the Draft EIR, one of the stated project objectives
is to "create a private resort community with a variety of interrelated and mutually supportive
commercial and recreational land uses that will also generate transient occupancy and sales tax
revenues in order to enhance the City's economic base and long-term financial stability." This
objective is particularly important here because the project site will not generate property tax
revenue to the City until at least 2035 (when certain existing County issued redevelopment bonds
expire), which means that developing the site without such tax revenue generating uses will put a
significant strain on the City's General Fund because the residential uses will increase the demands
for police, fire and other public services but will not provide any funding to pay for those City services.
This is an existing problem facing the City because several of the other residential communities in the
project vicinity currently have a negative effect on the City's General Fund.
Comment 52-f:
b. This proposed development is focused on short term rentals and also features fractional
ownership formulas. How does that reconcile with the nature of the surrounding residential
developments?
Response 52-f:
The project's compatibility with the surrounding land uses is discussed on pages 4.10-15 — 4.10-24 of
the Draft EIR, which determined that the project is consistent with the surrounding communities
because the majority of the project will be developed with low-density residential uses, with the
higher intensity tourist commercial uses concentrated in the southwest portion of the site and away
from the adjacent residential communities. In addition, the perimeter streets (Madison Street and
Avenue 58) will be improved with perimeter walls, landscaping and sidewalks, consistent with the
other communities in the area. Please see Response 41-c and Responses 83-w through 83-hh for a
further discussion of General Plan consistency issues. Please also see Response 52-g regarding STVRs.
Comment 52-g:
c. Most cities are fighting against short term rentals nuisances. Why would La Quinta be intent on
promoting such activities, instead of focusing on the needs of long-term residents?
Response 52-g:
The project proposes to allow short-term vacation rentals (STVRs) in all tourist commercial and
residential areas within the Project. The project Development Agreement will incorporate the
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extensive restrictions and regulations set forth in Chapter 3.25 of the City's Municipal Code, including
the operational requirements and restrictions in Section 3.25.070, which limits the number of
daytime and overnight guests in each unit to ensure that occupancy levels are appropriate for the
number of bedrooms and compatible with single-family residential communities. All STVRs will also
be subject to the noise restrictions in Sections 9.100.210 and 11.08.040 of the Municipal Code, as well
as the monetary and permit revocation penalties for violating the City's STVR regulations. With
adherence to these extensive requirements and regulations, there is no evidence that allowing STVRs
within the tourist commercial and residential portions of the project will cause any significant adverse
effects on any of the surrounding communities.
The City has also extensively investigated and evaluated the effects of the City's existing STVRs. On
December 7, 2021, City staff provided a report to the City Council detailing its tracking of STVR-related
complaints and City citations. This report shows that with implementation of the amendments to
Chapter 3.25 of the Municipal Code adopted in 2020 and 2021, the City is seeing a significant
reduction in both complaints and citations relating to STVRs. In addition, the majority of both
complaints and citations are for unpermitted STVRs, not STVRs that are participating in the City's
permitting and reporting requirements (see 12/7/21 City Council Staff Report, Figures 7 & 9). For the
proposed project, the Development Agreement requires that STVRS be centrally managed to ensure
full compliance with the permitting requirements and all operational restrictions, including noise,
occupancy and parking restrictions.
The commenter's opinions regarding the impacts of short term vacation rentals are noted, but no
evidence has been presented that allowing STVRs in the project will create any significant impact for
other project residents, or for the residents of the surrounding communities, and no such impacts are
anticipated.
Comment 52-h:
d. This proposed development aims to operate 365 days a year from 7 AM to 10 PM with
corresponding traffic noise, operating noise (wave equipment noise, wave noise (roar),
announcement/alarm noise, music noise, etc...) (DEIR 1-29, 4.11-15, 4.11-47, 4.11-49).
i. Why are the reports not investigating each one of these noise categories individually?
ii. Why are the reports not investigating all of these noise categories combined?
iii. Why are the reports relying solely on theoretical noise models?
iv. Why are the reports allowed to use and extrapolate data from other non -identical facilities?
v. Why are the developers not asked to execute real-time and real-life noise experiments (for all noise
sources individually and cumulatively) within the affected communities?
vi. Why is everyone studiously ignoring the impact during construction over a number of years,
especially since the developer is projecting and requesting 'open timing' for completion?
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vii. How can the City accept the unrealistic and unscientific argument that a 'mountain absorbs noise'?
Response 52-h:
In response to items i. through iv. in this comment, the Draft EIR and supporting noise study
(Appendix K.1) do analyze traffic and operational noise sources separately and also their combined
effects. As described on pages 4.11-22 and shown in Exhibit 4.11-2 of the Draft EIR, 10 off-site noise
measurement locations were selected as representative of the closest and most -sensitive receptor
locations, identified as locations R1 through R10. These locations are in, or closer to the project than,
the existing surrounding residential communities. Existing noise level measurements were taken in
all ten locations, and these noise levels are described on pages 22-24 of the Noise Study (Appendix
K.1). As described in Chapter 6 of the Noise Study, off-site traffic noise increases were modeled using
an industry -standard computer model that replicates the Federal Highway Association model and is
consistent with County of Riverside and City requirements. Project -related off-site traffic noise is
analyzed in Chapter 7 of the Noise Study (starting on page 35), including projected noise levels with
and without the project on all area roadway segments at different time horizons (including opening
year and full -buildout). Traffic noise impacts are discussed on pages 4.11-35 through 4.11-43 in the
Draft EIR. The Noise Study analyzes the operational noise in Chapter 10, Operational Noise Impacts
(starting on page 73 of the Noise Study). Each primary operational noise source was considered
separately by taking actual noise measurements at comparable facilities (Wave Basin/wave machine,
outdoor pool/spa activity, community park activity, neighborhood commercial activities), and then
using the industry -standard CadnaA noise modelling program to project the individual and cumulative
noise level increases at all 10 off-site receptors R1 — R10 from these noise sources. As stated in
Chapter 10 (on page 73 of the Noise Study), "it is important to note that the following projected noise
levels assume the worst-case noise environment with the Wave Basin/wave machine activity, outdoor
pool/spa activity, outdoor activity, and neighborhood commercial land use activity all operating
simultaneously." This is also stated on page 4.11-44 of the Draft EIR. In other words, combining all of
the operational noise anticipated at the project site would generate the highest possible noise levels
at the site. If the highest noise level at the project site does not exceed the City's established
thresholds of significance, then the project would result in less than significant impacts. Please also
see the Topical Response on Noise in Section 2.2.4 for a summary of the noise analysis for all potential
noise sources in the Draft EIR.
In response to item iii, and explained above, the comment is incorrect in that the noise analysis relies
on a combination of actual noise measurements and industry -standard computer noise modelling. As
described in Chapter 6 and on pages 73 — 76 of the Noise Study (Appendix K.1) methodologies utilized
and noise models were established by the appropriate state, federal and local agencies to ensure
accurate findings that comply with CEQA. As explained in Topical Response 2.2.4, a three dimensional
noise model was used to estimate the noise that would be generated by operation of the Wave Basin.
Noise modeling was conducted at eight different locations at the existing Kelly Slater Surf Ranch in
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Lemoore, California (see pages 73 - 74 of the Noise Study). In addition, supplemental noise
measurements were taken at the Lemoore facility in August 2021 to ensure that the measurements
were taken while the waves were being actively surfed to capture all sources of noise, including the
rescue jet ski. As explained in Appendix K.3 of this Final EIR, these measurements validated the
original noise findings and reflected a slight reduction in maximum noise levels due to improvements
to the wave machine technologies. The Wave Basin proposed in the project will use the same
technology and equipment and, for this reason, noise measurements were collected at the Wave
Basin in Lemoore and these monitored noise levels were incorporated into the noise modeling to
reflect the noise generated by the equipment and other sources of noise at this existing facility.
In response to item v., and as explained above and in the Noise Topical Response (Section 2.2.4), the
noise analysis includes real-world noise measurements taken at 10 sensitive receptor locations
around the project, as well as actual noise measurements of the existing Wave Basin in Lemoore and
other activities comparable to the uses proposed for the project. Table 4.11-26 shows the results of
this analysis and that project operational noise will not cause a significant increase in noise at any of
the 10 sensitive receptor locations (see Draft EIR p. 4.11-49).
In response to item vi., Section 3.6.5, Project Construction in Section 3.0, Project Description, contains
a complete description of the timeframes for construction of the project. As stated on page 3-23
"project construction will occur in eight (8) primary development areas with buildout anticipated to
occur in three primary phases over approximately 4- to 6 -years.
The Noise Study contains a full analysis of potential construction noise impacts in Chapter 11,
Construction Impacts (starting on page 81 of the Noise Study) that would occur during this
construction period, including potential noise increases at all 10 sensitive receptor locations. As
stated on page 85 of the Noise Study, "the construction noise analysis shows that the highest
construction noise levels will occur when construction activities take place at the closest point from
primary project construction activity to each of the nearby receiver locations. To evaluate whether
the project will generate potentially significant short-term noise levels at nearby receiver locations, a
construction -related noise level threshold of 85 dBA Leq (as established by the NIOSH [National
Institute for Occupational Safety and Health]) is used as an acceptable threshold to assess
construction noise level impacts. The construction noise analysis shows that the nearby receiver
locations will not experience noise levels that exceed the 85 dBA Leq significance threshold during
project construction activities as shown on Tables 11-2 and 11-3 [page 84 of Noise Study]. Therefore,
the noise impacts due to project construction noise is considered less than significant at all receiver
locations." Tables 11-2 and 11-3 of the Noise Study analyzes construction noise in phases. This
information is transposed to pages 4.11-32 — 4.11-35 of the Draft EIR, which fully discloses the
potential noise levels during construction activities.
In response to item vii., please refer to the Noise Topical Response in Section 2.2.4. As explained
therein, the technical experts at Urban Crossroads established that noise generated from project
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operation will not be amplified by Coral Mountain because, based on FHWA studies and guidance, if
all noise striking a hard surface were reflected back to a receiving point, the maximum increase in
noise would be limited to 3 dBA. However, not all acoustical energy is reflected back to the same
point, and accordingly, FHWA measurements show that reflective noise increases do not exceed 1-2
dBA, which is not perceptible to the human ear. In addition, the distance between the project noise
sources and Coral Mountain, as well as the soft desert landscape between the noise sources and Coral
Mountain mean that no significant project noise will reach or bounce off Coral Mountain. Also see
Response 14-q above.
Comment 52-1:
e. This proposed development aims to operated 365 days a year from 7 AM to 10 PM with
corresponding light pollution from a number of proposed new light sources (DEIR 4.1-41, 4.1-39, 4.1-
57, 4.10-28).
i. Why are the reports not investigating each one of the possible light sources individually?
ii. Why are the reports relying solely on theoretical light pollution models?
iii. How can a report that states 'insignificant' impact from 80 ft light poles be considered bona fide?
No refereed technical explanation or justification is provided in the report. Please justify why such
a glaring oversight should not be rectified and a new independent report commissioned?
iv. How can the City accept the unrealistic and unscientific argument that 'light will not significantly
reflect off water'?
v. Why would the developers be allowed an exemption (for 80ft) from the current municipal code
which allows only 8 ft pole heights for this type of use?
vi. Why are the developers not asked to execute real-time light impact experiments (for all light
sources individually and cumulatively — especially the two third mile long 80 ft poles every 20 ft
along the basin) within the affected communities?
vii. Why should there not be an independent study of project light impacts on the surrounding
communities?
Response 52-i:
In response to item i, the proposed residential and commercial uses will include standard lighting,
designed in accordance with applicable standards in the City's Municipal Code, as described in Section
4.1 of the Draft EIR, at pages 4.1-60 — 4.1-61, that will conform to Municipal Code lighting standards
and will not result in light levels that exceed City standards. Because high intensity lighting is proposed
for the Wave Basin detailed technical analysis of the lighting plan for the Wave Basin was completed,
as described in the Light and Glare Topical Response in Section 2.2.1 of this Chapter.
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In response to item ii — iv, the analysis of the potential for the lighting proposed for the Wave Basin
to result in substantial impacts was not based solely on theoretical light pollution models. As
explained in the Topical Response on Light and Glare in Section 2.2.1, and demonstrated in the lighting
contour exhibit on page 4-10 and Exhibits 4.1-14 through 4.1-19 in the Draft EIR. The photometric
analysis, which is the standard established throughout California and in the City for lighting analysis,
was completed for the proposed lighting plan for the Wave Basin and reflects the specific lighting
fixtures proposed for installation and use on the project site. In addition, as described in Topical
Response 2.2.1, additional testing was conducted during the lighting demonstration held on
November 17, 2021. As described on page 2-9 above and in Appendix B.2 to this Final EIR, the lighting
test validated the computer modeling results and confirmed that at 120 feet behind or next to each
light pole, light levels were consistently measured at or below 0.01 foot candles, which represents an
imperceptible light level. In addition, as explained in Appendix B.2, the proposed lighting system has
been optimized to both minimize any light spillage and also minimize any reflection off the surface of
the water. The 80 -foot height of the poles allows for each fixture to be aimed to only light the
intended portion Wave Basin itself while minimizing the angle at which the light hits the water surface
to minimize any reflection. In addition, each fixture is also fully shielded to provide an effective cut-
off of the light to avoid any spillage outside the immediate Wave Basin area.
In response to item v., the Developer is not seeking an exemption from the City's Municipal Code
limitations on outdoor lighting heights. Pursuant to Section 9.100.150 of that Code, recreational
facility lighting is not subject to a height limitation so long as the lighting complies with the allowed
recreational lighting cut-off of 10:00 p.m. (see Draft EIR at p. 4.1-39). In addition, the visual
simulations and line -of -sight analysis included on pages 4.1-22 through 4.1-39 demonstrate that due
to distance and intervening improvements and vegetation, the 80 -foot -tall poles will be barely visible,
or not visible at all from public vantage points, depending on the viewing location.
In response to items vi. and vii, as discussed in the Light and Glare Topical Response at Section 2.2.1,
and described in detail in Appendix B.2 to this Final EIR, the lighting analysis included highly accurate
computer modeling by the lighting engineers who designed the TLC for LED lighting system and
analyzed the complete system, and that analysis was subsequently validated by light readings taken
during an actual on-site lighting test using the exactly the lighting fixtures, pole height, location and
lighting direction used on the computer model and proposed for the project site. Conducting the
actual test with al 17 poles was physically and financially infeasible, but the readings from the two
poles and fixtures used for the test provided actual light readings the lighting engineers were able to
use to analyze the entire system modeling to ensure its accuracy and validity. In addition, members
of City staff attended the lighting test and personally observed the lighting demonstration to confirm
that the test, results, and photos of the lighting are accurate. Based on this analysis and Appendix
B.2, the lighting study supports the analysis and conclusions in the Draft EIR that the project will not
have any significant light or glare impacts on the surrounding communities.
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Comment 52-j:
f. This proposed development aims to exceed the current permissible height specs of the municipal
code for various structures (DEIR 4.1-57, 4.1-12, 4.1-13).
i. Why do the current reports not address such structures individually and specifically?
ii. How can loss of mountain view by numerous surrounding residential developments not be
considered a substantial objection to this proposed project?
iii. How serious can you take a report that states that 'vegetation is not permanent as it can change
form or be removed' as part of the argumentation that view loss is not an applicable argument in
this case? How can the City possibly accept this type of rationale without further thought or
question? Why should there not be an independent study of impacts on the surrounding
communities?
iv. At some point the report states: 'However, impacts associated with scenic vistas cannot be reduced
to less than significant levels and will remain significant and unavoidable.' (DEIR 4.1-45). How can
this be deemed acceptable as an argument to support a zoning change?
Response 52-j:
In response to items i. the Aesthetics chapter of the EIR properly analyzes and discloses the height of
the tallest buildings and other structures in each planning area, including where standard zoning code
limits are replaced with higher limits in the Specific Plan (see Table 4.1-5 and accompanying discussion
on pages 4.1-12 — 4.1-13). The location and height of homes are addressed (32' vs. 28' allowed in
zoning code), the location and height of the hotel is addressed (45' vs. 40' allowed in zoning code),
and the location and height of commercial structures within the neighborhood shopping center are
addressed (35' — consistent with zoning code).
As demonstrated by the line -of-sight analysis and visual simulations included as Exhibits 4.1-4
through 4.1-13, the proposed structures that exceed the standard limits in the zoning code will not
cause any significant impact on existing views.
In response to item ii, and contrary to the comment's assertion, the perimeter walls, landscaping and
low-density residential structures were determined to have a significant impact on existing public
views of Coral Mountain from the adjacent roadways, as described on pages 4.1-44 and 4.1-45 of the
Draft EIR. The Draft EIR correctly determined that these impacts would be significant and
unavoidable, even with a requirement for enhanced setbacks for perimeter walls and residential
structures from Madison Street and Avenue 58 (Mitigation Measures AES -1 and AES -2), as discussed
on pages 4.1-72 — 4.1-73.
In response to item iii, the comment's citation could not be found in the Draft EIR. However, contrary
to the comment's assertion, multiple line of sight analyses and visual simulations were prepared to
analyze the project's impacts on views of Coral Mountain and the Santa Rosa Mountains from public
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viewsheds. The analysis concluded that project landscaping and perimeter block walls, as well as the
low density housing properties proposed for the perimeter areas of project, would result in significant
and unavoidable impacts to the views of Coral Mountain and the Santa Rosa Mountains when viewed
along public rights -of -ways. Compared to the existing, unobstructed views of Coral Mountain and
Santa Rosa Mountains, any development on the project site would likely result in similar obstructed
views of the natural landscape. Therefore, the Draft EIR correctly concluded that impacts would be
significant and unavoidable. The impacts on viewsheds from the surrounding communities, therefore,
have been fully and correctly analyzed.
In response to item iv, the Draft EIR does not state that the significant and unavoidable impact
provides an argument for a zoning change. These are two separate issues. As required in CEQA
Guidelines Section 15093, the City is required to balance the economic, legal, social, technological or
other benefits of a proposed project against its significant and unavoidable environmental effects. In
order to approve a proposed project that will have significant and unavoidable impacts, the City
Council must first determine if the benefits of the project outweigh its impacts, and then state in
writing its basis for doing so in specific findings and a document known as a statement of overriding
considerations which, if made, will be attached to a resolution that will be required to certify the EIR.
This requirement is separate and in addition to the City's policy decisions and findings required to
amend the General Plan land use designations or zoning for the site, which will also be set forth in
any resolutions approving such amendments.
Comment 52-k:
g. This proposed development will create potentially significant environmental impacts due to
wasteful, inefficient or unnecessary consumption of energy resources (DEIR 1-22) and will increase
demand for energy in the service areas of IID and SoCal Gas Co (DEIR 4.5-34). The developer admits
that project specific impacts to greenhouse gas emissions will be significant and unavoidable (DEIR 1-
13).
i. How can the City justify a zoning change given these negative environmental facts?
ii. La Quinta residents are already being asked on a regular basis to conserve energy during heat
waves. How will the energy consumption of this project specifically impact the surrounding
communities?
iii. The EIR small print states that the developer will purchase vast amounts of carbon credits. How
can the City possibly believe, or prove, that this is a beneficially "green" project?
Response 52-k:
This comment incorrectly quotes the Draft EIR. Section 4.5, Energy Resources, of the Draft EIR,
concludes that the proposed project would not result in significant environmental impacts due to
wasteful, inefficient, or unnecessary consumption of energy resources at pages 4.5-25-4.5-28. While
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the project will use electricity and increase the demands for energy in IID's service area, the project
incorporates numerous energy efficiency measures, will comply with Title 24 and CALGreen
requirements, and will constitute a very small portion (approximately 0.19 percent) of IID's total
demands. The Draft EIR conclusions are based on calculations of project -related construction and
operational energy consumption for electricity, natural gas, and petroleum. The project will increase
demand for energy in the service areas of IID and Southern California Gas Company, since the site is
currently vacant and undeveloped but will not have any significant effects on the residents of La
Quinta because IID has sufficient electricity generation facilities to meet the project and its other
existing and planned future customers (see Draft EIR pp. 4.5-27 — 4.5-28). The Draft EIR also analyzed
service capacity and infrastructure to support the project, existing communities, and future
development in both Section 4.5, and Section 4.15, Utilities and Service Systems.
The Draft EIR fully evaluated the project's GHG impacts in Section 4.7, Greenhouse Gas Emissions,
and determined that even with implementation of numerous project design features that reduce GHG
emissions, the project will have a significant impact because project implementation would generate
GHG emissions totaling 6.46 MTCO2e per service population per year, which exceeds the applicable
SCAQMD significance threshold of 3.65 MTCO2e. However, with mitigation, the project GHG
emissions are reduced to below the SCAQMD threshold through the purchase of carbon credits. The
EIR does not state that such credits make the project "benefically green," only that such credits are a
recognized way to reduce a project's GHG emissions in California, at least for some types of projects.
Although this mitigation measure was identified in the Draft EIR, because the use of carbon credits
has not been broadly adopted in the Coachella Valley as acceptable and effective mitigation for
residential and resort projects, the EIR concludes that the GHG impacts should be considered
significant and unavoidable. See Draft EIR at p. 4.7-26.
As it regards justification, please see the discussion of CEQA Guidelines Section 15093, its allowances,
and the process by which these determinations are made in Response 52-j.
Comment 52-1:
h. This proposed development will require massive amounts of hazardous chemicals that will be used
and stored on site (DEIR 4.8-18).
i. Nowhere in the reports is there any substantial or specific explanation of usage, storage or safety
measures. Local residents demand to know all risks as detailed in an independent study.
ii. Available chemical treatments will not be sufficient during very hot summer months to provide
adequate protection from microscopic amoeba in the over -warm water. The developer has stated
the water will not be cooled during summer, hence this health risk is currently not be mitigated:
• Who will be liable if/when brain (amebic meningoencephalitis) infections occur?
• Will the City (and thus ultimately residents) end up footing the bill after being sued by a dead
surfer's family?
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• How will the developer specifically mitigate this issue?
Response 52-1:
Section 4.8, Hazards and Hazardous Materials, of the Draft EIR discusses the potential use, transport,
storage, and disposal of hazardous materials associated with the project in discussions a/b. starting
on page 4.8-16. As discussed on page 4.8-18 the Wave Basin is anticipated to use approximately
216,000 gallons of sodium hypochlorite and 14,440 gallons of sulfuric acid annually, which are both
commonly used chemicals in swimming pools. These chemicals will be stored on site and fed into
polyethylene tanks located in a pre-engineered metal building with a 24 -inch -high containment wall
with chemical resistant coating. As stated in Section 4.8, the project is required by state and local
regulations to implement features during project construction and operation that would mitigate
release of hazardous materials that would negatively impact the environment or people.
Contrary to comment h.(i) above, Page 4.8-19 discusses the existing regulations that apply to the
storage of these materials, including the County of Riverside's requirements for permitting businesses
that handle hazardous materials in conformance with Chapter 6.95 of the California Health and Safety
Code. The County's regulations require the applicant to obtain a permit to store these hazardous
materials on the site and electronically submit a business plan in the Statewide Informational
Management System. The Draft EIR correctly identified the quantities to be stored, the safety
measures to be employed, and the standards by which the project will abide, and determined that
these impacts would be less than significant.
Comment 52-m:
Local community home values are likely to be negatively impacted by this development if it proceeds.
Will Riverside County reduce the property tax basis for the affected homeowners when that happens?
Response 52-m:
The commenter's opinion regarding home values is noted, but this does not raise any recognized
environmental issues of the project. Section 15131 (a) of the CEQA Guidelines preclude the analysis
of economic effects unless that economic effect would have a physical impact on the environment,
which is not asserted here.
Comment 52-n:
The developer is going to request separate permissions for mass events (DEIR 1-7).
a. How will noise violations during Special Events be enforced by the City and what process will be
used?
b. How will illegal behavior during Special Events be monitored and mitigated?
c. Substantial additional traffic impact (including local gridlock for Trilogy and Andalusia) will be felt
by local residents. Why will the City not commission an independent study?
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d. How will unavoidable large crowd litter/trash generation immediately outside the park boundaries
be monitored and mitigated?
e. Will the developer be asked to cover all additional City service expenses (law enforcement, medical
response, fire, road repair, traffic signalization)?
f. If events are allowed to occur, will the City limit such individual event permits to maximum 2 per
year?
Response 52-n:
The proposed Specific Plan would allow 4 special events annually and limit the attendance to 2,500
persons. In response to this comment, it should be noted that, as identified on page 1-7 of the Draft
EIR Temporary Use Permit(s) (TUP) will be required for each event.
The City's process and requirements for Temporary Use Permits is contained in Sections 9.100.130
and 9.210.050 of the City's Municipal Code. Further, the Draft EIR addresses specific issues to be
addressed in each TUP, which include submission of special event traffic and parking plan and/or
traffic management plan (Mitigation Measures TRA -10 through TRA -11) to avoid any traffic or
parking impacts and ensure adequate public safety resources. (see Draft EIR pp. 4.13-62 — 4.13-63).
In addition, the TUP requires the City to make the specific findings set forth in Section 9.60.170, which
include that (a) the event will not be detrimental to the health, safety and general welfare of the
community in the area of the proposed event, (b) there is adequate area to accommodate the
anticipated attendance, (c) there is sufficient parking for the anticipated attendance, (d) food service,
medical facilities, solid waste facilities, sewage disposal facilities, and potable water service are
provided, (e) fire protection plans and facilities have been provided to the satisfaction of the fire
marshal, (f) security plans and facilities have been provided to the satisfaction of the sheriff, and (g)
public roadways are capable of accommodating the anticipated traffic volumes.
In response to item a., noise generated during Special Events was analyzed in the Noise Study and
discussed in Section 4.11, Noise, of the Draft EIR. Noise generated from the proposed Special Events
must comply with the City's noise limits set forth in Section 9.100.210 of the Municipal Code, and was
determined to result in less than significant impacts. However, if a noise violation were to occur
during a special event, the City's Code enforcement provisions allow for the imposition of financial
penalties and permit revocation, and potentially prosecution of a misdemeanor upon repeated
violations (see, e.g., Sections 1.01.200 et seq.).
In response to item b, as explained above, the TUP requires adequate security as approved by the
sheriff, and any illegal activities would be addressed by on-site security personnel, and/or the sheriff's
department.
In response to item c., please consult the Traffic Topical Response in Section 2.2 of this Chapter, as
well as Section 4.13, Transportation, in the Draft EIR. Technical studies, including a Traffic Impact
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Analysis, was conducted by traffic experts and reviewed by the City Traffic Engineer. The Draft EIR
correctly identified the trip generation, distribution and impact of special events in Tables 4.13-26,
4.13-27, and 4.13-28b, respectively. Impacts were identified at the intersections identified in Table
4.13-28a, which are the same intersections and require the same improvements required for Phase
3 of project buildout (see page 4.13-45). Impacts of special event traffic were identified as potentially
significant, and required mitigation, including Mitigation Measures TRA -9 through TRA -14. The Draft
EIR correctly identified the level of impact, provided mitigation, and demonstrated that the impacts
can be reduced to less than significant levels during special events.
In response to item d., the conditions of approval on all Temporary Use Permit issued will address
how trash is to be handled at each event, including addressing the need for trash pick-up or clean up
in areas located outside of the project site.
In response to item e., Temporary Use Permits for events requiring substantial involvement of police
and fire services are typically required, in their conditions of approval, to reimburse the Sheriff's
Department and Fire Department, as applicable.
In response to item f., the applicant has requested up to 4 special events annually, which is consistent
with the City Municipal Code provisions and controlled by the Specific Plan.
Comment 52-o:
4. California is experiencing a severe drought. For years (and continuing) we are all trying to conserve
water. This project will require millions of gallons of potable water every year. Looking at DEIR 4.10-
19, 1-27, 1-36, 4.10.20, 4.15-29, 4.15-34 (and I am probably missing a few) a number of questions
arise.
a. The developer's own estimates project water usage within a "4% or so" margin. What happens
when they go over the contract allotted numbers? Can they just buy unlimited additional gallons?
b. The developer reports having a contract already for potable water from our local aquifer. How can
the local water company be allowed to execute such a wasteful contract when public water
reserves are already under tremendous pressure.
c. The argument that this project uses less water than a golf is invalid because golf course operations
now mostly use recycled (gray) water. Why can the developer not be required to use recycled
water?
d. Is the City conscious of the fact that with rising population numbers the water wasted on this
project are going to be needed in the very near future?
e. The developer's reports on water usage are incomplete and rather less than scientifically justified.
Why does the City not request very detailed and scientifically/technically justified and
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independently generated information regarding evaporation, specific water usage patterns for
individual elements of the project facilities, detailed wave pool maintenance requirements?
Response 52-o:
The project's projected water use and the sufficiency of CVWD's existing water sources to meet the
project water demands and all other existing and planned future water demands are thoroughly
discussed in the Topical Response on Water Resources in Section 2.2.3 above, as well as in the
WSA/WSV attached as Appendix M of the Draft EIR.
In response to comments (a) and (b), the comments misstate the projected water demand and
developer's contractual rights. The developer does not have a contractual right to a specific volume
of water, but rather, CVWD has assessed the project's water demands and its compliance with
CVWD's water allocation limits set forth in its Landscape Ordinance No. 1302.4. If the project exceeds
the maximum water allowance (MAWA), further landscape plans will be denied until the project is
brought into compliance. The existing contract between CVWD and the developer pertains to the
developer's obligation to fund and/or construct sewer and water facilities but does not include any
contractual right to receive water from CVWD.
In response to comment (c), recycled water is not presently available in the project vicinity and is not
being used at the nearby golf courses. Please see Responses 19-b and 49-b for additional information
on the project's use of non -potable water and the availability of recycled water.
In response to comments (d) and (e), the commenter's opinions on the project's water demands are
noted. However, CVWD's groundwater management plans and long-range planning account for
population growth and increasing water demands. Please see the Topical Response on Water
Resources in Section 2.2.3, including Figure ES -6 and ES -8 from the 2022 Indio Subbasin Water
Management Plan Update, which show that between 2020 and 2045, even with the project and all
other existing and planned future uses, CVWD expects to have a net increase in groundwater storage
over that 25 -year period due to a combination of efficiency/water saving measures, source
substitution, and replenishment efforts. Finally, the WSA for the project provides, in Tables 2.0-2
(indoor) and 2.0-3 (outdoor), a detailed list of the uses proposed and the water demand resulting
from these uses. The City requested, as required by California Water Code Section 10910, that the
CVWD, the water purveyor and local expert on groundwater resources for the City, prepare a WSA,
which analyzed "evaporation, specific water usage patterns for individual elements of the project
facilities, detailed wave pool maintenance" and correctly determined that the impacts of the project
on water resources would be less than significant.
Comment 52-p:
5. The traffic analysis submitted reflects middle of the COVID pandemic activity between November
2019 and October 2020. This analysis mis-represents the actual anticipated traffic reality (DEIR 4.13-
42).
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a. The impact on local residents will be large. Why will the City not commission an independent study
at the developer's expense?
b. What considerations are in place for possible (new) public or private bus transportation to the
development? Has a detailed study been submitted?
c. What considerations are in place for queue locations for taxi, Uber, Lyft, etc? Has a detailed study
been submitted?
Response 52-p:
This comment is incorrect. As stated on page 29 of the Traffic Impact Analysis and page 4.13-10 in
Section 4.13, Transportation, in the Draft EIR, "the intersection LOS analysis is based on the traffic
volumes observed during the peak hour conditions using traffic count data collected on August 15th,
2017, April 9th, 2019, May 7th, 2019, and September 10, 2019 (which were all collected before the
effects of the COVID-19 pandemic). Moreover, these counts were adjusted upward in accordance
with the City's Engineering Bulletin # 06-13 to reflect peak season conditions."
Therefore, traffic counts were taken prior to COVID, and baseline numbers reflect peak season levels.
With respect to comment (a), the traffic study was completed by Urban Crossroads, traffic expert
consultants hired by the EIR consultant to prepare a traffic study in full compliance with all appliable
CEQA requirements and in compliance with a traffic study scope approved by the City. The traffic
study was reviewed by the City, as is their practice with all traffic studies, and found to be sufficient
to meet its standards and requirements, as established in City policy (Engineering Bulletin #06-13).
With respect to comments (b) and (c), bus service is not presently provided to the project area and is
under the control of Sunline Transit Agency, not the City of La Quinta. Detailed analysis of potential
locations for private buses or rideshare programs have not been completed at this Specific Plan level
of planning, but may be considered during future project implementation in connection with the
City's processing of individual site development permits, or for TUPs provided for special events, as
applicable.
Comment 52-q:
In this comment, a letter from Michiels, dated July 20th is attached.
Response 52-q:
The attached letters are copies of Comment Letters No. 45 and 46, above.
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Comment Letter No. 53: Dan Rendino
Date: July 21, 2021
Affiliation: Area Resident
Comment 53-a:
I attended by a zoom meeting last night a presentation by the developers on the proposed
development of the Coral Mountain Resort. My first impression is how in the world did this circus
proposal advance to the city council for purposes of trying to get a variance. It is an embarrassment
to admit to friends and neighbors that this is even being considered. We moved here because La
Quinta was a place that afforded us the opportunity to retire from the hectic city life that we were
brought up in. Had this project been known to us when we moved here, we would be living
somewhere else. This is exactly what we were trying to get away from when we bought here. These
are some of the reasons that this project should be deep - sixed.
Response 53-a:
This comment noted. Responses are provided below to the comments in this email message. For
clarification, the project does not include any request for a variance but it does seek amendments to
the City's General Plan and zoning for the site, and a Specific Plan whose development standards alter
Zoning standards, as allowed by Government Code Sections 65450 et seq. and Municipal Code
Chapter 9.240. Please see Responses 15-d and 17-a regarding these policy decisions.
Comment 53-b:
1. La Quinta does not need to be a haven for an additional STRV units (600 additional units with an
average of 3 bedrooms) at a time the town and its developments (PGA West where we live), are trying
to remedy the existing problems that already exist. La Quinta unlike some other valley towns has
allowed widespread STRV units to be permitted with the problems associated with them. I do
appreciate the effort the town has put in to remedy the situation. Now is not the time to reverse the
work done to correct the issues. I personally know people who have not bought property in our town
because of the widespread STVR's. They have chosen other towns that are more strict in this area.
Response 53-b:
The commenter's opinions are noted. Please see Response 52-g for a further response regarding
STVRs.
Comment 53-c:
2. Traffic is already a problem in La Quinta. There are only 3 entry points into La Quinta (Washington,
Jefferson and Madison). Traffic on these streets are already bad in the season. 600 three bedroom
apartments means 1800 additional vehicles on our streets 365 days a year. They claim this issue will
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be remedied by the town. Putting up additional stop lights does not fix the traffic problem but makes
it worse by increasing delays. This is not something that we need.
Response 53-c:
The commenter's opinions are noted. The Draft EIR included a complete assessment of the impacts
of the project on local traffic (pages 4.13-17 — 4.13-51), based on a technical report prepared to City
and professional standards. The analysis concluded that traffic will increase, but within thresholds
acceptable to the City, with the implementation of mitigation measures.
Comment 53-d:
3. The proposed plan does not include facts and data but are really just hopes, wishes and
suppositions. They only presented "goals". What happens when these goals are not met. Does the
town propose to shut them down? These hopes and dreams are applicable to noise, lighting, traffic,
water consumption, electrical overload etc. Pie in the sky! Anyone could see through what they were
trying to do, it doesn't pass the smell test. Throw out a bunch of hopes and wishes with nothing to
back it up, and hope that it sticks.
Response 53-d:
The commenter's opinions are noted. This comment does not provide any substantial evidence of
invalid data used in any of the technical reports or discussion in the Draft EIR. The technical reports
generated for the project were prepared by experts in their respective professional fields and
reviewed by the City of La Quinta. The methodologies used for the technical reports are based on
applicable local, regional and state thresholds of significance.
Comment 53-e:
4. Do the city officials and these developers realize that all of California is being stressed by a terrible
drought which predictions say will only get worse. We are being asked to limit the use of water for
household use, golf courses are being forced to find different means of irrigation and these people
want to fill a pool with 18 million gallons of precious drinking water so that someone could go surfing
150 miles away from the ocean. Who comes up with these ideas? What city would approve this. The
water in this pool in the summer will be almost 100 degrees. In this climate how much evaporation
takes place? What happens when the pool repairs are needed and the pool has to be drained? Why
should my water rate be raised so that these people can live out their dreams of a Disneyland in the
Desert? They claim Imperial Irrigation says out is possible. Because it is possible does not mean it
should be done! The entire West is under draught conditions and you have a proposal in from of you
to make it worse.
Response 53-e:
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The commenter's opinions are noted. Please see the Topical Response on Water Resources in Section
2.2.3 of this Chapter for information on the water demand estimate for the project, evaporation rates,
and CVWD's groundwater management plan, including projections for long-term water demand and
supplies. With respect to water temperatures please see Response 42-d. Regarding repairs to the
Wave Basin, both maintenance and repairs can be completed without draining the Basin (see
Appendix M.2 to this Final EIR).
Comment 53-f:
5. They also want to be able to have "special events"! Four times a year! 4 days per event! That is 16
Coachellas a year! One thing about the pandemic that was good was that there was no Coachella.
Enough said. La Quinta does not need to be another Coachella with the disruption it brings.
Response 53-f:
The commenter's opinion on the special events proposed as part of the project is noted. The special
events proposed for the project are limited to a maximum of 2,500 people per day, whereas
attendance at the Coachella and Stagecoach music festivals can exceed 100,000 people per day.
Comment 53-g:
6. They "think" that noise will not be an issue because their model tells them so. No independent data
just hopes, wishes and dreams. They claim that Coral Mountain will be an absorber of the noise.
Really? Having 80 foot light towers and wave machines going off every 3 minutes from 7AM to 10PM
is just not something we should allow.
Response 53-g:
The commenter's opinion is noted. Please see Response 52-h for a complete response to this
comment.
Comment 53-h:
7. Homes will start at $2.5 million. Do you know anyone who would buy a home to live in the middle
of a water park? These homes will never be built and sold and the project will have a 16 million gallon
pool in a hole in the middle of the desert. The tax revenue you hope to get will not ever happen.
Response 53-h:
The commenter's opinions on the project are noted.
Comment 53-i:
I am really surprised that this project has risen to the point where it is even being considered. I would
be embarrassed to tell someone that the town of La Quinta is even considering this project. I am
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confident that you city officials will put an end to this madness and get on to serious issues facing the
town. I thank you for your consideration.
Response 53-h:
This comment is noted.
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Comment Letter No. 54: Carol Welty and Art Stephens
Date: July 21, 2021
Affiliation: Area Resident
Comment 54-a:
The drought in the west is well documented one of the worst handful of years since the year 800 A.D.
per Park Williams a hydroclimatologist at UCLA. One third of crops in California cannot be planted due
to lack of water. The drought is draining reservoirs by 30% like Lake Mead at an alarming rate,
including our own Salton Sea. To use precious water in the desert for a water absorbing fun park is
beyond measure of lack of insightfulness.
Response 54-a:
The commenter's opinion is noted. Please see the Topical Response on Water Resource in Section
2.2.3 of this Chapter, which provides a detailed explanation of CVWD's groundwater management of
the Indio Subbasin, and how that planning and management accounts for climate change and the
potential for extended drought conditions and potential reductions in water deliveries from the
Colorado River and State Water Project exchange. After accounting for these conditions, CVWD has
determined that there are adequate supplies of water to serve the proposed project and all other
existing and planned future uses in the area.
The Draft EIR correctly determined that the project will not have any significant adverse effects
relating to water use.
Comment 54-b:
Not only the water problem but to put a commercial project among planned residential communities
does not make sense. We moved to this community in great part because it was a quiet community
and area for residential use only.
Response 54-b:
The commenter's opinion on the proposed commercial uses are noted. Please see Responses 15-d
and 17-a as they relate to processing of changes in land uses.
Comment 54-c:
We strongly urge the city planning department as well as all involved in approving any development
to please be aware of all of the negatives involved with allowing this project to go through. Thank you
for your consideration.
Response 54-c:
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This comment is noted.
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Comment Letter No. 55: Fredrick Roth
Date: July 26, 2021
Affiliation: Area Resident
Comment 55-a:
I have read the proposed plan and EIR. I oppose the project. I bought my house across Madison from
this project in full knowledge that that undeveloped parcel was zoned for golf and low-density homes.
I never would have bought here if I thought that property would become a higher -density
development, with hundreds of short-term renters coming for events at least four times a year. This
project obviously would require rezoning for commercial, hotel, and amusement facilities. There is
absolutely no reason why the City of La Quinta should approve such a rezoning. We don't need it, we
don't want it, and it's a terrible misuse of a wonderful parcel. That parcel should be developed for
low-density properties as planned and promised.
Response 55-a:
The commenter's opinions on the proposed zone change and special events are noted. As it relates
to changes in the zoning required for the project, please see Responses 15-d and 17-a.
With regard to short-term rentals, please see Response 52-g.
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Comment Letter No. 56: Derek Wong (2)
Date: July 27, 2021
Affiliation: Area Resident
Comment 56-a:
A fundamental shift in how we live our lives is occurring on a magnitude beyond the headlines...the
full import of this catastrophic drought has yet to take effect as it continues to unfold daily. There is
no way to determine its duration but it is said that a full 10 years of solid seasonal rain will be required
before we "return to normal." Repeat: 10 years!
It has been publicized ad nauseam that the reservoirs are at their lowest levels ever, that the Colorado
River supply will cease and that wells throughout the state are being over -pumped, agricultural fields
are increasingly fallow, wildlife decimated, wildfires burning without end and towns left dried and
barren...
...and yet, we continue to discuss the building of Wave pools, golf courses, private lagoons and lakes
as if there is no crisis at all. To even consider this project and others like it is irresponsible and borders
on deliberate shortsightedness... with profit as the motivator. Slick marketing that promises an
economic paradise with hints of environmental concerns tossed in for appeasement. I find it foolish
and exceedingly hypocritical for the developer to continue touting the benefits of this playground
while ignoring the havoc that encircles us all.
The wealthy can go to any beach in the world for water sports, many La Quinta residents live here full
time and to betray their peace and serenity for this playground is just wrong.
Be responsible citizens, build responsibly, do not rezone Coral Mountain.
Response 56-a:
Please see Response 54-a and Topical Response, 2.2.3, Water Resources in Section 2.2 of this Chapter.
As it relates to rezoning of the property, please see Responses 15-d and 17-a.
The commenter's opinion on the use of water for water features is noted.
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Comment Letter No. 57: Agnes Collins
Date: July 28, 2021
Affiliation: Area Resident
Comment 57-a:
Further to my letter of opposition to the above noted proposal sent to you on March 8, I have
reviewed the environmental report and other pertinent information. I remain strongly opposed to a
surf park development in our area for the same reasons outlined in my March 8 letter as follows:
We have owned our property in Puerta Azul at 57th and Madison for the past 10 years. During that
time, we have immensely enjoyed hiking, walking and cycling in our quiet peaceful community. We
chose our home in La Quinta because we loved the beautiful natural environment.
Response 57-a:
This comment is noted.
Comment 57-b:
We have been informed about the proposal to build a surf park just a short distance from us at 58th
and Madison. We are stunned to hear that this could actually happen in our quiet neighborhood.
Apart from our very serious concerns about the environmental impact of this type of development,
this is just the wrong area for a tourist/commercial development of this nature. While some may say
it will increase the value of nearby properties, that is not the reason most of us purchased in this area.
The proposed development will destroy the character of our quiet tranquil community. A Disney -like
surf park may be desirable to developers, provide recreational opportunities for short term visitors
and will no doubt increase the tax base but the increased noise, traffic and pollution will destroy the
very reason that we moved to the area.
Response 57-b:
The commenter's opinions on the proposed project are noted. As described in Section 3.0. Project
Description in the Draft EIR, the project is a mixed use project that includes low density residential
uses, tourist commercial and general commercial uses, and for clarification, the neighborhood -
serving commercial uses are proposed at the corner of Avenue 58 and Madison Street, and low
density residential is proposed along both Madison Street and Avenue 58. The Wave Basin and other
tourist commercial uses are in the southwest portion of the site and away from the perimeter streets
and surrounding commercial neighborhoods. This comment does not provide substantial evidence to
support the argument that the project will have significant noise, traffic or pollution impacts. As
demonstrated in Sections 4.2, Air Quality, 4.11, Noise, and 4.13, Transportation in the Draft EIR, the
potential impacts of pollution generated at the project; noise generated from the project; and traffic
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related to the proposed project are analyzed and disclosed. The project will result in less than
significant impacts to air quality, noise, and traffic with the implementation of mitigation measures,
based on the technical studies described in those sections of the Draft EIR.
Comment 57-c:
Apart from these issues, we are even more concerned about the environmental sustainability of
building such developments in the desert. We have read the developer's publications attempting to
address environmental issues but we are also aware of the dire warnings of experts in the
environmental field.
Response 57-c:
The commenter's opinion is noted. Although the comment does not identify any specific
environmental or sustainability issues arising out of building developments in the desert, please see
Topical Responses 2.2.3 regarding water resources and Sections 4.5 and 4.7 regarding energy
resources and greenhouse gas emissions, respectively, which provide a detailed discussion the
project's sustainability features.
Comment 57-d:
Now is not a time for excess consumption, economic growth -seeking or projects disconnected from
the environmental issues we face today. The reality of climate change should force us to rethink our
growth models to reduce natural resource consumption and reconcile our relationship with nature.
Please protect our community and our environment and do not allow this proposal to proceed.
Response 57-d:
This comment is noted.
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Comment Letter No. 58: Duncan Woodfin
Date: July 28, 2021
Affiliation: Area Resident
Comment 58-a:
It frightens me to think that there may be a zoning change from residential to commercial that would
allow a Wave Machine/Amusement Park Development below the Coral Mountains in La Quinta. This
Surf and Wave ride would use millions of gallons of fresh drinking water to fill and refresh the ride in
a time of catastrophic drought here in California. The massive amounts of treatment chemicals
needed and continual refill of this pool will destroy the ecology of the site.
Response 58-a:
Please see Responses 15-d and 17-a in response to the comment's concerns regarding changes in
zoning. Please see Topical Response on Water Resources in Section 2.2.3 of this Chapter, and Sections
4.9, Hydrology and Water Quality, and 4.15, Utilities and Service Systems in the Draft EIR for
information on the water needed for the project and the water supply analysis prepared by the
Coachella Valley Water District (CVWD).
With regard to the comment on the chemicals that will be used to treat the water in the Wave Basin,
please see Response 52-1.
Comment 58-b:
How could we even be considering such a monster project that would use our precious fresh drinking
water and tax an already overburdened electrical grid that would be needed to operate the wave
action.
Response 58-b:
Please see Response 58-a regarding the water supply analysis in the Draft EIR, and please also see the
Topical Response on Water Resources in Section 2.2.3 above.
The commenter's opinion on the electrical service system is noted. As described in Sections 4.5,
Energy Resources, and 4.15, Utilities and Service Systems, in the Draft EIR, the project will use
8,642,729 kWh annually, after accounting for the 17.25% reduction in energy demand resulting from
the project's energy efficiency and sustainability project design features (see Draft EIR pages 4.5-25 —
4.5-28). Section 4.5 determined that the construction and operation of the proposed project would
not result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary
consumption of energy resources (CEQA threshold of significance page 4.5-20). Please also see
Response 52-k.
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Comment 58-c:
If this project is approved, it would send the signal that water conservation is no longer needed. That
the drought is nothing but fake news spewed by a corrupt government. Is this the message you want
to send?
Response 58-c:
The commenter's opinion is noted. Please see the Topical Response on Water Resources in Section
2.2.3 of this Chapter for information on the water supply analysis.
Comment 58-d:
As an aside, his project also shows extreme disrespect for our residential community by blocking the
walking path at the base of the Coral Mountains. The developer representative has emphasized
multiple times that they will block this path from neighbors to use; to be used only by their privileged,
rich guests even though the US Bureau of Land Management currently welcomes hikers by
multiple signs permanently posted on the pathway. So many of us in La Quinta enjoy this quiet,
peaceful walk each day. How can you possibly allow public space to be handed over to private
interests. This shows the out of state Developer just doesn't care about being a good neighbor.
Response 58-d:
The existing hiking trail located adjacent to Coral Mountain will remain open to the public.
As stated on page 4.13-47 of the Draft EIR (Section 4.13, Transportation), the Desert Recreation
District Master Plan includes a proposed trail along the toe of Coral Mountain, associated with the
future Coral Mountain Interpretive Center. The proposed trail alignment falls within the project
boundaries. As shown in Mitigation Measure TRA -15, project plans will include accommodations for
this trail within the designated conservation area at the southwestern edge of the property adjacent
to Coral Mountain. Please also see Appendix P to this Final EIR for the Desert Recreation District letter
agreement regarding this future trail connection.
Comment 58-e:
Please Mayor Evans, I beg you, don't turn this quiet neighborhood into a noisy, traffic congested,
water wasting theme park. It is truly the wrong development, in the wrong place and at the wrong
time. Do not support a change of zoning.
Response 58-d:
This comment is noted.
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Comment Letter No. 59: Martin Brewer
Date: July 29, 2021
Affiliation: Area Resident
Comment 59-a:
I am submitting the following comments/concerns about the contents of this document.
(1) The DEIR correctly describes the effect of the project on aesthetics as "Significant and
Unavoidable" even after mitigation. I agree with this assessment, and as the report notes,
there will be adverse effects on scenic vistas, "degradation of the visual character or quality
of the site," and light and glare. Of particular concern to me are the numerous 80' light poles
that will be on from dusk to 10:00 p.m. There are residential communities very nearby, and
this issue alone should be of great concern to the City.
Response 59-a:
The commenter's characterization of the Aesthetics section of the Draft EIR is correct. The
commenter's opinions are noted.
Comment 59-b:
(2) The report states that there will be a "Less than Significant" impact on energy. With a huge wave
pool making waves on a daily and continuous basis, this conclusion seems ridiculous to me. The report
states that no mitigation is required pursuant to the criterion of "Result in potentially significant
environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources,
during project construction or operation." In my judgment, the operation of a wave pool in the middle
of the desert is the epitome of wasting energy.
Response 59-b:
The commenter's opinion on the energy needed to operate the wave pool are noted.
The Draft EIR correctly discloses the energy impacts of the project. Calculations to determine project -
related energy demand were made through the CaIEEMod Version 2016.3.2 model. CaIEEMod is a
statewide land use emissions computer model designed to provide a uniform platform to quantify
potential criteria pollutant and GHG emissions associated with construction and operations from land
use projects. As stated in Section 4.5, page 4.5-26, the project will generate additional demand for
energy at build out of the project of approximately 8,642,729 kW/year, which includes a 17.25%
reduction based on the project's energy efficiency and sustainability project design features. As
discussed on pages 4.5-26 — 4.5-28, the energy use constitutes approximately 0.19% of IID's total
projected demand in 2031, which is consistent with IID's long-term plans for electricity capacity and
supplies and does not represent a wasteful use of energy because the project complies with Title 24
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and CALGreen energy efficiency requirements. The La Quinta General Plan, General Plan EIR, and La
Quinta Greenhouse Gas Reduction Plan were also consulted in order to determine whether the
project exceeded local standards. The significance thresholds were determined based on state and
local thresholds for energy consumption, as shown on page 4.5-15. Please also see Response 52-k.
Comment 59-c:
(3) The report states that Greenhouse Gas emissions will be "Significant and Unavoidable." The
mitigation recommended is that the "Project Applicant" purchase a large amount of carbon credits
as an offset. I would suggest that a better and more environmentally sound solution would be denial
of the project.
Response 59-c:
The commenter's opinion on this proposed mitigation measure and the project is noted.
The mitigation measure provided in the Draft EIR satisfies CEQA standards for mitigation; however,
the Draft EIR also notes that the purchase of carbon credits to offset increases in greenhouse gas
emissions does not have a long track record of successful implementation in the Coachella Valley for
resort and residential communities, and as a result, conservatively concludes that the impact should
be considered significant and unavoidable.
Comment 59-d:
(4) Under "Hydrology and Water Quality," the report states the project's impact is "Less than
Significant." This section includes, "Deletion of Groundwater Supplies..." I do not understand how a
wave pool that will reportedly use millions of gallons of potable water a year is a "Less than
Significant" issue.
Response 59-d:
Please see Topical Response, 2.2.3, Water Resources in Section 2.2 of this Chapter for information on
the water demand estimate for the project, the maximum amount of water the project can use, and
CVWD's groundwater management plan, including projections for long-term water demand and
supplies. The Draft EIR, as described on page 4.15-31, correctly concluded that the project will have
a less than significant impact on water supplies.
Comment 59-e:
(5) Under noise, the report talks mostly about construction noise, and then states, "The operation of
the Wave Basin and associated machines shall be limited to daytime and evening hours of 7:00 a.m.
and 10:00 p.m., compliant with the recreational operational hours allowed by the City of La Quinta."
This is a "non -answer" answer, as it does not address the actual amount the wave pool, employee jet
skis, any loudspeakers, alarms, music, etc., will make.
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Response 59-e:
This comment is incorrect. The Draft EIR analyzes all construction -related and operational noise
generated from the proposed project in Section 4.11, Noise. As explained on pages 4.11-45 and 4.15-
46, the noise generated by the wave pool and loudspeakers (alarms and amplified music are not used
at the Wave Basin) were included in the modeling for noise generated by the project, with a peak
noise level of 75.7 dBA near the wave machine's cable roller system. As shown in Tables 4.11-24 and
4.11-25, this results in a maximum noise level of 51.4 dBA at the nearest off-site sensitive receptor
location and 64.0 dBA at the nearest on-site area immediately adjacent to the Wave Basin itself, which
do not exceed the thresholds of significance established by the City. In addition, further noise level
measurements were taken at the Lemoore facility in August 2021 to evaluate improvements to the
wave machine cable roller system, and to ensure that the measurements were taken while the waves
were being actively used by surfers with the rescue jet ski in operation. These measurements showed
a slight decrease in peak noise levels from 75.7 dBA to 73.5 dBA at a location 12 feet from the noise
source (see Appendix K.3 in this Final EIR).
In addition, as shown on Table 4.11-26 (comparing current ambient noise levels to projected total
noise levels at project buildout), and explained on pages 4.11-48 — 4.11-49, the project will not
significantly increase noise levels at any of the off-site sensitive receiver locations and will not cause
total noise levels to exceed the City's 65 dBA threshold of significance. Please also see the Topical
Response on Noise in Section 2.2.4.
Comment 59-f:
(6) The report states the impact of the project on "Transportation" will be "Less than Significant." This
is a very large development, so it is difficult for me to accept this assessment, but it certainly does not
appear that will be the case during the minimum of four large "Special Events' per year. The City
should look into this in much more detail.
Response 59-f:
The Draft EIR analyzes all traffic that will be generated by the proposed project in Section 4.13,
Transportation, including special event traffic (see pages 4.13-17 — 4.13-47). The potential impacts
from special event traffic are addressed on pages 4.13-42 — 4.13-47, including potential intersection
delays and turning lane storage capacity, and all such facilities will continue to operate at acceptable
levels of service with the improvements required for buildout of the project. In addition, the Draft
EIR identifies Mitigation Measures TRA -9 though TRA -13 to further ensure that special events will
not cause any significant traffic or safety impacts (see pages 4.13-46 — 4.13-47, and 4.13-62 — 4.13-
63). Please also see the Topical Response on Traffic at Section 2.2.5 above.
Comment 59-g:
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Last, as I understand it, this project would require a change in zoning of the property essentially from
residential to tourist commercial. Given the heavily STVR orientation of the project, its hotel, and its
commercial components, this is entirely incompatible with the surrounding developments and will
forever change the nature of this community. The City should not allow that to occur.
Response 59-g:
As described in Section 3.0. Project Description in the Draft EIR, the project is a mixed use project that
includes low density residential uses, tourist commercial and general commercial uses. The project
will require General Plan and Zoning map amendments to assign a Tourist Commercial designation to
the site. Please see Responses 15-d and 17-a as they relate to the proposed Change of Zone, and the
process required to undertake these changes.
Additionally, the proposed resort is consistent with the City of La Quinta's goals and policies for the
City in the La Quinta General Plan. Project consistency with the General Plan is analyzed in Section
4.10, Land Use and Planning, of the Draft EIR. Per Section 4.10 of the Draft EIR (page 4.10-17), the
implementation of the Tourist Commercial land use designation and the associated development of
a recreational facility and hotel will promote the continued growth of the tourism and resort
industries in La Quinta by providing resort, recreational, commercial, and residential land uses on the
386 -acre property. Additionally, the residential uses will incrementally increase demand for
commercial goods and services in the region, thus enhancing the economy. This is consistent with
Policy LU -5.2, Goal LU -6, and Policy LU -6.3 of the General Plan.
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Comment Letter No. 60: Bridgett Novak (1)
Date: August 2, 2021
Affiliation: Area Resident
Comment 60-a:
Please consider this part of the overwhelming opposition to the proposed Wavepark project at
Madisonand Avenues 58/60 in La Quinta.
Response 60-a:
The commenter's opinion on the project is noted.
Comment 60-b:
The project is in DIRECT OPPOSITION to the City of La Quinta's current Noise Ordinances. The City
limits construction hours from 6:00 a.m. to 7:00 p.m. Monday thru Friday and 8:00 a.m. to 5:00 p.m.
Saturday, and prohibits construction noise entirely on Sunday and Holidays. This means that this
Wavepark/Surfamusement Park project will violate the current Noise policies from day one!!
Response 60-b:
The comment is incorrect. There is no substantial evidence in the record that the project would be
constructed outside of the City's permitted hours of construction. Please refer to page 4.11-9 of
Section 4.11, Noise, in the Draft EIR for the correct hours stated in the City Municipal Code 6.08.050
(also provided below for reference). The project will be required to comply with these hours, as stated
on page 4.11-35.
La Quinta Municipal Code
The La Quinta Municipal Code established standards to mitigate noise impacts from construction
activities. To control noise impacts associated with the construction of the proposed project, the City
has established limits to the hours of operation. These are summarized in Table 4.11-2, Construction
Hours, below.
Table 4.11-2 Construction Hours
Jurisdiction
Municipal
Code
Section
Permitted Hours of
Construction Activity
Construction
Noise Level
Standards
La Quinta
5.08.050
October 1st to April 30th
7:00 a.m. to 5:30 p.m.
Mondays to Fridays
May ist to September 30th
6:00 a.m. to 7:00 p.m.
Mondays to Fridays
n/a
All Year: 8:00 a.m. to 5:00 p.m Saturdays; no activity Sundays
and holidays
"n/a" - The City of La Quinta does not specify specific construction noise level standards.
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Comment 60-c:
To exist as currently planned... it has to be considered a 'Special Event'... and not just for the four
times a year they claim they will request... but for every day they operate! Please be serious about
this! What they are proposing is to operate a noisy Amusement feature 7 days a week, from 7:00 a.m.
to 10:00 p.m... in total violation of the City's current regulations. This is another reason why
Meriweather's requested zoning change from residential to commercial should definitely NOT be
allowed.
Response 60-c:
The project requests a zone change in order to allow the proposed resort component of the project.
Please see Responses 15-d and 17-a as it relates to the process required for changing the Zone on the
property. Please also see the Topical Response on Noise in Section 2.2.4 in this Chapter, as well as
Response 59-e.
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Comment Letter No. 61: Bridgett Novak (2)
Date: August 2, 2021
Affiliation: Area Resident
Comment 61-a:
The current Draft EIR for the Coral Mountain Surfamusement Park must be rejected and
Meriweather's request for a zoning change be denied.
P.S. Please add the attached to the documents I already submitted via email on 3/31/2021 and
4/2/2021. All should be considered part of the Public record and Official opposition to this project
and any related zoning change request.
Response 61-a:
This introductory comment is noted. Responses to Novak's attached letters are provided in Response
61-b through 61-1.
Comment 61-b:
Please add this submission to the documents I already submitted in writing (via email) on 3/31/2021
and 4/2/2021. I have seen lots of DEIRs and never seen one so devoid of actual measurable data (on
which conclusions are supposed to be drawn). This DEIR instead relies on conjecture and vague
statements like "no significant issue". That is NOT acceptable...and the City Council is NOT doing its
job if it does not toss this document back to Meriweather and its obviously -biased consultant MSA.
PLEASE TAKE THIS PROJECT AND CITIZENS' CONCERNS SERIOUSLY. In this document, I will address 3
of my primary concerns (though I'm concerned about many others, too).
Response 61-b:
The commenter's opinion on the information and analysis in the Draft EIR are noted.
The Draft EIR includes analyses based on technical studies prepared by technical experts and attached
as appendices to the Draft EIR. The methodologies used for the technical reports are based on
applicable local, regional and state methodologies and satisfy CEQA criteria for determining
significance thresholds (CEQA Guidelines Appendix G). The information in the EIR constitutes
substantial evidence, as defined in Section 15384 of the CEQA Guidelines, supporting the conclusions
in the Draft EIR regarding the significance of the impacts of the project.
Comment 61-c:
LIGHT POLLUTION
For the developers to casually claim that their 80 -foot light towers will have "directional" lights
pointed towards the water is totally insufficient. A study needs to be conducted with actual water
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and a backdrop of a rock -wall mountain (like Coral Mountain) to determine how much deflected light
will bounce off the water and the mountains...and from how far away the light towers, their bulbs,
their direct and diffused light, and their poles will be visible. Our home is deep within Andalusia and
we can see the entire face of Coral Mountain from our backyard. Those light towers and their bulbs
will be visible. That is NOT acceptable and not properly addressed in the DEIR.
What about other lights throughout the development? There are walking paths, outdoor
dining/entertainment areas, bike paths, homes, a hotel, a restaurant, etc. planned for this project. All
will have outdoor lighting that has to be measured and evaluated.
Response 61-c:
Please see the Light and Glare Topical Response in Section 2.2.1 of this Chapter, which describes the
lighting demonstration conducted on November 17, 2021. As described, the light poles and light
fixtures would emit light levels at or below 0.01 -foot candles (which represents an imperceptible light
level) at 120 feet behind or next to each light pole.
Lights throughout the development are also analyzed in discussion d. of Section 4.1, Aesthetics, of
the Draft EIR. Within this section, discussion of lights associated with the various uses are analyzed
(pages 4.1-60 to 4.1-70). This section demonstrates that outdoor lighting in the project low density
residential, open space recreation, and neighborhood commercial planning areas would comply with
the standards in La Quinta Municipal Code Section 9.100.150. This Code requires all exterior lighting
to be fully or partially shielded. Fully shielded means "the fixture shall be shielded in such a manner
that light rays emitted by the fixture, either directly from the lamp or indirectly from the fixture, are
projected below a horizontal plane running through the lowest point on the fixture where light is
emitted, thus preventing the emission of light above the horizontal." Partially shielded means "the
fixture is shielded in such a manner that the bottom edge of the shield is below the plane centerline
of the light source (lamp), minimizing the emission of light rays above the horizontal." Section
9.100.150 also requires that "[a}II exterior lighting shall be located and directed so as not to emit light
on adjacent properties."
Onsite lighting within PA I, PA II and PA IV will result in lighting levels consistent with those of
surrounding developments, will comply with the requirements of the Municipal Code, and will be less
than significant.
Comment 61-d:
Are there going to be big screens (aka jumbotrons) showing surfers every day the Wave Basin is open
and broadcasting big images of entertainers for their special events? Those light emissions have to be
evaluated.
Response 61-d:
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Large digital display screens (i.e., big screens) are not proposed as part of the project. Digital display
screens may be proposed for use during special events, however, approval of a Temporary Use Permit
(TUP) is required for each special event and as part of the review of any TUP application the City would
review all aspects of the proposed special event, including the use of digital display screens and
include conditions of approval to ensure the special event will not result in any significant effects.
Comment 61-e:
The ability to see surrounding mountains, palm trees, the sky, and stars at night is a HUGE part of
what makes La Quinta the 'gem of the desert'. This is a very serious issue and MUST be carefully
studied in the DEIR and EIR process, NOT just surmised by Meriweather and MSA (or whoever else
they hire to issue 'expert' opinions). DEIRs and EIRs are not supposed to be based on opinions...but
on measurable facts. Please do your job and demand this be done properly!
Response 61-e:
Please consult Section 4.1, Aesthetics, for a full analysis of the proposed project's impact on
aesthetics.
Section 4.1, Aesthetics, of the Draft EIR analyzed the project's impacts on surrounding scenic vistas
when viewed from public viewpoints. With the exhibits generated in Section 4.1 of the Draft EIR, it
was determined that from the public viewpoints, many of the project components, including the
proposed hotel and Wave Basin, would not be visible from public rights -of -ways. Please consult pages
4.1-22 through 4.1-28 for analysis of the proposed project on the various scenic vistas, as well as
Exhibits 4.1-4 through 4.1-13 for a line -of -sight analysis and visual simulations from various
viewpoints. Contrary to the assertion that the conclusions regarding aesthetic impacts were
"surmised," they were based on detailed line -of -sight analyses that evaluate the distance, viewing
angle and intervening obstructions to determine whether and to what extent the project features will
be visible from 5 different viewing locations surrounding the project site. This analysis is illustrated
in 5 line -of -site exhibits (see Exhibits 4.1-4, 4.1-6, 4.1-8, 4.1-10, and 4.1-12). In addition, visual
simulations were prepared from the same five locations to demonstrate what will be visible from the
five locations at project buildout and to compare those views to what exists today (see Exhibits 4.1-
5, 4.1-7, 4.1-9, 4.1-11, and 4.1-13). As shown in these exhibits, the proposed Wave Basin light poles
and hotel will not be readily visible from any of the 5 viewing locations due to distance, elevation
changes, and intervening vegetation and perimeter features of the project. However, it was
determined that the proposed project would result in significant and unavoidable impacts to currently
available public views of Coral Mountain due to the change from undeveloped desert land to a
developed community with perimeter walls, landscaping and homes that will partially obstruct
existing views of Coral Mountain and the Santa Rosa Mountains from some locations (see Draft EIR
pages 4.1-44 and 4.1-45).
Comment 611:
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We also believe the developer is far too cavalier with regard to NOISE concerns. It is really laughable
that the developer points to noise studies that were conducted at Lemoore. As La Quinta resident
Kathy Weiss said during the 3/30/2021 Zoom meeting, "that's apples and oranges". First of all,
Lemoore is surrounded by flat agricultural fields and no residential developments. They apparently
intend to build this Wave Basin right up against Coral Mountain. Noises created in that basin will echo
off the rock face and reverberate far and wide!!! And what about the grinding sound of the train -like
rail system that moves back and forth or the hydrafoils that help create the waves? All of this needs
to be carefully measured and evaluated for this particular site!!
And what about the tower where the Public Announcer sits and from where he/she broadcasts
upcoming waves, musical choices, safety warnings, etc.? It will be a public announcement system with
loud speakers!
And what about the jet ski(s)? used to run surfers back to the beginning of the wave experience? A
"Travel & Leisure" article says the basin will accommodate 25 surfers at a time...so there will have to
be multiple jet skis routinely ferrying surfers back & forth. And there will likely be other jet ski -type
devices in the water to rescue people who are injured and to take photographs of the surfers (since
everyone will, no doubt, want a visual memory of their experience...and which will likely be another
way for the developers to make money). The DEIR needs to include measurements of the PA and jet
ski noise...at this particular location.
Response 61-f:
The commenter's opinion is noted. With respect to the noise concerns regarding the Wave Basin,
including all sources of noise (wave machine, public announcement system, jet ski, etc.), please see
the Topical Response on Noise in Section 2.2.4 and Responses 52-h and 59-e.
Comment 61-g:
In addition, this project is in DIRECT OPPOSITION to the City of La Quinta's current Noise Ordinances.
The City limits construction hours from 6:00 a.m. to 7:00 p.m. Monday thru Friday and 8:00 a.m. to
5:00 p.m. Saturday, and prohibits construction noise entirely on Sunday and Holidays. This means that
this Wavepark/Surfamusement Park project will VIOLATE the current Noise policies from day one!!
To exist as currently planned... it has to be considered a 'Special Event'... and not just for the four
times a year they claim they will request... but for every day they operate. Please be serious about
this! What they are proposing is to operate a noisy Amusement feature 7 days a week, from 7:00 a.m.
to 10:00 p.m... in total violation of the City's current regulations. This is another reason why
Meriweather's requested zoning change from residential to commercial should definitely NOT be
allowed!
Response 61-g:
Please see Responses 60-b and 60-c.
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Comment 61-h:
UTILITY OVERLOAD
Will the project's need for huge amounts of continuous power affect the cost, availability and/or
dependability of electricity, water, gas, Internet and WiFi in surrounding neighborhoods? Will the
current IID facility on Avenue 58 have to be expanded? As local residents, we regularly receive
requests from IID to "restrict usage" and get news about "rolling outages", which occur regularly
throughout the summer. This project is likely to put huge amounts of additional stress and draw on
our current grid. THIS NEEDS TO BE CAREFULLY MEASURED...which is another reason to REJECT THE
CURRENT DEIR and deny the zoning change request.
Response 61-h:
The project's energy demands and IID's capacity to meet those demands are fully analyzed in Section
4.5, Energy Resources, and 4.15, Utilities and Service Systems, in the Draft EIR, which concluded that
the project would not have any significant impacts. With respect to the expansion of the IID facility
on Avenue 58, the project will be required to install an additional transformer bank at the existing
substation and install underground conduit and line extensions in the existing right -of way in Avenue
58 as described on page 3-32 and shown on Exhibit 3-14. As evaluated throughout Chapter 4 of the
Draft EIR, these project -related improvements will not cause any significant environmental effects.
Please also see Responses 52-k and 59-b above.
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Comment Letter No. 62: Philip Novak
Date: August 2, 2021
Affiliation: Area Resident
Comment 62-a:
I wish to criticize the defensibility of the DEIR's position that the proposed Wavepark "will not have
any significant noise impacts" (4.11.7).
The DEIR's Noise conclusions (4.11) are based entirely on a Noise study (Appendix K-1) carried out by
Urban Crossroads' William Lawson. Thus my criticisms are directed to Lawson's study. My first
criticisms address two points in his study of traffic noise. They are relatively minor points but, if valid,
deserve to be amended in the final EIR. My third and last criticism is major. It calls into serious
question the validity of his study of the Wavepark's projected operational noise.
Response 62-a:
This introductory comment is noted. Responses are provided below to specific comments.
Comment 62-b:
Criticism 1: An apparent contradiction.
The DEIR's contention that the project will not have any significant traffic noise impacts appears to
directly contradict something Lawson's Noise Study says on p.1 of its own Executive Summary. Here
is Lawson's statement, verbatim:
Based on the significance criteria in outlined in Section 4, the Project -related noise level increases are
considered potentially significant [emphasis Novak's] under Existing with Project conditions at the
following two roadway segments:
• Madison Street north of Avenue 58 (Segment 8)
• Avenue 60 west of Madison Street (Segment 27)
Response 62-b:
The citation relates to a description of a hypothetical condition where all project traffic is added to
the existing roadways under current conditions, without taking into account actual future traffic
conditions or roadway and other planned improvements that will be in place. Section 7.2, Existing
Conditions Project Traffic Noise Level Increase, of the Noise Study (page 51) explains that "an analysis
of existing traffic noise levels plus traffic noise generated by the proposed project has been included
in this [Noise] report for informational purposes. However, the analysis of existing traffic noise levels
plus traffic noise generated by the proposed project scenario will not actually occur since the project
would not be fully constructed (Phase 1, 2 & 3) and operational until year 2026 cumulative
conditions." The Noise Study continues to state "this scenario is provided solely for analytical
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purposes and will not occur, since the project will not be fully developed (Phase 1, 2 & 3) and occupied
under Existing 2019 conditions. Therefore, no mitigation measures are considered to reduce the
Existing with Project condition traffic noise level increases, and impacts are considered less than
significant since they will not actually occur." In other words, this comment in the executive summary
is describing an artificial and hypothetical condition that will not actually occur.
Comment 62-c:
Criticism 2: A baffling, and to me, incomprehensible paragraph in Lawson's Executive Summary.
Immediately following the passage just quoted above Lawson states:
All other roadway segments are shown to experience less than significant noise level impacts under
Existing plus Project conditions. However, this scenario is provided solely for analytical purposes and
will not occur, since the Project will not be full [sic] developed (Phase 1, 2 & 3) and occupied under
Existing 2019 conditions. Therefore, no mitigation measures are considered to reduce the Existing
with Project condition traffic noise level increases, and impacts are considered less than significant
since they will not actually occur. The analysis shows that the unmitigated Project -related traffic noise
level increases under all traffic scenarios will be less than significant. [emphases Novak's].
• "First, what is it exactly that Lawson is referring to in line 2 as 'this scenario'? How extensive
is this supposedly non -occurring scenario?"
• "Second, he says that the 'scenario,' whatever that is, will not occur. What exactly will not
occur?"
• "Third, in the paragraph's second underlined phrase Lawson tells us again that something 'will
not occur,' but also that this non -occurring something will carry a measurable level of
significance (i.e., 'none'). How can something non-existent be measured?"
• "Fourth, in the last sentence Lawson's use of the word 'analysis' seems an overstatement.
suggest it would be far more accurate to describe his activity here as a thought experiment or
a theoretical consideration."
Response 62-c:
In response to the first, second, and third bullet points in this comment- "this scenario" is referring to
the potentially significant impacts that were determined to occur at Segments 8 and 27 under a purely
hypothetical condition where traffic at full buildout of the project is added to the existing (2019)
conditions. This is fully addressed in Response 62-b above.
The commenter's opinion in the fourth bullet point in this comment is noted.
Comment 62-d:
Criticism 3:
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Lawson's crucial assumption in studying the La Quinta Wavepark's projected operational noise —
namely, that his audio recording of the Lemoore Surf Ranch's actual operational noise during a 53 -
minute period on April 13, 2020 is a fully adequate proxy of what the La Quinta Wavepark's
operational noise (15 hours per day, most days of the years) will be — is breathtakingly flimsy. He
never argues for this assumption, for example, by providing an appropriately comprehensive account
of all the relevant topographical (and many other) differences and similarities between Lemoore and
La Quinta. He just assumes, and implicitly asks his readers to assume along with him, that Lemoore
operational noise is a fully adequate stand-in for what the La Quinta operational noise is expected to
be! Given the depth of local La Quintan concern over the project's potential for noise pollution,
Lawson's highly questionable root assumption translates into unacceptably weak grounds for his
opinions about levels of noise. For the LQCC to uncritically embrace Lawson's highly dubious report
about operational noise and thus to overrule La Quintans' noise concerns would be tantamount to a
dereliction of duty.
Response 62-d:
Concerns regarding the accuracy of comparing noise measurements of the Kelly Slater Surf Ranch in
Lemoore to the proposed project were introduced by the public during the project's scoping meeting
on March 30, 2021. For context, the area surrounding the Kelly Slater Surf Ranch in Lemoore is
characterized by agricultural fields, whereas the proposed project is located on the desert floor and
adjacent to Coral Mountain. The public expressed concerns that sound propagation and attenuation
would vary between the different land types. Urban Crossroads provided a Noise Memo, dated April
20, 2020, to address this concern (included as Appendix K.2 in the Draft EIR). The Noise Memo states
that agricultural fields and desert floors are considered soft surfaces for the purposes of sound
propagation. Only hard surfaces, such as pavement, would change the sound attenuation
characteristics of the project. In addition, the worst-case reference noise level conditions were taken
during peak wave noise events at 12 feet, as stated above, whereas Coral Mountain is located
approximately 650 feet from the Wave Basin. The reference noise level measurements themselves
do not include any sound attenuation for the agricultural fields. Please see the Noise Topical
Response in Section 2.2.4, which describes both the noise sources studied at the Lemoore facility, and
how those noise sources were applied to the project site. As it relates to the noise measurement
timing (53 minutes) and operation of the project. The assumptions and analysis in the Draft EIR were
correctly undertaken, and the conclusions accurately described.
Comment 62-e:
Further elaboration of Criticism 3. As Lawson begins his report on operational noise he makes
reference to the existence of sensitive noise receivers in La Quinta (ten on-site, ten nearby off-site)
that he used in his study of La Quinta traffic noise. Under the new heading, 'Operational Noise
Impacts,' he writes:
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"This section analyzes the potential stationary -source operational noise impacts at the nearby
receiver locations, identified in Section 9, resulting from operation of the proposed Coral Mountain
Specific Plan Project."
What is Lawson talking about here? We all know that no sensitive noise receiver in La Quinta ever
recorded any Wavepark operational noise in La Quinta, for the simple reason that there is currently
no Wavepark operation in La Quinta to make any noise.
Response 62-e:
Noise sensitive receivers are uses that may be sensitive to increased noise levels, including homes
located in proximity to the project (page 69 of Noise Study). These noise sensitive receivers primarily
included the residential areas and communities surrounding the project site. Urban Crossroads placed
noise measuring equipment at these locations, as described on pages 4.11-23 and 4.11-24. Based on
the measurements taken at these locations, Urban Crossroads was able to model the potential noise
level increases as a result of project construction and operation. Urban Crossroads was then able to
determine whether the increase in noise would result in significant impacts.
Comment 62-f:
In any case, Lawson soon discontinues references to La Quinta receiver locations and, to his credit,
points us to the real source of his operational noise data. He discloses it, mind you, not in his main
text, Appendix K-1, but in his own Appendix to that Appendix, namely Appendix 10.1. (Does this
qualify as burying crucial information in fine print?) Appendix 10.1 is entitled 'Reference Noise Levels,'
a studiously vague but ill -disguised name for 'Lemoore Noise Levels.' Lawson finally spells out what
his all-important 'reference noise levels' for operational noise are: measurements of the Wave
Machine noise (for 53 minutes on April 13, 2020, time -of -day not disclosed) at the 'existing Surf Ranch
located at 18556 Jackson Avenue in the City of Lemoore, California.'
Lawson tells us that the total noise he is out to measure at Lemoore and then "project" onto La Quinta
is the sum of the Lemoore Wave machine noises plus all other site noises, characterizing the latter
only as "outdoor pool/spa activity, outdoor activity, and neighborhood commercial land use activity."
Neither here nor anywhere else in Lawson's study could I find any indication that he included
measurements of the noise of 4 jet skis and a loudspeaker (15 hours per day, most days of the year)
among his "other site noises." If Lawson really did omit measuring these noises in trying to project
what the La Quinta Wavepark would sound like, his current conclusions suffer a truly fatal blow and
should not be accepted into the final EIR.
Response 62-f:
Contrary to the comment's assertion, the noise study describes the assumptions for Operational
Noise Impacts on page 73. In this section, Urban Crossroads analyzes the potential stationary -source
using reference noise levels from uses similar to what the project proposes. Appendix 10.1 of the
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Noise Study is referenced in this section. As it relates to the measurements of operational noise levels
at the Wave Basin, pages 4.11-44 and 4.11-45 of the Draft EIR contain a thorough description of how
the measurements were taken of all noise sources at the Wave Basin, including the public
announcement system. In addition, further noise readings in Lemoore were taken on August 15,
2021, to ensure that the measurements were taken with surfers on the waves and with the rescue jet
ski operating, and to evaluate the current wave machine cable roller system that is planned for the
project. As explained in Appendix K.3 of this Final EIR, the noise readings in August showed a slight
decrease in peak noise levels from 75.7 dBA to 73.5 dBA, 12 feet from the wave machine activity.
Please also see the Noise Topical Response at Section 2.2.4 and Responses 52-h and 59-e.
Comment 62-g:
Finally, a minor point, but perhaps important in its own way. Lawson tells us that in order to
logarithmically combine all simultaneous Lemoore noises into a sum total, he plugged his Lemoore
recordings into a Noise Analysis computer program. Has anyone on the LQCC critically inquired into
the scientific standing of this program, whether it has been peerreviewed and deemed reliable,
whether it's been adequately field-tested, or whether this was perhaps the program's maiden
voyage? Can we trust its output on such a crucial issue? I ask because of something I thought I heard
G. Simon say at the LQCC meeting of July 20, 2021, namely that Lawson's computer program is the
brainchild of his retired rocket -scientist (and presumably tech -hobbyist) dad. This wouldn't mean it
can't be a great program but isn't some extra due diligence required here?
Response 62-g:
Section 10.2 of the Noise Study (Appendix K.1) provides a thorough description of the CadnaA
computer noise modeling program used for the operational noise analysis and how that program
complies with the applicable ISO 9613 protocols. This is a reliable, industry -standard three-
dimensional noise modeling program used extensively in the industry to accurately predict noise
levels taking into account the site-specific topography, buildings and other noise barriers, among
other factors.
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Comment Letter No. 63: Sandra Stratton
Date: August 2, 2021
Affiliation: Area Resident
Comment 63-a:
1.2.1 Proposed Project
"Meanwhile, the project area west of Madison Street, is the subject of the General Plan Amendment,
Zone Change, new Specific Plan, Tentative Tract Map, Site Development Permit, and Development
Agreement proposed for the project and discussed in greater detail below."
There are six major changes proposed [referring to the proposed entitlements]. Why did this project
make it this far through planning and the City Council? Where is the explanation of when and how
this first proposed to amend the City's General Plan? What was the justification to proceed further?
Response 63-a:
The proposed entitlements are discussed in Chapter 3.0, Project Description, and Section 4.11, Land
Use and Planning. Project History is included on page 2-2, Chapter 2.0, Introduction, of the Draft EIR.
City Staff have received and processed applications filed by the property owner as required under La
Quinta's Municipal Code and State law. Also see Responses 15-d and 17-a as they relate to the review
process for the project.
Comment 63-b:
The city council should provide its residents with a written and public justification of its intent, so
there can be no misunderstanding of facts, history and responsibilities. In addition the city should
certify that THEY PERSONALLY have studied this report and responses from residents.
Response 63-b:
The City Council has received the Draft EIR, will receive the Final EIR, will hold a public hearing to
consider the EIR and the project entitlement applications, will deliberate in public, and will make its
decisions during this public hearing.
The City Council will consider the project in full compliance with CEQA. Section 15090 of the CEQA
Guidelines requires that, should it wish to approve the project, the City Council must certify the Final
EIR. Specifically, the City Council is required to certify that the Final EIR has been completed in
compliance with CEQA; that the Final EIR was presented to the City Council, and that the City Council
reviewed and considered the information contained in the Final EIR prior to approving the project;
and that the final EIR reflects the City's independent judgment and analysis.
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Section 15091 of the CEQA Guidelines, Findings, requires that the City Council adopt written findings
for each significant environmental effect identified in the Final EIR. If the project will result in any
unavoidable significant effects, approval of a Statement of Overriding Considerations is required by
Section 15093 of the CEQA Guidelines to identify the specific reasons supporting approval of the
project action based on the Final EIR and/or other information in the record.
Comment 63-c:
"Existing residential communities occur to the north, south, and east. Avenue 58 and residential
properties define the project's northern boundary; Madison Street and the Andalusia community
define the eastern boundary; Coral Mountain defines the property's southwestern boundary; and
vacant land and residential properties define the southern and western boundaries."
The residential properties mentioned are not only Andalusia, but Trilogy to the Southeast, PGA West
Weiskopf to the Northeast, The Quarry to the West, Santerra to the North, Coral Mountain Estates to
the North. These existing communities house a significant population and conform to the current LQ
General Plan. All of the residents of these communities along with the single family residential on
Avenue 60 should have been advised by mail in 2019 of their opportunity to comment at that time.
Response 63-c:
Regarding public notice of the project and the environmental review process, the City has fully
complied with all applicable legal requirements including sending the Notice of Preparation of the EIR
(NOP) to the Office of Planning and Research and all responsible and trustee agencies, and filed a
copy of the NOP with the Riverside County Clerk, in February 2021, as required by State CEQA
Guidelines (2021) Section 15082, and advertised in the Desert Sun on February 17, 2021. To facilitate
early public involvement in the environmental review process the City also published notice of the
NOP in the Desert Sun newspaper, posted a copy of the NOP on its website. Additionally, the City
advertised a Notice of Availability (NOA) of the Draft EIR in the Desert Sun Newspaper in June 2021,
and posted the NOA on its website and sent notice to NOP commenters, and all parties who requested
notice, as required by CEQA Guidelines Section 15087. The effectiveness of the City's efforts to
facilitate early and full public participation in the CEQA process is further evidenced by the numerous
emails and other correspondence received in response to the March 2021 NOP, and well as the
approximately 80 comments received from the public on the Draft EIR.
Comment 63-d:
"Development Agreement (DA 2021-0002) would vest the applicant's right to develop the Coral
Mountain Resort Specific Plan area pursuant to the entitlements described above, address short-term
rentals within all planning areas of the project, ensure that the project has a net positive fiscal impact
on the City despite the lack of property tax revenue to the City through 2035, and ensure the timely
completion of infrastructure to serve the project and surrounding area, and ensure that the project
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design features and mitigation measures identified in this EIR are enforceable by the City as project
requirements. "
STVR's will increase the traffic, noise and population. The City will not receive tax revenue through
2035! While approving STVR's which are being curtailed in the rest of the City, this is insane that it
would be allowed with NO TAX REVENUE! What exactly is a "net positive fiscal impact" without
revenue? This needs further explanation.
Response 63-d:
The commenter's opinion regarding STVRs is noted. The reference to the City not receiving tax
revenue through 2035 refers to property taxes, that will go to the County until 2035 to pay for
redevelopment bonds issued by the County prior to City annexation of this area. TOT and sales tax
revenue from the proposed project provide a way for development of this property to have a net
positive impact on the City's finances instead if a negative financial impact as would occur if the site
is developed under its existing entitlements. Please refer to Response 52-g for further information
regarding the proposed STVRs.
Comment 63-e:
"Zone Change (ZC 2019-0004) will revise the existing zoning from Neighborhood Commercial, Low
Density Residential, and Golf Course, to Neighborhood Commercial (CN), Low Density Residential (RL),
Parks and Recreation (PR), and Tourist Commercial (CT)."
La Quinta Zoning Code Section 9.240.010 states the following required findings shall be made by the
City Council prior to approval of any specific plan or specific plan amendment:
1. Consistency with the General Plan — IT IS NOT
2. Public Welfare — The noise, traffic, light pollution is detrimental to the general welfare. "Significant
and Unavoidable" as shown on EIR
3. Land Use Compatibility— IT IS NOT compatible with surrounding low density adjacent communities.
4. Property Sustainability — The existing specific plan for this property is sustainable. It is unknown if
a Wave Basin will survive. All of Kelly Slater's recent Surf Ranch proposals have not come to fruition.
He has not exhibited that his business model will survive, much less open. Why should the City of LQ
be the test case? What will happen to a dry, abandoned wave pool community?
PR and CT zoning is completely inconsistent with the neighborhood. This is nothing more than a
glorified amusement park.
Response 63-e:
The commenter's opinions are noted. This comment asserts that the project is not consistent with
the General Plan but does not provide and data or evidence to support this assertion. Please see
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Section 4.10, Land Use and Planning, of the Draft EIR for analysis of the consistency of the project
with the General Plan goals and policies and land use compatibility. Contrary to statement 2 above,
the potential noise, traffic and light impacts of the project were found to be less than significant with
incorporation of all identified mitigation measures. This is summarized in the Topical Responses for
these topics in Sections 2.2.4, 2.2.5, and 2.2.1, respectively, and addressed in detail in Chapters 4.11
(noise), 4.13 (traffic), and 4.1 (aesthetics) in the Draft EIR. Project sustainability features are analyzed
in Chapters 4.2 (air quality), 4.5 (energy), 4.7 (GHG emissions), and 4.12 (public services). Ultimately,
the decision to approve the requested zone change is a policy decision to be made by the City Council,
who will be required to make the findings specified in Zoning Code Section 9.240.010 if it decides to
approve the zone change. Please see Responses 15-d and 17-a for more information regarding this
process.
Comment 63-f:
"The Coral Mountain Resort Specific Plan (SP 2020-0002) will establish a new master plan governing
the allowable land uses, design guidelines, and development standards to allow creation of a
boutique resort and master -planned community. The Specific Plan includes four Planning Areas which
are coterminous to the General Plan and Zoning designation boundaries described above."
This is anything but a BOUTIQUE RESORT AND MASTER -PLANNED COMMUNITY! It is not private. It
cannot be private and generate enough attendance to justify the cost of this wave pool. It is clearly
open to the public who reserve a room at the hotel or rent one or two days at the STVRs. Master
planned communities do not invite 2,500 people to attend events, four times a year.
Response 63-f:
The commenter's opinions are noted. The project will be gated and private, with the exception of the
neighborhood commercial project at the northeast corner of Avenue 58 and Madison Street, as
described on pages 3-13 — 3-23 of the Draft EIR. The residential, tourist commercial, and open space
uses proposed for the project would only be accessible to the residents and guests of the resort.
Gated entry is required for these uses. Public access to these areas will be prohibited.
Comment 63-g:
"Planning Area I (PA I) — Neighborhood Commercial is located on 7.7 acres at the southwest corner of
Avenue 58 and Madison Street, and allows for the construction of 60,000 square feet of publicly
accessible neighborhood commercial building space with affiliated circulation and infrastructure
improvements."
The opposite corner of Avenue 58 and Madison has been available for commercial development for
the 11 years I have lived in Trilogy. For most of that time it was posted with a sign to attract
commercial tenants. Nothing was ever developed. Meriwether must also find commercial tenants in
order to build commercial space. It seems unlikely.
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Response 63-g:
The commenter's opinions regarding the marketability of the property are noted.
Comment 63-h:
"PA IIIG — Back of House: The Back of House subarea contains approximately 26.5 acres that will be
graded as level, largely open land south of the Wave Basin. This subarea will provide unprogrammed
gathering and staging space for temporary equipment such as port -a -potties, shade structures,
tenting for inclement weather, and catering equipment that might be used during events."
This area will cause significant traffic on Avenue 60. Andalusia and Trilogy have spent and continue
to spend significant funds to landscape and maintain the beauty of this street between our
communities.
Response 63-h:
The commenter's opinion is noted. As shown in Exhibit 4.13-2, approximately 25% of the project's
external trips are anticipated to use the secondary access on Avenue 60, and as shown on Table 4.13-
23, the intersection of Avenue 60 and Madison Street will operate at level of service B at full buildout
with an all -way stop sign traffic control. The same is true during special events (see Table 4.13-27).
As explained in Chapter 4.13 of the Draft EIR, and summarized in the Topical Response on Traffic in
Section 2.2.5, the project will not have any significant traffic impacts with implementation of the
required mitigation measures.
Comment 63-i:
It will be a direct conduit for trucks hauling everything for these events. That is unacceptable. The
developer is directed to map out a route for all of the construction traffic. Given that Trilogy has not
been considered in any evaluation, the route will likely go along 60th from Monroe to the site.
Response 63-i:
The commenter's opinion is noted. With respect to construction traffic, Mitigation Measure TRA -8
requires City review and approval of a Construction Traffic Control Plan to avoid traffic impacts and
protect public safety. Although the construction route and access point have not been selected yet,
it is anticipated that a temporary construction access will be established on Madison Street, not
Avenue 60, to minimize impacts the existing residents on Avenue 60. With respect to special events,
which require City approval of a Temporary Use Permit (TUP), Mitigation Measure TRA -10 requires a
special event traffic and parking plan to be submitted with the TUP application for each proposed
special event to ensure that special events will not cause any significant traffic or parking impacts. If
the analysis does not demonstrate acceptable operations, the TUP will be denied. Mitigation
Measures TRA -11 through TRA -14 identified in the Draft EIR will also reduce impacts of traffic related
to special events to less than significant levels. TRA -11 requires Traffic Management Plans to be
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submitted to the City and Police Department for review and approval prior to special events. TRA -12
through TRA -14 require traffic control, which typically include special event flaggers, law enforcement
personnel, online or transmitted event information (suggested routes, parking, etc.) and portable
changeable message signs (CMS) located at critical locations identified by the La Quinta Police
Department. TRA -12 through TRA -14 will be include in TUP conditions of approval for each
occurrence. Please see pages 4.13-42 to 4.13-47 of the Draft EIR for full discussion and analysis. The
Draft EIR correctly and thoroughly analyzed the potential impacts to Avenue 60.
Comment 63-j:
"PA IIIB —The Wave: The Wave subarea contains approximately 31.2 acres containing an artificial surf
Wave Basin and associated infrastructure.
PA IIIC— Wave Club: The Wave Club subarea contains approximately 3.2 acres fronting the Wave Basin
and will function as a private clubhouse with amenities for exclusive use by the Coral Mountain
community."
"1.4 Areas of Controversy; the potential for a significant change in the visual character of the area
from a single -story residential and golf environment to a hotel and Wave Basin facility; and the
potential impacts of proposed 80 -foot light standards surrounding the Wave Basin on the night sky,
light and glare. Visual simulations, line -of -sight analyses and photometric analyses were conducted
for the project.
4.1 AESTHETICS
Table 1-3 Summary of Environmental Impacts and Mitigation states the level of Significance and
Mitigation clearly is "Significant and Unavoidable".
Page 136 of 738 includes the line of sight analysis.
LINE OF SIGHT SECTION 'E' FROM AVENUE 60
The viewpoint does not include views from Trilogy. It was taken west of the intersection of 60th and
Madison at street level. Many houses along 60th (Barrel Cactus Rd) are elevated above 60th.
Detail "A" Wave Basin/Light. The line of sight on Exhibit 4.1-12 shows that the tops of the 80 foot light
poles will be above the line of sight from street level. That does not take into consideration any of the
homes in Trilogy which are higher in elevation.
Response 63-j:
The location for the Line of Sight Section E was selected to show the potential view impacts from
Avenue 60 near the existing residences, which is a view shared by portions of Trilogy from a greater
distance. As shown on Exhibit 4.1-12 and 4.1-13, the direct line of sight toward the Wave Basin and
hotel from that viewing location is partially obstructed by existing landscaping and the proposed
project perimeter wall. The distance from the viewing location to the nearest light pole is 1,274 feet.
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The distance to the nearest portions of Trilogy is substantially further. Accordingly, while the
increased elevation of Trilogy may allow the upper portions of the light poles to be in the line of sight
from Trilogy, the distance and intervening trees and other vegetation will avoid any significant
impacts to Trilogy residents, consistent with the determinations in Chapter 4.1 of the Draft EIR. Please
also see the Topical Response on light and glare in Section 2.2.1.
Comment 63-k:
To state they will only be on from dusk to 10 pm is absurd! That is not a mitigation. The poles will be
visible 24 hours a day.
I personally live in Trilogy and my backyard on the golf course faces the southwest corner of this
community where the Wave Basin and lights are located. Currently I enjoy every morning and evening
looking directly at Coral Mountain and enjoy the change in colors. No six foot fence is going to cure
Anything. I already can look over the fences surrounding Andalusia. (Photos attached)
Response 63-k:
Mitigation Measure AES -3 (page 4.1-73 of the Draft EIR) regarding the hours of operation associated
with the 80 -foot light poles is required. This Mitigation Measure acts to reduce impacts of light and
glare from the light fixtures, as required by CEQA threshold topic d) in the aesthetics section.
Mitigation Measure AES -3 reduces impacts of light emitted from the 80 -foot poles to less than
significant levels because it is consistent with the La Quinta Municipal Code Section 9.100.150 for
recreational uses of light. Please also see the Topical Response on Light and Glare in Section 2.2.1, as
well as Appendices B.1 and B.2 of this Final EIR, for additional evidence and analysis regarding the
proposed Wave Basin lighting system. As explained and illustrated therein, the lighting system's
directional fixture aiming and light cut-off visors allow the Wave Basin itself to be illuminated with no
light spillage outside of the Wave Basin area.
With respect to the visibility of the light poles in the daytime, please review Exhibits 4.1-12 and 4.1-
13 which show what the view will look like from a location on Avenue 60 that is much closer to the
poles than any portion of Trilogy. Please also see Response 63-j.
As explained on page 4.1-39, of Section 4.1, Aesthetics, in the Draft EIR, "Some light poles may be
visible to the residential estate lots and Avenue 60; however, due to the distance of the fixtures to
adjacent properties and the small mass of the proposed light fixtures, they are not anticipated to
significantly impact the scenic vista." As the properties in Trilogy are substantially further from the
light poles than the viewing location on Avenue 60 this conclusion is also applicable to the Trilogy
properties.
Comment 63-1:
In conclusion the Line of Sight Analysis is inadequate as it does not take into consideration the line of
sight from the northern and western boundaries of Trilogy. The City needs an independent analysis.
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Response 63-1:
The commenter's opinion is noted. As described above, the Draft EIR accurately and thoroughly
analyzed line of sight, and correctly determined that impacts from some locations would be significant
and unavoidable.
Comment 63-m:
"Coral Mountain Coral Mountain partially lies within the southwest corner of the project property.
Coral Mountain extends over 400 feet above sea level and provides a scenic resource for the
surrounding area. The Mountain is currently viewed without significant obstructions from the public
roadways, Avenue 58 to the north, and Madison Street to the east."
This section of the EIR gives no consideration to views from Trilogy. We have over 1200 homes many
of which have excellent views of Coral Mountain. To give our community no consideration is
irresponsible. Views from the streets alone is not a thorough analysis. A drive-by view from the street
is inadequate. Many views are from homes on the golf course inside the community.
The citizens of Trilogy deserve adequate consideration and an accurate analysis of the views and
noise.
Response 63-m:
As explained in Responses 63-j and 63-k above, the line of sight and visual simulations from location
E (Exhibits 4.1-12 and 4.1-13 adequately address views of the Wave Basin light poles from properties
in the Trilogy property. Please also see Response 61-e.
Comment 63-n:
4.11 Noise
The sounds from the waves, wave riding vehicles which accompany the surfers, competition
broadcasts/music and the public cheering will all be very disturbing. Viewing platforms on top of the
hotel will be visible and add to the light pollution. The sounds will bounce off Coral Mountain. I can
hear a car drive along 60th, stop at the Madison corner, turn right and continue to a stop at 58th. You
cannot tell me that the sounds created by all of the traffic and venue will not be noise pollution.
Response 63- n:
Please see the Topical Response on Noise in Section 2.2.4 and Responses 52-h, 59-e, and 62-f above,
which explain how the operational noise analysis was completed and show why the project will not
have any significant noise impacts on the surrounding communities.
Comment 63-o:
LAND USE
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• Land use compatibility throughout the City. A WAVE BASIN IS NOT COMPATIBLE.
• Changes and variations from the Zoning Ordinance in a Specific Plan will be offset by high quality
design, amenities and mix of land uses. A WAVE BASIN AMUSEMENT AND STVR'S DOES NOTJUSTIFY
THE CHANGE.
• A broad range of housing types and choices for all residents of the City. THE RANGE OF HOUSING
TYPES DOES NOT BENEFIT THE RESIDENTS OF THE CITY. A FEW HIGH PRICED LOTS FOR SFR'S—THERE
ARE PLENTY ALREADY IN LA QUINTA.
• Consider changes in market demand in residential product type to meet the needs of current and
future residents. THERE IS NO DEMAND FOR A TOURIST RESORT FOR NON-RESIDENTS.
•A balanced and varied economic base which provides a broad range of goods and services to the
City's residents and the region. A SMALL COMMERCIAL DEVELOPMENT AT THE CORNER OF 58 AND
MADISON DOES NOT SATISFY THIS POLICY.
• Maintain commercial development standards in the Zoning Ordinance including setbacks, height,
pad elevations and other design and performance standards that assure a high quality of
development. 17-80 FOOT LIGHT POLES CREATE LIGHT POLLUTION AND ARE NOT CONSISTENT
WITH THE ZONING ORDINANCE.
• Support and encourage the expansion of the resort industry as a key component of the City's
economic base. SILVERROCK RESORT HAS BEEN IN PLANNING AND CONSTRUCTION FOR MANY
YEARS AND IS SUFFICIENT TO SATISFY "EXPANSION".
LIVABLE COMMUNITY
A community that provides the best possible quality of life for all its residents. THIS DEVELOPMENT
WILL NEGATIVELY IMPACT SEVERAL COMMUNITIES WITH THOUSANDS OF RESIDENTS.
ECONOMIC DEVELOPMENT
The Land Use Element shall maintain a balance of land use designations to address economic needs,
meet market demand, and assure a wide range of development opportunities. WHERE IS THE MARKET
DEMAND FOR A WAVE BASIN FOR SURFERS IN THE DESERT.
The continued growth of the tourism and resort industries in the City. THIS IS THE WRONG LOCATION
FOR A PUBLIC RESORT.
HOUSING
Provide housing opportunities that meet the diverse needs of the City's existing and projected
population. Identify adequate sites to accommodate a range of product types, densities, and prices
to address the housing needs of all household types, lifestyles, and income levels. Conserve and
improve the quality of existing La Quinta neighborhoods and individual properties. MILLION DOLLAR
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LOTS FOR SFR'S ARE READILY AVAILABLE IN LQ. STVR'S ARE ALREADY OPPOSED BY THE CITY. THERE
IS NO LOW INCOME HOUSING PROPOSED.
Response 63-o:
The commenter's opinions regarding the project's consistency with General Plan policies are noted.
Please see Responses 41c, 52-f, and 83-w through 83-hh for a further explanation of project's
consistency with these General Plan policies.
Comment 63-p:
WATER RESOURCES
The project promotes water conservation through the use of drought tolerant plant materials and
water efficient irrigation techniques. The project will comply with all City and Coachella Valley Water
District (CVWD) regulations and building code s for water conservation. Additionally, recycled water
will be used for common area irrigation for landscaping. The Wave Basin provides a recreational
amenity to support the proposed resort and residential uses, and does so with substantially less water
demand than required for alternatives amenities, such as an 18 -hole golf course.
DROUGHT TOLERANT PLANTS AND IRRIGATION ARE ALREADY USED ALL OVER LA QUINTA. THIS IS
NOT A MOTIVATION TO APPROVE THIS PROJECT. RECYCLED WATER FOR IRRIGATION vs THE FRESH
WATER TO FILL A WAVE BASIN IS NOT A JUSTIFICATION. MOST GOLF COURSES ALREADY USE
RECLAIMED WATER NOT FRESH WATER.
One cannot ignore the daily headlines from e -news, TV reports, newspapers and magazine articles
declaring a state -of -emergency with the reservoirs servicing the western states all reporting historic
lower than normal levels. Drought monitoring maps show most of Riverside County is in the severe
drought category but is edging closer to the extreme drought classification which is thought to be
inevitable. Whether this summer or next spring, a full state drought declaration could be ordered and
restrictions enacted.
Response 63-p:
Please see the Topical Response on Water Resources at Section 2.2.3 which provides a thorough
description of the area's current water status, and CVWD's water planning and conservation strategy.
Comment 63-q:
How will wave pools or lagoons operate then? How will these Wave Basins and oasis lagoons be
replenished factoring in the enormous daily evaporation rates and the heavy winds inherent in our
valley? Answer: by drawing ever more potable water from the aquifers of course. Just last year in
2020, the entire Coachella Valley endured 140 confirmed days of 100 degree plus temperatures.
Additionally, IID has recently published warnings that rolling brownouts for this summer are likely to
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occur which will affect homes, businesses, and wave pools/lagoons equally. However, downtime for
surf parks and lagoons is lost revenue.
"In order to assure that everyone in the region has sufficient water, it is important that La Quinta, as
one of the stewards of the local water supply, manages and conserves this important resource"
(quote from Water Resources III -57).
"The City's goals, policies and programs relating to water resource management are important to the
District's continued ability to provide domestic water to new and existing developments in the City
and the Sphere of Influence". (quote from Water Resources III -57).
"Continued growth in the City and the region has resulted in an increased demand for domestic water.
As a result, CVWD extracts more water from the Lower Thermal sub -area than is naturally recharged
into it every year — a condition known as overdraft. "(quote from Water Resources III -58)."
An "effective manner to reduce overdraft in the aquifer is through water conservation. The City and
CVWD have implemented a number of conservation programs in recent years which have reduced
consumption of domestic water. It is critical that these programs continue and expand, as possible,
through build out of the General Plan". (quote from Water Resources III -60 Just because a deemed
water usage may have been acceptable in the past, it does not mean that responsible changes need
not be made going forward as new environmentally challenging conditions might dictate.
It's unacceptable that the residents of La Quinta be required to conserve water with respect to their
personal use (which we would willingly comply with in the interest of being good citizens and
stewards of our water resources), while a commercial venture such as this wave/surf park continues
to draw extraordinarily on our aquifers and power supply for an essentially private recreational outlet.
The developer has repeatedly stated that the Coral Mountain Project will use less water than a golf
course. It is common knowledge that golf courses, both existing and new, have many water
conservation options and measures available, wave pools and lagoons have no such alternatives.
Wave Pools must use clean, fresh drinking water from the two sub -basins servicing our valley. These
sub -basins rely on replenishment from the Colorado River but La Quinta cannot count on that source
for our aquifers anymore, especially in a historic drought.
Response 63-q:
Please see Topical Response, 2.2.3, Water Resources in Section 2.2 of this Chapter which describes
CVWD groundwater basin management efforts and its success in increasing existing storage in the
Indio subbasin over the past decade and its plans to continue doing so for the next 25 years through
a combination of conservation and efficiency measures, source substitution, and replenishment
efforts. Based on CVWD's detailed studies and analysis, it concluded that it has sufficient water
supplies to serve the project and all other existing and planned future growth. Please also see
Responses 19-b and 49-b regarding the availability and use of recycled water in the project area.
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Comment 63-r:
Why was there no noise receiver location in Trilogy? Trilogy is closer to the Wave Basin than those
residents on 58th.
Response 63-r:
The Noise Study analyzed sensitive receiver locations on Avenue 60 at properties closer to the project
than Trilogy. These properties would experience a greater noise level (both existing and future) than
a location at Trilogy because noise levels decrease by 6 dBA with each doubling of distance from the
source (see, e.g., Draft EIR pages 4.1-11 and 4.1-25). Sensitive Receptor location R8 in the noise study
is located at the nearest residence to the project on Avenue 60 (see p. 4.11-23 and Exhibit 4.11-2),
and at this location, project operations will have a noise level of 47.0 dBA (see Table 4.11-25). When
combined with ambient noise levels, this location will have a noise level of 48.7 dBA, which is
substantially below the City's threshold of significance of 65 dBA (see Table 4.11-26).
At Trilogy, which is more than twice as far from the Wave Basin as the R8 location, project generated
noise would decrease by at least 6 dBA to 41.0 dBA, which is lower than the current ambient noise
levels at all of the 10 sensitive receptor locations studied around the project site. In other words, at
Trilogy, the current ambient noise level (from traffic, landscaping, etc.) likely already exceeds the
maximum noise it could receive from project operations, and therefore, Trilogy residents are not
likely to be able to hear any noise generated by project operations.
Comment 63-s:
In conclusion I firmly believe that the draft EIR is slighted heavily in favor of the developer and has
not considered the residents of Trilogy who are closer to the Wave Basin are and associated structures
than any of the communities on 58th. The city council should provide its residents with a written and
public justification of its intent, so there can be no misunderstanding of facts, history and
responsibilities. In addition the city council should certify that THEY PERSONALLY have studied this
report and responses from residents.
Unlike many politicians who vote without reading a word of a bill, I trust that our City Council will do
its duty and study the draft EIR and all responses from the citizens of La Quinta before voting.
Response 63-s:
The commenter's opinion on the Draft EIR is noted. Please also see Response 63-b regarding the
requested written explanation of any decisions the City Council makes on the project applications.
Comment 63-t:
In this comment, Stratton provides two pictures taken from her home.
Response 63-t:
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Receipt of the photos is acknowledged, and their content considered in the formulation of Responses
63-j through 63-m, above.
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Comment Letter No. 64: Terje Berger
Date: August 3, 2021
Affiliation: Area Resident
Comment 64-a:
La Quinta don't have a lot of recreation space left. It is this space and south of La Quinta Cove.
Response 64-a:
This comment is noted. Please note that the project site is privately owned property, and as discussed
in Section 2.2, Project History in the Draft EIR, it has been part of an approved specific plan and zoned
for private development for more than 20 years. Accordingly, the project site is not public recreational
space now and it is not planned or approved to serve as public recreation space.
Comment 64-b:
California suffers from a severe drought which get worse for every year. It doesn't sound well to put
a water park in.
Response 64-b:
Please see Topical Response, 2.2.3, Water Resources in Section 2.2 of this Chapter.
Comment 64-c:
If the contractor wants land for a water park, there is plenty over by Classic Club and the new sports
arena that is planned.
Response 64-c:
The commenter's opinion is noted.
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Comment Letter No. 65: Alena Callimanis
Date: August 3, 2021
Affiliation: Area Resident
Comment 65-a:
I am so sorry this is late. I hope I can still present during the public comments section today in the City
Council Meeting. I would also like to get the Council at some point a copy of the presentation. Should
I bring copies with me?
Thank you for your help.
P.S. I did this without a video I wanted. I was slammed at work and did not have enough time this
morning to embed it. Lucky you!!!
Response 65-a:
This comment is noted.
Comment 65-b:
Coral Mountain Surf Resort The Wrong Location in this Heat.
Response 65-b:
This comment is noted.
Comment 65-c:
WADI Adventure Park in the United Arab Emirates
- Only other surfing park in a desert environment
- Contacted the operations manager at WADI to get insight into the challenges
- 140 -mile pipeline from coast to bring desalinated water at a rate of 1 million gallons a week
for a total use at the park
- 2.8 Million gallon pool, cooled to 85 degrees in the summer
o Pools in the 90s plus hot temperatures create potential for heat stroke. Surfers
acknowledge artificial surf wave riding more strenuous due to amount of time riding
the waves
o Warmer pools can incubate protozoa and viruses (brain -eating amoeba).
o Algae buildup increases significantly in hot water; chlorine requirement increases
makes pool use a skin and nasal -passage irritant
o Coral Mountain basing their chlorine needs on their Lemoore Surf Park
- 40,000 USG added daily to the surf pool from May to November and 10,000 USG from
December to April.
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Response 65-c:
The information provided regarding the United Arab Emirates facility is acknowledged. As it relates
to the temperature of the water, please see Response 42-d. As it relates to protozoa and viruses,
please see Response 77-u. The operation and maintenance of the Wave Basin will comply with State
and County health standards to ensure that people are not exposed to dangerous swimming
conditions. As stated on page 4.8-19 of the Draft EIR, the project will be required to comply with
regulations established by the California Department of Public Health and the Riverside County
Municipal Code. The project will be required to use pool disinfecting and cleaning supplies, and shall
be required to follow the procedures established in the Municipal Code and Chapter 6.95 of the HSC.
These standards are designed to prevent contaminants, including protozoa and viruses, from
surviving in the water. As it relates to daily additions to the wave pool, please see Response 65-d
below. As it relates to chlorine use, the Wave Basin is anticipated to use approximately 216,000
gallons of sodium hypochlorite and 14,440 gallons of sulfuric acid annually, which are both commonly
used chemicals in swimming pools (for maximum accuracy, estimates are based on actual rates at the
wave basin in Lemoore, not usage rates at typical swimming pools). These chemicals will be stored
on site and fed into polyethylene tanks located in a pre-engineered metal building with a 24 -inch -high
containment wall with chemical resistant coating (see page 4.8-18). Please see Appendix M.2 of this
Final EIR for additional information on the treatment and filtration system for the Wave Basin.
Comment 65-d:
Let's look at evaporation numbers
- In the CVWD Water Assessment Coral Mountain surf pool replenishment is listed at 39 million
gallons yearly
o Not based on any knowledge of surf pool requirements. Based on standard factor of
1.2 for moving waters and pan evaporation numbers 2005 when we only had 99 days
over 100 degrees
- The World Surf League, which purchased Kelly Slater wave technology, wrote that on very hot
days, the Lemoore Surf Ranch, the pool lost 250,000 gallons a day. They had 27 days over 100
degrees in 2020, with the hottest temperature last year of only 107 degrees.
- La Quinta had 143 days over 100 degrees in 2020. 250,000 gallons times 143 days equals 36
million gallons lost to evaporation in 143 days.
- We had 56 days over 110 degrees. So how much above 250,000 gallons is the evaporation on
those days? What about the rest of the 222 days of the year? We had 51 days over 90 degrees.
Plus our very windy days adding to evaporation.
- You see very quickly that the 39 million gallons calculated by CVWD is wrong.
Response 65-d:
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As explained in the Water Resources Topical Response in Section 2.2.3 above, CVWD's methodology
for determining the water needed for the proposed Wave Basin accounts for evaporation based on
local climatic conditions and actual size of the site-specific proposed uses. Specifically, the
evaporation and water demand calculations required under CVWD Landscape Ordinance No. 1302.4,
which are consistent with the requirements of Title 23 of the California Code of Regulations, Chapter
7, Section 492.4, require determining a "maximum applied water allowance" (MAWA) for the project.
As set forth on page 22 of the WSA/WSV, the MAWA is calculated by multiplying the specific area's
annual evapotranspiration (here 64.22 inches) times an evapotranspiration adjustment factor (here
the highest adjustment factor of 1.2 was used for a moving water body) times the square feet of area
(815,443 square feet for the Wave Basin area) times 0.62 to convert to gallons, shown as follows:
64.22 x 1.2 x 815,443 x 0.62 = 38,961,606 gallons; or 119.58 acre feet per year.
The comment references an anecdotal evaporation figure estimated by the World Surf League, stating
that on very hot days the Wave Basin in Lemoore lost 250,000 per day. From this World Surf League
estimate, the commenter extrapolates potential evaporation based on comparisons of days in
Lemoore with temperatures over 100 degrees and days in La Quinta with temperatures over 100
degrees. However, these inexact comparisons are not sufficient to calculate total estimated
evaporation rates or water demand for the proposed Wave Basin because they lack critical
information including, most importantly, actual established evaporation rates in Lemoore as
compared to La Quinta. Simply comparing daily high temperatures does not allow for accurate
evaporation calculations.
By way of contrast, CVWD adopts evaporation rates for each of four different climate zones in its
service area which take into account several key factors not considered in the comment above,
including elevation, wind conditions, and shadow conditions (see Appendix C to Landscape Ordinance
1302.4). To ensure accuracy and consistency with California state requirements, CVWD updates its
Landscape Ordinance frequently (most recently in 2019). Accordingly, the water demand calculations
used in the WSA/WSA and Draft EIR are based on local evaporation rates established by CVWD in
compliance with California state mandated requirements and constitute substantial evidence in
support of water demands relied upon in the Draft EIR. These calculations are further validated by
U.S. Department of the Interior, Bureau of Reclamation, calculations of water lost to evaporation in
open water bodies within the CVWD service area (see Reclamation Managing Water in the West,
Estimates of Evapotranspiration and Evaporation Along the Lower Colorado River—September 2010).
As shown in Appendix A, p. A1-37 of that report, CVWD is estimated to have 5,521 acre-feet of open
water evaporation over 886 acres of open water, or approximately 6.23 acre-feet of water per acre.
Using the full Wave Basin footprint of 18.72 acres, this would amount to 116.63 acre-feet of
evaporation annually, which is very close to the calculations described above from CVWD's approved
WSA/WSV for the project (119.58 acre-feet per year).
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Going back to the anecdotal evaporation information supplied in the comment, even assuming,
hypothetically, that the evaporation rates stated in this comment are accurate and could be used to
calculate higher total evaporation rates than determined by CVWD (or the Bureau of Reclamation),
such an increase in evaporation would not materially change the project's effect on available water
supplies. As noted above, the project's total 958.63 AFY constitutes only 0.49 percent of CVWD's
projected growth in water demand. The commenter has provided no evidence that increased
evaporation assumptions for the Wave Basin would materially affect CVWD's conclusions.
Accordingly, the project will not have any significant adverse effects relating to water use because
CVWD has confirmed that it has adequate water to serve the project and all other current and future
uses, even under extended drought conditions, and because the project will not interfere with
CVWD's groundwater management plans.
Comment 65-e:
Golf Courses vs Surf Pool
- Please stop believing the developer that the Surf Basin will use 25 % of the water usage of a
golf course.
- Please remember that golf courses can use recycled and grey water; surf pools cannot.
- A local golf course decreased their water usage summer 2020 by 17% no problem.
- Surf park can't decrease their water usage or they close.
- Golf courses have new designs that are environmentally friendly.
- I am not advocating a golf course at the site. Lots of choices for family -friendly amenities.
o Rock wall climbing; Hiking trails; Miniature Golf; Tennis; Bike trails; Community pool;
Playgrounds; Pickleball; etc.
- THIS IS THE TYPE OF FAMILY FRIENDLY RESIDENTIAL DEVELOPMENT LA QUINTA NEEDS
Response 65-e:
The commenter's opinion is noted. Please see the Water Resources Topical Response in Section 2.2.3.
Please also see Responses 19-b and 49-b as it relates to the availability and use of tertiary treated
water in this part of La Quinta.
Comment 65-f:
How can they say no noise impact. (Power Point Slide showing a Channel 3 News still photo was
emailed to City, but no audio or video clip was received).
Response 65-f:
The commenter's opinion is noted.
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Comment Letter No. 66: Wendy Clarke
Date: August 3, 2021
Affiliation: Area Resident
Comment 66-a:
I respectfully request to speak in person during the joint meeting of City Council and the Planning
Commission's public session tomorrow, Aug 3 @ 7 pm. My written presentation is attached for
distribution.
Thank you for your help. Let me know if there is anything else you need. I look forward to meeting
you.
Good afternoon Mayor Evans, Council members, Planning Commission, and staff. Thank you for your
service. Mayor, it is good to see you and other familiar faces. My name is Wendy Clarke; My Family
has lived full-time in the desert for 34 yrs.; 16 years ago, I moved to Trilogy.
Response 66-a:
This comment is noted. Responses to specific comments are provided below.
Comment 66-b:
I am here to speak to the Coral Mountain Wave rezoning request.
Exempt from pass-through property tax $$ due to the agreement with The Thermal Redevelopment
Project, this undeveloped land provides little revenue. I trust, you, the current city council, might have
negotiated something different. If rezoned, LQ gains TOT and South LQ residents' quality of life is
permanently, negatively impacted.
John Gamlin, project president, recently shared that he has managed S.LQ, luxury, low-density
residential neighborhoods. The CMWR will not be similar in any way with a massive artificial surf
wave, stadium lighting, broadcast system, music, and STVRenters.
Response 66-b:
The commenter's opinions are noted.
Comment 66-c:
Beyond the 4 proposed annual events, additional temporary -use permits are likely. Kelly Slater has
made public his support of artificial surf waves for the Ultimate Surfer, for Olympic training and
competition. LA is the 2028 Summer Olympic host. What will one special event look like? Chaos for
1,000s of residents. Our neighborhoods are not transient or a tourist destination. We intentionally
purchased homes away from the commercial corridor. We relax after a busy workday, exercise, retire,
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enjoy nature, socialize. When we drive down Madison nearing home, there is a sense of calm. We
deserve protection of this paradise.
Response 66-c:
The commenter's views are noted. The proposed specific plan would limit the number of special
events to no more that 4 per year, with a maximum attendance of 2,500 persons. Any request for
more than that number would require an amendment to the Specific Plan (if approved) and further
environmental review, both of which would require Planning Commission review and City Council
approval at public hearings.
Comment 66-d:
Today, we are environmentally mindful and face a life-threatening drought:
lakes reaching historic lows. Supplying 80% of the world, California's almonds are no longer being
planted due to water shortages. We have been asked to reduce water consumption by 15%. Any
governing body approving any project that uses a significant amount of water, is irresponsible.
This Surf Wave will deplete drinking water from our Colorado River supplied Aquifer. NPR reports,
"The Colorado River is tapped out. Extremely dry conditions like the region is experiencing in 2021,
make clear that the Colorado River is unable to meet all the demands communities in the Western
U.S. have placed on it, and it's up to its biggest users to decide who has to rely on it less".
What are our mutual responsibilities?
Everyone reduces water consumption
CVWD transitions remaining golf courses to grey water and denies all nonessential, requests
requiring water sourced from the Colorado River.
The city supports independent studies that evaluate local evaporation rates, actual site noise, and
traffic studies post pandemic.
Response 66-d:
Please see the Water Resources Topical Response in Section 2.2.3 for information on CVWD's
groundwater management plan, including projections for long-term water demand and supplies
under drought conditions. As the comment relates to noise and traffic, please see the Topical
Responses for these issues in Section 2.2.4 and 2.2.5, respectively, for information on the noise and
traffic studies completed for this project and the Draft EIR conclusions that the project will not have
any significant environmental effects in these topic areas.
Comment 66-e:
The city observes its General Plan 2035 "Livable community" that speaks to "long-term quality of life
of its [the City's] residents".
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Response 66-e:
The commenter's views are noted.
Comment 66-f:
It is great to think big; change is inevitable. Meriwether has spent millions, aligning with Kelly Slater
and Michael Schwab. It does not justify their project. Please honor S. La Quinta's established
communities and reject The Wave, rezoning request. It will have permanent, quality -of -life
consequences for many 1000's of residents.
Response 66-f:
The commenter's opinion is noted. Please see Responses 15-d and 17-a as they relate to the
requested zone change and procedures for review.
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Comment Letter No. 67: Diane Rebryna (City Council Meeting)
Date: August 3, 2021
Affiliation: Area Resident
Comment 67-a:
Further to my email of earlier today, please find the written version of our comments to be presented
in the Open Session in front of City Council attached.
We wish these to be part of the public record.
Thank you again for your assistance with this; again, please feel free to reach out with any questions
or comments.
Response 67-a:
This comment is noted. The previous email referenced in this comment is included in Comment 67-b.
Comment 67-b:
My name is Diane Rebryna
My husband's name is Anast Demitt.
We reside at [removed for privacy], La Quinta CA 92253
Our phone number is [removed for privacy].
We wish to address City Council during the open session re the Coral Mountain Resort - Diane would
like to speak first using her 3 minutes, and to correlate, Anast would like to follow immediately
thereafter with his allotted 3 minutes.
Thank you for accommodating our request.
If there is anything else that you require at this time, please do not hesitate to reach out.
Response 67-b:
This comment is noted. The commenter's oral presentation is transcribed in the following comments.
Comment 67-c:
Thank you for allowing me to speak today regarding Coral Mountain Resort, which I will refer to going
forward as "the Project".
My name is Diane Rebryna, and my husband Anast Demitt and I are very blessed to have our winter
home here at Trilogy in La Quinta. Please know that we truly love this city, particularly its tranquil and
beautiful southeast corner, which is why we chose to settle there.
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Response 67-c:
This comment is noted.
Comment 67-d:
At the outset, I wish to say that we've spent an inordinate amount of time reviewing the Draft EIR —
which at over 1,500 pages was very challenging and intimidating to the average reader to say the
least. There were so many topics, with this and that 'study' and these and those 'mitigating factors'
that were covered. Some of the DEIR was formulated with conjectures as evidenced by the
statements such as 'are not anticipated to', 'would not significantly impact,' etc. I certainly felt
overwhelmed as I tried to extrapolate all of the potential impacts of this project on life as we know it
in South La Quinta.
Response 67-d:
Please see the Topical Response on the Ability to Comprehend Draft EIR at Section 2.2.7, . The term
"not anticipated to" is commonly used in the preparation of EIRs, and means that, as substantiated
in the text, the subject outcome or effect is not expected to occur. The term "would not significantly
impact" is also commonly used to mean that based on the evidence and analysis discussed in the EIR,
the subject of the sentence (e.g. traffic noise) is not going to exceed the established threshold of
significance for that topic or issue. These terms are used to describe conclusions and evidence -based
projections, rather than conjecture as suggested in the comment.
Comment 67-e:
To help me understand the DEIR, I also reviewed the 2021 CEQA guidelines - a reference document
based on the CA Environmental Quality Act to which is used to develop Environmental Impact
Reports. It was here that I had my "eureka" moment! This document, as part of the DEIR checklist
speaks to a topic called "Mandatory Findings of Significance" where the following is asked: "Does the
Project have environmental effects which will cause substantial adverse effects on human beings,
either directly or indirectly"?
That is when it hit me! - this Project, as a result of the request for REZONING to allow for it definitely
has many known and potentially unknown environmental domino type effects on the 'human beings'
— those being us — the residents of the communities nearby.
Response 67-e:
Identification of project impacts in relation to defined CEQA thresholds of significance for each topic
are provided in each section of the Draft EIR. The findings within the Draft EIR determined whether
impacts for each environmental topic would result in less than significant impacts, less than significant
impacts with the implementation of mitigation measures, or significant and unavoidable impacts in
accordance with CEQA. The Draft EIR correctly identified significant impacts and provided mitigation
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measures where feasible, and where there were no feasible mitigation measures, correctly identified
the impacts as significant and unavoidable. The specific issues of rezoning portions of the property
and whether the project is consistent with the General Plan's goals and policies is addressed in
Section 4.10 of the Draft EIR. Please also see Responses 15-d, 17-a, 41-c, 52-f and 83-w through 83-
hh.
Comment 67-f:
1. First of all, the Developer has asked for Sub - Phase Development based on "market and consumer
demand". I am overwhelmed as I think of how plans for our lives will be totally predicted on the
fact that the waves and phases of construction noise and traffic could go on for years and years.
We may never see the completion of this project in our time here.
Response 67-f:
Similar to many large developments, the proposed project would be developed in several phases. The
Draft EIR correctly analyzed construction impacts over multiple phases in Section 4.11, Noise, and
Section 4-13, Transportation. Mitigation measures for both these issues are included on page 4.11-
54 — 4.11-55 for Noise and pages 4.13-61— 4.13-63 for Transportation.
Comment 67-g:
2. As a result of the rezoning change, Special Events asked for by the Developer could be permitted
through the use of TUPs. What's to prevent the 4 [special events] that are being asked from turning
into 8, or more, per year? City noise ordinance will be altered to accommodate these. There will
definitely be access and egress challenges to most of the surrounding communities—this could impact
our safety and well being, should there be traffic tie ups both during as well as before and after special
events to allow for prep and take down days.
Response 67-g:
As it relates to the number of special events, please see Response 66-d. The proposed project does
not include any changes to the City's noise ordinance. Please see Response 52-n for additional
information on the review and approval of the Temporary Use Permits (TUPs) that will be required
for each of these events and how temporary traffic conditions during these events will be addressed.
Comment 67-h:
3. Finally, I am totally perplexed as to how this Project with its enormous water usage with 18 million
gallons of water to fill it from our aquifers would even be considered in our desert environment with
its high temperatures, high evaporation rate and winds, especially during a mega -drought. I know of
no other "recreational activity' which would even be considered if there was an equivalent current
and potential future threat to the environment as a consequence. There is a global movement under
way to conserve water, with good reason, and we must think of our children and grandchildren.
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Response 67-h:
Please see the Water Resources Topical Response in Section 2.2.3 for information on the water
demand estimate for the project, and CVWD's groundwater management plan, including projections
for long-term water demand and supplies during drought conditions.
Comment 67-i:
New Speaker: Anast Demitt
My name is Anast Demitt and Diane is my wife. Thank you for allowing me to continue on with our
presentation. This topic is of such concern to me that I felt I needed to travel here to speak to Council
today and express my concerns on this proposed Development.
Response 67-i:
This comment is noted. Please see the responses to Comments 67-j through 67-n below.
Comment 67-j:
1. Traffic - Once the Tourist Commercial aspect of Coral Mountain Resort is "up and running" there
will traffic changes that will significantly impact our day to day lives as we know them. The traffic
study included in the DEIR is flawed in my opinion as it was conducted during COVID when many
seasonal residents chose not to return to the valley. The base traffic volumes used in the analysis
are therefore an underestimation of the actual volumes. The study shows that levels of service in
some of the affected areas will be reduced to level F, the lowest possible level of service in traffic
engineering. That means long delays at intersections and increased commute times regulating in
more GHG emissions. The DEIR recommends that changes be implemented to reduce impacts on
the level of service. The developer indicates that they will pay for 'their proportional share'. This
does not seem to be a fair trade off as we the citizens are subsidizing a private development that
we will not see any benefit from.
Response 67-j:
As explained on page 29 of the Traffic Impact Analysis included as Appendix L.1 in the Draft EIR, and
the supplemental memo from Urban Crossroads included as Appendix L.3 in this Final EIR, the traffic
counts were taken on four different days in 2019, prior to the start of the COVID-19 pandemic and
were adjusted for seasonality pursuant to the City's traffic study requirements as set forth in EB #06-
13. These adjusted traffic counts accurately reflect the existing traffic conditions in the project
vicinity.
The Draft EIR, Section 4.13, Transportation, identifies a combination of improvements that will be
required to be constructed by the project developer at the time of project development, as well as
the project's fair -share contribution to other traffic improvements that will be constructed by the City
under its capital improvement plan, which are funded through the project's development impact fee
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and TUMF obligations. The Draft EIR correctly analyzed the impacts, identified required
improvements and their funding sources, and provided mitigation measures (cite by number) to
assure that levels of service at affected intersections would remain at the City's acceptable threshold
of LOS D.—
Comment 67-k:
2. Lighting - The Developer proposes seventeen 80 foot tall light towers and lighting with variances in
parking lots and visitor areas. The effect of this lighting is another unknown that cannot be qualified
at this location. The proposed development will be similar to what I see when I drive by the Indian
Wells Tennis Gardens at night. Furthermore, from the proposed project site, the illumination from a
public park in Coachella is clearly visible in our skies. This project, with its seventeen light towers and
commercial glare, is not the place that I would choose to observe the beautiful dark skies that our
desert is known for. We will say good bye to that here as well.
Response 67-k:
Please see Topical Response, 2.2.1 Lighting of this Chapter for information on the lighting plan
proposed for the Wave Basin. The project does not propose any variances to City standards in parking
lots and visitor areas, which will be subject to the City's zoning requirements set forth in Sections
9.100.150 (outdoor lighting) and 9.150.080 (parking facility light poles limited to 18 feet), and will be
reviewed as individual site development permits are processed. The commenter's opinions regarding
lighting are noted. As it relates to lighting from the park in Coachella, please see the Light and Glare
Topical Response in Section 2.2.1. and Response 51-c above.
Comment 67-1:
3. Short Term Vacation Rentals - One of the biggest concerns that I have relates to the potential
approval of over 700 STVR's for the site, should rezoning occur. Every room in the hotel and casitas
and every house will be approved as an STVR. The proposed $2.5M dollar homes - AND UP - will have
multiple bedrooms with multiple people sharing a house. Add in a full hotel for one of the Special
Events or even for Coachella or Stagecoach, and this development rapidly becomes nothing more
than a large scale B&B with a rotating door. That could mean literally 5 to 6 thousand additional
transient visitors in and out of the Project each day.
Response 67-1:
The commenter's opinion is noted.
As described on page 4.7-9 of the EIR, the project's permanent service population is estimated at
2,672 people, including residents, hotel guests, and employees.. As described on page 3-13 of the EIR,
special events will be limited to 2,500 attendees. Whether these attendees will occupy a hotel room
or residence on the property or come from elsewhere is not known, and as a result, the EIR
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conservatively estimated that these attendees would come from elsewhere, as described on page
4.13-43, Table 3.13-26, Special Event Trip Generation. Please also see Response 52-g concerning
STVRs.
Comment 67-m:
Is this the type of intrusive commercial development that we want 'inserted' amongst the established
communities of the Quarry, Trilogy, PGA West, Andalusia and Senterra, to name a few residential
districts close by?
Response 67-m:
The commenter's opinion is noted.
Comment 67-n:
All for the sake of the TOTS that will be collected on the STVRs? What happened to the highly touted
goals for quality of life in the La Quinta 2035 plan? Is this development and all that it brings along with
it really worth the adverse impact it creates on the residents and citizens of South La Quinta?
I'm respectfully asking you today to please "stick to the plan", that is, the 2035 La Quinta General Plan
- particularly the component that speaks to the 'livable community' which addresses the 'long-term
quality of life of its residents.
This PROJECT is a square peg in a round hole! I encourage you to do as we did and please read the
entire 1500 plus page DEIR. You will see that there is not enough certainty from the information
presented to allow for rezoning with confidence, and to ensure that there will not be long term life
impacting consequences for we, those residents -'those human beings" - who live nearby.
Thank you for allowing us to provide our perspective today to you. Please say no to the rezoning of
this Parcel of land to Tourist Commercial.
Response 67-n:
Please see Responses 15-d and 17-a as they relate to the rezoning of the property and the review
process. Please also see Responses 41-c, 52-f, 83-w through 83-hh, and Section 4.10, Land Use and
Planning, for analysis of the compatibility of the proposed land uses with existing and planned
surrounding land uses and the goals and policies in the City's General Plan.
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Comment Letter No. 68: Dan Stiel
Date: August 3, 2021
Affiliation: Area Resident
Comment 68-a:
As a full-time resident of La Quinta - and as someone who does not surf and has absolutely no ties or
economic interests in this proposed project - I wanted to express my support for the Coral Mountain
Resort, the proposed luxury, private, residential community, including its surfable wave pool.
My support comes from these perspectives - but mostly from making numerous visits to similar
surfable pools across the U.S. I made these visits as a marketing executive on behalf of my employer
to evaluate potential sponsorship participation in events taking place at these surfable wave pools.
My observations from these visits give me confidence in lending my support for the proposed La
Quinta project as one that is consistent with the type of community La Quinta aspires to be — a resort
town that offers an exceptional level of high-quality amenities.
Response 68-a:
The commenter's opinion is noted.
Comment 68-b:
My personal experiences visiting surfable wave pools across Texas and California taught me that these
facilities attract serious athletes and avid surfing enthusiasts of every age and gender who are every
bit as similar to the kinds of people you'll see golfing, playing tennis, or enjoying polo on any given
day across the communities of La Quinta and across the Coachella Valley.
I would consider the atmosphere of these surf parks to be akin to any golf range - participants were
quiet, cerebral, and focused on improving their game — passionate about the sport. I never once saw
rowdy, party, or raucous behavior. I even saw diverse groups of local kids taking surf lessons on
several occasions. A surfable wave pool can only hold a relatively small number of participants at any
given time - not unlike a golf course.
Response 68-b:
The commenter's opinion is noted.
Comment 68-c:
Just like golf, it's not a cheap sport. - for example, at Kelly Slater's Surf Ranch 2021, a day of private
activities and lessons begins at $3,100.00: https://fulcrumsurf.com/shop/surf-ranch/
Response 68-c:
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The commenter's opinion is noted.
Comment 68-d:
La Quinta has an opportunity to continue to diversify its 'quality' outdoor recreational amenities and
appeal for continued economic prosperity and relevancy, including outdoor activities that drive
economic activities during 'off season' periods when it's too hot for traditional La Quinta diversions
such as tennis, golf, even hiking. Surfing is one such high-quality amenity, especially when combined
with the resort itself.
Response 68-d:
The commenter's opinion is noted.
Comment 68-e:
Competitive surfing events are every bit as serious as a polo or golf tournament. Should competitive
events take place, expect the audiences to be as well behaved as those who attend one of the
numerous pro and amateur golf, polo and tennis events in our communities.
Response 68-e:
The commenter's opinion is noted.
Comment 68-f:
I would encourage anyone with serious reservations about to make a visit to a surfable wave park. If
you can't make it, check Kelly Slater's Surf Ranch online: Kelly Slater Wave Company.
Response 68-f:
The commenter's opinion is noted.
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Comment Letter No. 69: Thomas Swope Jr.
Date: August 3, 2021
Affiliation: Resident of Cathedral City
Comment 69-a:
Hello, My name is Thomas Swope Jr, and I live in Cathedral city CA.
I do realize that I am not a La Quinta resident, but I wanted to write to you, or someone and express
my concerns about building a wave park in our desert.
Response 69-a:
The commenter's opinion is noted.
Comment 69-b:
Our desert is always in a constant state of drought, and that situation is most likely never going to
change. We all are dependent on our aquifer for our drinking water, and or other water needs, and I
really think that filling a wave pool with my, and everyone else's DRINKING WATER!! Is a really bad
and stupid idea.
How exactly do you justify asking everyone to conserve as much water as possible, and then you allow
a wave pool to be built that will consume millions of gallons of water to full, and to keep full. 1 honestly
can't believe that this project is being entertained by your city council. The answer should be
elementary to each and every one of you. WE DON'T HAVE THE WATER FOR SUCH A PROJECT, so the
answer should be NO."
Response 69-b:
Please see Topical Response, 2.2.3 Water Resources in Section 2.2 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies during drought conditions.
Comment 69-c:
Please, for every resident's sake in our or valley, do the right thing and DO NOT allow this project to
move forward. It's a form of waste that we all cannot afford.
Thank you for taking the time to read my letter.
Response 69-c:
This comment is noted.
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Comment Letter No. 70: Jan Wm. Talbott
Date: August 3, 2021
Affiliation: Area Resident
Comment 70-a:
As a year -around resident at Trilogy and close to the corner of Madison and 60 were quite concerned
about this project in terms of noise, traffic, night light pollution, water usage, etc. Perhaps even more,
we're worried as to what could happen if this thing goes belly up in a couple years. That would be an
albatross hard to dispose.
Please do not authorize the zoning changes necessary to locate this project in our residential area.
There are many, many available parcels throughout the Valley where such a project would have little
to no negative impact on the residential community.
Response 70-a:
The Draft EIR analyzes project -related impacts to lights, water use, noise, traffic, etc. in compliance
with CEQA Guidelines. These topics are discussed in Section 4.1, Aesthetics, Section 4.9, Hydrology
and Water Quality, Section 4.11, Noise, and 4.13, Transportation, (respectively) in the Draft EIR.
These findings are also summarized in Section 2.2 of this Chapter along with additional information
in Topical Responses 2.2.1, Light and Glare, 2.2.3, Water Resources, 2.2.4 Noise and 2.2.5 Traffic in
response to comments on the analysis of these topics in the Draft EIR.
The comment's concern regarding the feasibility of the project is noted.
With regard to consideration of alternative locations for the project, an alternative location was
discussed in Chapter 7.0, Alternatives, of the Draft EIR: "CEQA Guidelines requires examination of an
alternative location for the project if such locations would result in the avoidance of or lessening of
significant impacts. The project objectives specifically relate to the existing Coral Mountain Resort
property, which is currently undeveloped and vacant. Additionally, the project applicant has not been
able to locate a suitable alternative location of at least 380 acres that is available for purchase and
that would substantially reduce any of the significant impacts of the proposed project." As allowed
under Guidelines Section 15126.6. The alternative site location was not further analyzed.
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Comment Letter No. 71: Kathy Weiss
Date: August 3, 2021
Affiliation: Area Resident
Comment 71-a:
Honorable Mayor Evans, Members of the Council, staff. Thank you for the opportunity to speak on
the Coral Mountain project. My name is Kathy Weiss. I am a homeowner /resident at the Quarry.
#1. Location
Many of you might think the Quarry won't be impacted because the DIR said there was nothing to
The West of the project. For the record, The Quarry is to The West of the proposed Wave Basin at
Coral Mountain.
Response 71-a:
This comment is noted. Although "the Quarry" is not listed by name, the first page of the project
description (page 3-1) states that the project site has a residential community located to the west,
and the Quarry can be readily seen on the project site vicinity map, Exhibit 3.2. The eastern edge of
the Quarry is also identified in the Noise Study as one of the nearby sensitive noise receptor locations
(see page 4.11-23 and Exhibit 4.11-4.11-2).
Comment 71-b:
#2. Noise
Everyone who lives near Coral Mountain knows that sound reverberates throughout this area. I can
hear the murmur of simple conversations between the hikers in Coral Mountain Park, and at Lake
Cahuilla Camper Park. From my home at The Quarry, I can hear the music, the bass beat, and the roar
of the crowds during Coachella and StageCoach. In fact, from inside my home, I can tell you if the
vehicle rumbling down west of 58th & Madison has a gasoline or diesel engine.
Just like my neighbors, I hear the sounds of coyotes and hoot owls every evening.
I ask any sound engineer, that has NOT been hired by the Developer, to demonstrate sound trajectory
to La Quinta Mayor & City Council members. The finding of "no significant" noise impact in the DIR
illustrates what a one-sided publication this is.
Response 71-b:
The commenter's opinions are noted. Please see the Noise Topical Response in Section 2.2.4 of this
Chapter. As acknowledged in that section, the project will generate noise. However, and as also
described in that section, the noise levels will not exceed City standards.
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Comment 71-c:
#3 Side effects of Tourist/Commercial Zoning
Louder noise allowances, longer business hours, overnight stays, special events, bigger and taller
buildings, and public safety commercial lighting are permitted, and sometimes required under
Tourist/Commercial zoning. Here is just one example- the Wave Basin requires an audible (not visual)
30 -second alarm if there is an emergency, followed by another 30 -second audible alarm to signal the
emergency has ended. California State mandated Alarm can be as loud as it needs to be in order to
be heard over "The Tub and The Train," (nickname given to the Wave Basin by Kelly Slater's peers),
the screaming and cheering crowds, the crashing of waves onto concrete flooring, and the jet skis
zipping up and down the Basin. As the Tub is geared for the Novice Surfer Tourist, the alarms could
be going off several times a day. If I had wanted to live in a noisy, tourist/commercial neighborhood,
I certainly wouldn't have built a home at The Quarry.
Response 71-c:
Please see Responses 59-e and 62-f for a thorough discussion of how the Noise Study took into
account all sources of noise at the Wave Basin, including the wave announcements and rescue jet ski,
and see the Topical Response on Noise in Section 2.2. for a summary of the Draft EIR conclusion that
operation of the Wave Basin and other project uses will not cause any significant noise impacts to the
surrounding residential communities. As shown in Table 4.11-25 on page 4.11-48 of the Draft EIR,
the loudest offsite noise level from project operations will be 52.2 dBA at receptor location R6
(approximately 134 feet from the project boundary and directly east of the Wave Basin), whereas the
loudest noise level recorded at the wave basin in Lemoore was 75.7 dBA (see Table 4.11-24 on page
4.11-45 of the Draft EIR). The offsite reading was more than 20 dBA less than at the noise source
(wave machine) because noise levels diminish by approximately 6 dBA with each doubling of distance
from the noise source (see page 4.11-25 of the Draft EIR). The Wave Basin will not be equipped with
an emergency alarm. Public safety is maintained by controlling access to the site and Basin, and surfer
safety is addressed with lifeguards and the rescue jet ski. In addition, under La Quinta Municipal Code
Section 9.100.210, emergency operations are exempt from the City's noise limits in non-residential
zones.
Comment 71-d:
#4 STVR's
As La Quinta City Council and its residents know, STVR's are a big nuisance, not only here in La Quinta,
but elsewhere in Coachella Valley, and wherever people want to Vacation. The vast majority of people
who propose short term vacation rentals do not live in this town. Most are out of towners or
Commercial investors.
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If City Council choses 750 more STVRs over our tranquil South La Quinta Community, you are voting
against your own Community. Are we a community or a Commodity to you?
To remind everyone, the Development Agreement proposes:
"Short term vacation rentals will be an allowable use in all planning areas within the Project".
In "Developer Speak" -That means 100% of the 600 "Dwelling Units" (per the Developer's words) built
on this property can be STVR's. In essence an overnight Hotel Room with a shared kitchen. The
developer states "Dwelling Unit" prices will start at $2.5 million and go to $5 million. That tells me the
Dwelling Units are going to be McMansions w/ 3 to 10 bedrooms each. Add the massive 150 room
key hotel and we have "Surf City Party- land" with (a potential overnight) population of 4-5,000
lodgers at our doorsteps. Simply put, 750 STVR dwellings and 4-5,000 lodgers will be throbbing in the
middle of Andalusia, Trilogy, The Quarry, Santerra, Puerta Azul and PGA West (which has a section on
58th), plus the other resident communities lining 58th Street West of Madison. This Meriwether
project goes against every single zoning statement in the La Quinta General Plan 2035.
The developer, when asked about the noise and light pollution, has been very careful to always reply,
"we don't want the noise to impact our residents." From reading the DIR and the DA, this project is
not catering to have many residents. I want to emphasize the developer plans to build the Wave Basin,
Hotel and Casitas first. After completion in 2-5 years down the road, only then will developer
construct dwelling units on the sold Lots. A "Dwelling Unit "- per the developer's own words, in the
DIR, has an Owner(s), but not necessarily a Resident. A Rental has an "Owner", a Home has a
"Resident." Keep in mind, The "Dwelling Unit" owners that chose to buy and build at Coral Mountain
Wave Park, plus the tourists booking a stay, do so knowing that the "Tub and Train", announcer, jet
skis, crowds, entertainment venues, etc. will be going non-stop 15 hours daily with 1,000's of
tourist/lodgers milling around outside all over the place.
It's easy for the Wave Park lodgers to leave and go back home when tired of the noise, crowds, and
commotion. For the neighboring homeowners, it is not so easy. WE will have to soundproof our lives,
unable to hear the birds, bees and other native wildlife. We will be stuck in a nightmare that never
ends.
The surrounding neighborhood property owners and I bought &/or built homes in South La Quinta
because we wanted a peaceful, low-key residential atmosphere. We enjoy the light traffic, no hustle -
bustle, being outside listening to the sounds of nature. Our homes and daily life will be impacted
negatively in which way.
Before I chose the location of where I live in La Quinta, I asked my realtor what the West Andalusia
parcel was zoned for. The realtor told me "Low -Density Residential w/18 -hole golf course. It is
planned to be Andalusia's higher -end homes with their own golf -course." I did more due diligence by
visiting the Andalusia Sales site, looked at their Master Plan 3-D model and confirmed the zoning with
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the Developer's representative. Finally, after studying the LQ City zoning map, I felt confident to
purchase my lot and commence building a home at The Quarry.
If any of us wanted to live next door to a "Surf City Mega- Event Complex" we would have done so.
The majority of the homeowners in South La Quinta moved here by choice, (as we were not born and
raised in La Quinta.) Permitting this Zone change is slap in the Face to every single person that chose
to live, buy, and/or build in South La Quinta.
LQ City Council would be showing us that we, your South La Quinta residents, just don't matter.
I thought City Governments were designed to protect its residents and their properties, and make its
Residents pleased to be living there.
You can call me naive, because I never thought our local government would cater to an out of state
rookie -developer, that has only been in business for 8 years. For the record- This developer has
already pulled the plug on one La Quinta based, City owned development: SilverRock.
La Quinta Government should stand by their thousands of residents. Not the Out -of -Town developer
that has a dubious history w/ La Quinta.
Response 71-d:
The commenter's opinions are noted. With respect to STVRs, please see Response 52-g. With respect
to noise, please see Response 52-h, 59-e, and 62-f. With respect to lighting, please see the Topical
Response on Light and Glare at Section 2.2.1, and with respect to land use compatibility, please see
Response 41-c and 52-f.
Comment 71-e:
#5. Developer Agreement
For the record, the developer's proposed time frame, as proposed in the DA, is 40 years. That is 4 —
0. F 0 R T Y. I quote this 6- year old article from the Desert Sun dated October 21, 2015, regarding the
SilverRock project. "Robert Green Jr., of Robert Green Co., and John Gamlin, of Sofia Investments, will
keep SilverRock moving forward after Meriwether Co. withdrew to pursue other interests, city
Economist McMillen said." (For the record, this is the same John Gamlin we heard speak on
Meriwether's behalf at the last open City Council Meeting)
In other words, Meriwether, the same developer that dropped Silver Rock to pursue "Other
interests", wants a 40- year time frame in the Development Agreement.
That is alarming. What if Meriwether drops this one too?
Yes, I am well aware that Developers, City, State & Public entities, Planning Business, Consultants,
Realtors, etc. have interacted, networked & fraternized with each other on a daily basis for many,
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many years. In fact, most of LQ City Council members are involved in these types of pursuits. When it
comes to assembling DIRs for City Review, it is definitely a stacked deck in favor of the Developer. The
"no significant impact" stated over and over in the DIR clearly illustrated this bias. LQ Government's
easy acceptance of the more than 1,000 -page DIR cemented the fact. The repetitive "No significant
Effect" would be laughable if the thousand pages+ plus DIR wasn't so blatant in its lack of
transparency, readability, and comprehension.
Having personally met and known many Developers, a good, responsible, and successful Developer
looks to invest and "develop" where there is a real need, the timing is right, and there is an
overwhelming neighborhood desire for the "Development" to happen. That is certainly not the case
here. All which makes me ask why the Developer and their financial backers bought a parcel that did
not have the desired Zoning already in place for their Project?
Who, in LQ government, gave them the "greenlight"?
Why would La Quinta government even think this is "in character" of the existing neighborhood
zoning?
In summation, I beg of you, Mayor Evans, and La Quinta City Council Members to vote NO on granting
the Property Commercial/Tourist zoning. A zone change permit would be absolute disaster in the
making for the many thousands of residents close to this proposed Tourist/Commercial Mega -
development.
Response 71-e:
The commenter's opinions are noted. Please see Responses 15-d and 17-a as they relate to the zoning
for the property and the review process. Issues raised by the commenter regarding the development
community and the feasibility of the project are not CEQA issues, and do not require response here.
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Comment Letter No. 72: August 3rd City Council Meeting Transcribed Presentations
Date: August 3, 2021
At August 3rd City Council Meeting
Comment 72-a:
La Quinta City Council Meeting August 3, 2021
Public Comment on Matters Not on the Agenda
https://laquinta.l2milesout.com/video/meeting/81158bc2-9a14-47c8-9a20-7c4e88cea5e6
Speakers discussing the Coral Mountain Resort Project and time of appearance in video linked above.
In -Person Comments
Alena Callimanis (Transcribed); 0:45 — 7:35 minutes
Kelly Welton (Transcribed); 7:46 — 9:15 minutes
Wendy Clarke (Transcribed); 9:20 — 14:06 minutes
Diane Rebryna and Anast Demitt (Transcribed); 14:15 — 23:49 minutes
Verbal Comments via Teleconference
Kathy Weiss (Transcribed); 27:35 — 38:45 minutes
Response 72-a:
This comment is noted. The comments in these presentations are responded to below. Where
applicable, the responses refer back to the same comments that were submitted to the City in written
form. For example, Ms. Callimanis submitted her presentation and it is included as Letter 65; Ms.
Clarke's submitted presentation is Letter 66; Ms. Rebryna and Mr. Demitt's submitted comments are
Letter 67; and Ms. Weiss's submitted presentation is Letter 71.
Comment 72-b:
Located at: 0:45 — 7:30 minutes
Speaker: Alena Callimanis
Hello. My name is Alena Callimanis. What should I do about this [indicating mask]?
Mayor: Your choice.
Callimanis: I can? Alright, that way I can make sure you hear me. Okay, they are bringing up my
presentation, and uh. It's only going to be up there? [indicating one screen] Okay. There we go, great.
Uh, so the first thing I want to do, and I'm not saying this to brag, or anything like that, but, I mean, I
do have a bachelor's in physics, I have a masters in physics. So, I take my research in whatever I do
very seriously. So, when I put my name on something, that means I really looked into it and feel 100
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percent confident that I am giving the correct information. So, I wanted to make sure that I covered
that upfront.
Response 72-b:
This comment is noted.
Comment 72-c:
Alright, um. This is the WADI Adventure Park in the U.A.E. It's the only other surfing park in a desert
environment that maps to what we have. And I think I talked about it before. But what I did was, I
contacted the operations manager at that pool so that I could understand the challenges they have
by having a surf pool in the heat like we do. Uh, the first thing of course is that, you know, they had a
140 -mile pipeline from the coast that brings desalinated water to the, um, to them because they don't
have an aquifer where they are. Um, but, one of the things that's really important is that they told
me they cool the pool to 85 degrees for a number of reasons are listed here.
- Pools in the 90s, plus hot temperatures like we're having in the 110s and so on, uh create
potential for heat stroke. And that has happened.
- Warmer pools can incubate Protozoa and viruses. So, this is what they actually told me is that
one of the key reasons they want to cool their water to 85 because they want to keep it safe
for their, um, surfers.
- The other thing I did miss was that surfers acknowledge that by riding on the artificial waves,
they really exerting a lot more energy than regular wave because it goes on for a much longer
extended period of time. So that raises the chance, if you're doing, during the day in a hot
water pool for heat stroke.
- Algae buildup significantly increases in hot water, with hot water and hot weather. So, chlorine
requirement increase the pool, to make it safe away from chlorine away from this protozoas
and everything, um, it just increases to the point where it may be unusable for swimmers in
it. The Coral Mountain base, uh, people, developers base their chlorine needs on Lemoore
Surf Park, and I will in the Draft Environmental Impact Report, and I'll go over that in the next
page real quick.
Response 72-c:
Please see Response 65-c.
Comment 72-d:
When I left the house, my pool was 95 degrees today. So that's really hot. Um, on the next page
[indicating PowerPoint]. Uh, very quickly, the CVWD water assessment said that they would need 39
million gallons yearly to replenish the evaporation from the surf pool. Um, unfortunately that was not
based on any knowledge of surf pools, we didn't have that kind of data. So they did it based on a
standard factor of 1.2 for moving waters and pan evaporation numbers 2005 when we only had 99
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days over 100. So that's that the calculations are based on. However, luckily, the World Surf League,
which purchased Kelly Slater wave technology, that's going to make up our pool here in La Quinta,
wrote that on very hot days, the Lemoore Surf Ranch, the pool lost 250,000 gallons a day. Okay now,
they had — I went through and calculated how many days over 100 they had — they had 27 days over
100 degrees in 2020, with the hottest temperature last year of only 107. We had 143 days over 100.
Um, so I used that as a number from basing my calculations for evaporation. So, 250,000 gallons times
143 days equals 36 million gallons lost to evaporation in 143 days. If you look at line number one,
CVWD has in their water assessment they only need to replenish 39 million for a whole year. I
calculated based on the Kelly Ranch evaporation, 100-uh, 36 million gallons only in 143 days. That
leaves us with — oh we also had 56 days over 110 Degrees. What does that now mean for the 250,000
gallons? How much of a factor is it above that for more evaporation right? We don't know that. uh,
could it be 300,000 dollars on the days over — 300,000 gallons on the days over um, 110 degrees? Uh,
what about the rest of the 222 days of the year where we have evaporation due to wind? Due to
heat? We had 51 days last year over 90. That's another large amount of, of days over it. You'll quickly
see that the 39 million gallons calculation by CVWD is wrong. I hate to say that, but.
Response 72-d:
Please see Response 65-d.
Comment 72-e:
Again, so golf courses versus surf pools. I gave you those numbers so that you see, you stop believing
the developer that a surf basin will use 25 percent of what a golf course will do. These evaporation
figures show that we don't even know how much more it's going to be. Um, and golf courses use
recycled and grey water; surf pools can't. Uh, last year local golf course decrease their water usage
by 17 percent over the summer without a law being in place to say please reduce it. They're able to
do that. You know, you can't — surf park can't decrease their water or they close. Golf courses have
new designs that are environmentally friendly. I'm not advocating another golf course here. I want to
have a family -friendly development here. You could have rock wall climbing, bike trails, hiking trails,
community pools, miniature golf, playgrounds, tennis, pickleball, all that, I think are, in lines of what
you want for residential community.
Response 72-e:
Please consult Response 65-e.
Comment 72-f:
Finally, I just wanted to show you a picture of the conception. Uh, how can they say no noise impact?
Look where that pool is in relation to Coral Mountain. So thank you very much.
Response 72-f:
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Please see the Topical Response on Noise in Section 2.2.4 of this Chapter which addresses the
potential for the proximity of the project to Coral Mountain to affect noise levels.
Comment 72-g:
Located at: 7:46 — 9:15
Speaker: Kelly Welton
Welton: Good afternoon my name is Kelly Welton, I live in Trilogy, and I just wanted to raise some
concerns that we weren't really satisfied by the answers given to us by Merriwether and Garrett
Simon on, I believe the first call that we had.
Response 72-g:
This comment is noted.
Comment 72-h:
One question asked was - what about the noise factor, if they are going to be in operation until 10
o'clock in the evening? If we have noise concerns at 10 o'clock in the evening, who can we call? And
his answer was "oh the hotel staff will take care of that." So, I'm not exactly sure what that meant or
how that will happen, but I would like to then ask — if we don't get any satisfactory problem solving
by the hotel staff for noise 5 pm, when no one is here, who do we call? What is the plan B? Will La
Quinta Police come? Will Riverside County sheriff come?
Response 72-h:
Please see the Topical Response on Noise in Section 2.2.4 of this Chapter which addresses the
potential for the project to result significant noise impacts. The noise analysis determined the project
will not exceed the noise standards established in the City's noise ordinance or have any significant
noise impacts on the surrounding residential communities. For this reason, enforcement actions by
the City in response to noise complaints are not anticipated. Any such complaints would be addressed
by the City in accordance with the City's Municipal Code. For example, LQMC Section 9.100.210 limits
outdoor noise levels to 65 dBA between 7:00 a.m. and 10:00 p.m., and 50 dBA during the nighttime
hours of 10:00 p.m. to 7:00 a.m. at any sensitive receptors, which includes the surrounding residential
communities and future homes within the project. In addition, Sections 11.08.090 and 11.08.040
make it a punishable infraction to disturb the peace by willfully making any unreasonably loud noise.
The City also publishes phone numbers for making noise complaints. Code Compliance receives
complaints at 760-777-7050. In addition, the City has established a STVR hotline for complaints at
760-777-7157.
Comment 72-i:
And my second one kind of tags on Alenas picture, and I didn't know I could send a PowerPoint, but
I'll pass this around so you can see it, but the proposed wave pool that they have in proportion to.
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Mayor: You can start over here, actually with City Clerk.
Welton: If you look at the size of that Wave pool, in proportion to the size of the about 8 blocks of
Trilogy, you can't tell me that whatever contraption they're going to use to make a wave in that pool,
won't be heard. That's a huge pool. It's 8 blocks of Trilogy. Thank you.
Response 72-i:
Please see the Topical Response on Noise in Section 2.2.4 of this Chapter and Section 4.11, Noise, of
the Draft EIR. As described therein, the Draft EIR did not claim that the project would not generate
noise. The Draft EIR did, as demonstrated in Tables 4.11-25 and 4.11-26, show that noise levels would
not exceed City thresholds of significance for residential receptors.
Comment 72-j:
Located at: 9:20 — 14:06
Speaker: Wendy Clarke
Hi Mayor Evans, Council members, Pena, Fitzpatrick, Radi Sanchez and staff. I really appreciate your
service. Good to see everybody. My name is Wendy Clarke, and my Family has lived in the Valley here
for 34 years.; 16 years ago, I moved to Trilogy.
Response 72-j:
Please see Response to this comment at Response 66-a.
Comment 72-k:
And I am here to speak today about the request for Coral Mountain to rezone land adjacent to many
of the communities surrounding where I live. Currently, we all know the land provides little revenue
for the City, basically due to the Thermal Redevelopment Project. And I trust maybe City Council
would have negotiated something different years ago, but it is what it is. And if it's rezoned, the City
realizes Transient Occupancy Taxes, what happens to the residents? Our quality of life is negatively
and permanently impacted.
I had an opportunity to hear John Gamlin on a Zoom call recently and he shared that he's managed
some south La Quinta luxury properties, uh, in residential neighborhoods. This project is in no way
like any of those neighborhoods. With a huge amounts of surf waves, broadcast system, music, short
term rentals.
Response 72-k:
Please see the response to this comment at Response 66-b.
Comment 72-1:
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Beyond the 4 annual events that they propose, there is additional temporary -use permits I believe it
can be requested. Kelly Slater has made public that he supports the artificial surf waves for Olympic
training and competition. LA is hosting the 2028 Olympics. What will one special event look like?
Chaos for 1,000s of residents. Our neighborhoods are not transient, and they are not a tourist
destination. We intentionally purchased homes away from the commercial corridor. And to relax after
a busy workday, some of us have retired, we like to exercise, enjoy nature, socialize with our
neighbors. It's funny when I drive down Madison on the way home from errands, there is a calm that
comes over me. Um, this paradise deserves to be protected.
Response 72-1:
Please see the response to this comment at Response 66-c.
Comment 72-m:
Today, environmentally mindful we face a life-threatening drought, and I won't go into all the details
because we've talked about this a lot, but lakes are at historic lows. California supplies 80% of the
world's almonds, and trees aren't being planted because there is no water. We have been asked to
reduce water by 15%. Any governing body approving any project that uses a significant amount of
water, is irresponsible.
This Surf Wave will deplete water from our aquifer supplied by the Colorado River. NPR reports, "The
Colorado River is tapped out. Extremely dry conditions like the region is experiencing in 2021, make
clear that the Colorado River is unable to meet all the demands the Western U.S. have placed on it.
It's up to its biggest users to decide who has to rely on it less."
In closing, what are our mutual responsibilities?
- Everyone reduces water consumption.
- CVWD transitions remaining golf courses to grey water and denies all nonessential, requests
requiring water sourced from the Colorado River.
- The city requires studies that evaluate local evaporation rates, the actual noise of the site, and
traffic studies that are post pandemic.
Response 72-m:
Please see the response to this comment at Response 66-d.
Comment 72-n:
- The City observes its General Plan 2035 "Livable community" that speaks
quality of life of its residents."
Response 72-n:
Please see the response to this comment at Response 66-e.
to "long- term
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Comment 72-o:
It is great to think big; change is great and inevitable. Having lived in La Quinta is wonderful. It's real
exciting to see young people moving here. Meriwether has spent millions. They've aligning with Kelly
Slater and Michael Schwab. Their project is beyond unreasonable. Please honor south La Quinta's
established communities and reject The Wave, rezoning request. It will have permanent, quality -of -
life consequences for many 1000's of residents.
Thank you.
Response 72-o:
Please see the response to this comment at Response 66-f:
Comment 72-p:
Located at: 14:15 — 23:49
New Speakers: Diane Rebryna and Anast Demitt
Good afternoon Honorable Mayor and City Council Members, staff, and fellow attendees. Thank you
for allowing me to speak today regarding Coral Mountain Resort, which I will refer to going forward
as "the Project". My name is Diane Rebryna, and my husband Anast Demitt and I are truly blessed to
have our winter home here in Trilogy in La Quinta. Please know that we truly love this city, particularly
its tranquil and beautiful southeast corner, which is why we chose to settle there.
Response 72-p:
Please see the response to this comment at Response 67-c.
Comment 72-q:
At the outset, I wish to say that we've spent an enormous amount of time reviewing the Draft
Environmental Impact Report - which at over 1,500 pages was very challenging and intimidating to
the average reader, to say the least. There were so many topics, with this study and that "study" and
these and those "mitigating factors" that were covered. Some of the DEIR was formulated with
conjectures; there were statements like "are not anticipated to", "would not significantly impact",
and I felt overwhelmed as I tried to extrapolate all of the potential impacts of this Project on life as
we know it in South La Quinta.
Response 72-q:
Please see the response to this comment at Response 67-d.
Comment 72-r:
To help me understand the DEIR, I also reviewed the 2021 CEQA guidelines — this is a reference
document that's based on the CA Environmental Quality Act to which is used to develop
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Environmental Impact Reports. And it was here that I had my "eureka" moment! This document, as
part of the DEIR checklist speaks to a topic called "Mandatory Findings of Significance" where the
following is asked: "Does the Project have environmental effects which will cause substantial adverse
effects on human beings, either directly or indirectly"?
That is when it hit me, yes we are the human beings that will be impacted. So this Project, as a result
of the request for rezoning to allow for it, will have many known and potentially unknown
environmental domino type effects on the "human beings" - those being us - the residents of the
communities nearby.
Response 72-r:
Please see the response to this comment at Response 67-e.
Comment 72-s:
1. First of all, the Developer has asked for Sub -Phase Development based on "market and consumer
demand". I am overwhelmed as I think of how plans for our lives will be totally predicated on the
fact that the waves and phases of construction noise and traffic could go on for years and years.
We may never see the completion of this Project in our time here.
Response 72-s:
Please see the response to this comment at Response 67-f.
Comment 72-t:
2. As a result of the rezoning change, Special Events asked for by the Developer could be permitted
through the use of TUPs. What's to prevent the 4 that are being asked for from turning into 8, or
more for the City? City noise ordinances can be altered to accommodate these special events.
There could definitely be access and egress challenges to most of the surrounding communities,
and this could impact our safety and wellbeing, should there be traffic tie ups both during as well
as before and after Special Events to allow for prep and take down days.
Response 72-t:
Please see the response to this comment at Response 67-g.
Comment 72-u:
3. And finally, I am totally perplexed as to how this Project with its enormous water usage with 18
million gallons of water to fill it from our aquifers would even be considered in our desert
environment with its high temperatures, high evaporation rate and winds, and especially during
a mega -drought. I know of no other "recreational activity' which would even be considered if
there was an equivalent current and potential future threat to the environment as a consequence.
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There is a global movement under way to conserve water, with good reason, and we must think
of our children and grandchildren.
Thank you very much.
Response 72-u:
Please see the response to this comment at Response 67-h.
Comment 72-v:
New Speaker: Anast Demitt
Mayor: And Anast Demitt.
Demitt: Mayor Evans, Mayor Pro Tem Radi, Council members, City staff, fellow La Quintans. My name
is Anast Demitt and I am a semi -retired forensic structural engineer. My 45 years of engineering
training has allowed me to learn how to read technical documents. That Draft EIR that I read was one
of the worst technical documents I've ever read. It is not to the point, it is full of conjecture, tends to
cloud the issues, and what's very disappointing - everything has little to no impact. there's no
cumulative analysis as to what happens.
Response 72-v:
This comment is noted. Regarding the length and overall readability of the Draft EIR, the commenter's
opinions are noted. Please see Topical Responses Section 2.2.6 (Length of Draft EIR) and Section 2.2.7
(Ability to Comprehend the Draft EIR).
Comment 72-w:
One of the areas that concerns me on this proposed element is the section of the DEIR related to
traffic.
1. Once the Tourist Commercial aspect of Coral Mountain Resort is "up and running" there will traffic
changes that will significantly impact the day to day lives of many La Quintans and affect their
lives as we know them today. The traffic study included in the DEIR is flawed, because in my
opinion, it was conducted during COVID when many seasonal residents chose not to return to the
Valley. The base traffic volumes used in the analysis are therefore an underestimation of the
actual number of vehicle trips on those roads. The study shows that levels of service in some of
the affected areas will be reduced to level F. Now in engineer speak — A is good level of service
and F is absolutely the worst. As a consequence, that means there will be long delays at
intersections and increased commute times regulating in more GHG emissions, and longer delays
in getting to our homes. The Report recommends that changes be implemented to reduce the
impacts on the level of service. The Report recommends widening the roads, adding signalization
to 8 intersections. When I asked the developer how this is - who is going to bare this cost, their
comment is that they are going to pay "their proportional share". What is their proportionate
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share? I would submit the citizens of La Quinta will be paying a significant portion of these costs.
This does not seem to be a fair trade off as we the citizens are subsidizing a private development
that we will not see any benefit from.
Response 72-w:
Please see the response to this comment at Response 67-j.
Comment 72-x;
2. I would also like to talk about the lighting - The Developer proposes to use seventeen 80 foot tall
light towers with lighting with variances in parking lots and visitor areas. The effect of this lighting
is another unknown that cannot be quantified. The developer had a light study done, and that is
low and behold from the company that sells them lights. Not much of a conflict in my opinion.
The proposed development will be similar to what I see when I drive by the Tennis Gardens in
Indian Wells. Furthermore, from the proposed project site, the illumination from a public park in
Coachella is visible. So even though the light may not directly reflect off the water surface, into
the adjacent communities, the glow above the park will certainly be visible. I think we can kiss our
dark La Quinta skies good-bye, if that is the case.
Response 72-x:
Please see the response to this comment at Response 67-k.
Comment 72-y:
3. And finally, I want to talk about the Short Term Vacation Rentals [STVR]. Potentially we can have
700, over 700 STVRs on that site. The DEIR asks that every room in the hotel, casitas, and every
house will be approved as a STVR. The proposed $2.5M dollar homes will have multiple bedrooms
with multiple people sharing a home. Add in a full hotel for one of the Special Events or even for
Coachella or for Stagecoach, and this development rapidly becomes nothing more than a large
scale B&B with a rotating door. That could mean literally 5 to 6 thousand additional transient
visitors in and out of the project each day.
Response 72-y:
Please see the response to this comment at Response 67-1.
Comment 72-z:
Is this the type of intrusive commercial development that we want inserted among the established
communities of the Quarry, Trilogy, PGA West, Andalusia, Santerra, just to name a few.
Response 72-z:
Please see the response to this comment at Response 67-m.
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Comment 72 -aa:
All for the sake of the TOTs that will be collected on the STVRs? What happened to the highly touted
goals for quality of life in the La Quinta 2035 Plan? Is this development and all that it brings along with
it really worth the adverse impact it creates on the residents and citizens of South La Quinta?
I'm respectfully asking you today to please "stick to the plan", that is, the 2035 Plan - particularly the
component that speaks to the "livable community" which addresses the "long- term quality of life for
its residents."
This project is a square peg in a round hole. I encourage you to do as we did and please read the entire
1,500 plus page DEIR, it cures insomnia. You will see that there is not enough certainty from the
information presented to allow for rezoning with confidence, and to ensure that there will not be
long term life impacting consequences for we, those residents -'those little human beings' - who live
nearby.
Thank you for allowing us to provide our perspective today. Please say no to the rezoning of this
parcel to Tourist Commercial.
Response 72 -aa:
Please see the response to this comment at Response 67-n.
Comment 72 -bb:
Located at: 27:35 — 38:45
New Speaker: Kathy Weiss
Honorable Mayor Evans, Members of the Council, and staff. Thank you for the opportunity to speak
on the Coral Mountain project. My name is Kathy Weiss, and I am a homeowner and resident at the
Quarry.
#1. Location
Many of you might think The Quarry won't be impacted because the DIR said there was nothing to
the West of the project. For the record, The Quarry is to the west of the proposed Wave Basin at Coral
Mountain.
Response 72 -bb:
Please see the response to this comment at Response 71-a.
Comment 72 -cc:
#2. Noise
Everyone who lives near Coral Mountain knows that sound reverberates throughout this area. I can
hear the murmur of simple conversations between the hikers in Coral Mountain Park, and at Lake
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Cahuilla Camper Park. From my home at The Quarry, I can hear the music, the bass beat, and the roar
of the crowds during Coachella and StageCoach. In fact, from inside my home, I can tell you if the
vehicle rumbling down west of 58th & Madison has a gasoline or diesel engine. Just like my neighbors,
I hear the sounds of coyotes and hoot owls every evening. I ask any sound engineer, that has NOT
been hired by the Developer, to demonstrate sound trajectory to La Quinta Mayor & City Council
members. The finding of "no significant" noise impact in the DIR illustrates what a one-sided
publication this is.
Response 72 -cc:
Please see the response to this comment at Response 71-b.
Comment 72-dd:
#3 Side effects of Tourist/Commercial Zoning
Louder noise allowances, longer business hours, overnight stays, special events, bigger and taller
buildings, and public safety commercial lighting are permitted, and sometimes required under Tourist
Commercial zoning. Here is just one example - the Wave Basin requires an audible (not visual) 30 -
second alarm if there is an emergency, followed by another 30 -second audible alarm to signal the
emergency has ended. California State mandated Alarm can be as loud as it needs to be in order to
be heard over "The Tub and The Train," by the way the tub and the train is a nickname given to the
Wave Basin by all of Kelly Slater's peers, the screaming and cheering crowds, the crashing of waves
onto concrete flooring, and the jet skis zipping up and down the Basin. As the Wave Basin is geared
for the Novice Surfer Tourist, the alarms could be going off several times a day. On, off, on, off. If I
had wanted to live in a noisy, tourist commercial neighborhood, I certainly wouldn't have built a home
at The Quarry.
Response 72-dd:
Please see the response to this comment at Response 72-c.
Comment 72-ee:
#4 STVR's
As La Quinta City Council and its residents know, STVR's are a big nuisance, not only here in La Quinta,
but elsewhere in Coachella Valley, and wherever people want to vacation. The vast majority of people
who propose short term rentals do not live in this town. Most are out of towners or Commercial
investors.
If City Council choses 750 more STVRs over our tranquil South La Quinta Community, you are voting
against your own community. Are we a community or a commodity to you? To remind everyone, the
Development Agreement states: "Short term vacation rentals will be an allowable use in all planning
areas within the Project ". In "Developer Speak"- That means 100% of the 600 "Dwelling Units" —
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those are the Developer's words not mine - built on this property can be STVR's. In essence an
overnight Hotel Room with a shared kitchen. The developer states "Dwelling Unit" prices will start at
$2.5 million and go to $5 million. That tells me the Dwelling Units are going to be McMansions with 3
to 10 bedrooms each.
Add the massive 150 room key hotel and we have "Surf City Party -land" with a potential overnight
population of 4- to 6,000 lodgers at our doorsteps coming and going on a daily basis. Simply put, 750
STVR dwellings and 4,000 to 500 lodgers will be throbbing in the middle of Andalusia, Trilogy, The
Quarry, Santerra, Puerta Azul and PGA West (which does have a section on 58th), plus the other
resident communities lining 58th Street West of Madison. This project goes against every single
zoning statement in the La Quinta General Plan for 2035.
The developer, when asked about the noise and light pollution, has been very careful to always reply,
"we don't want the noise to impact our residents." From reading the DIR and the DA, this project is
not catering to have many residents. I want to emphasize the developer plans to build the Wave Basin,
Hotel and Casitas first. After those are completed in 2 to 5 years down the road, then will developer
will start to construct dwelling units on the sold lots. A "Dwelling Unit "- per the developer's own
words again, not mine, in the DIR, has an Owner, but not necessarily a Resident. A Rental has an
"Owner", a Home has a "Residence." There is a big difference between an owner and resident. All the
communities I mentioned to you are residential communities. Now, keep in mind, The "Dwelling Unit"
owners that chose to buy and build at Coral Mountain Wave Park, plus the tourists booking a stay, do
so knowing that the "Tub and Train", the announcer, the jet skis, the crowds, the entertainment
venues, etc. will be going nonstop 15 hours a day, that's why they want to be there. And there will be
all those 4- to 5,000's of tourist/lodgers milling around outside everywhere. The Wave Park lodgers
can leave and go back home when tired of the noise, the crowds, and the commotion. We, the
neighboring homeowners, cannot. We will be stuck in a nightmare that never ends.
The surrounding neighborhood property owners and I bought and/or built homes in South La Quinta
because we wanted the peaceful, low-key residential atmosphere currently there. Before I chose the
location of where I live in La Quinta, I asked my realtor what the West Andalusia parcel was zoned
for. The realtor told me "Low -Density Residential with 18 -hole golf course. It is planned to be
Andalusia's higher -end homes with their own course." I did more due diligence by visiting the
Andalusia Sales site, looked at their Master Plan 3-D model and confirmed the zoning with the
Developer's representative. Finally, after studying the LQ City zoning map, I felt confident enough to
purchase my lot and commence building a home at The Quarry.
If any of us wanted to live next door to a "Surf City Mega -Event Complex" we would have done so,
we didn't. The majority of the homeowners in South La Quinta moved here by choice; meaning that
we were not born and raised here. Permitting this Zone change is slap in the face to every single
person that chose to live, bought, and build in South La Quinta. LQ City Council would be showing us
that we, your South La Quinta residents, just don't matter. I always thought City Governments were
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designed to protect its residents and their properties, and make its residents happy to be living there.
You can call me naive, because I never thought our local government would cater to an out of state
rookie developer, that has only been in business for 8 years. For the record - this developer has
already pulled the plug on one La Quinta based, City owned development: SilverRock. La Quinta
Government should stand by their thousands of residents in south La Quinta. Not the Out -of -Town
rookie developer that has a dubious history with La Quinta.
Response 72-ee:
Please see the response to this comment at Response 71-d.
Comment 72-ff:
#5. Developer Agreement
For the record, the developer's proposed time frame, as written in the DA, is 40 years. That is 40. F.
O. R. T. Y. I quote this account from the Desert Sun — uh, this 6 -year-old account from the Desert Sun
dated October 21, 2015, regarding the SilverRock project. "Robert Green Jr., of Robert Green Co., and
John Gamlin, of Sofia Investments, will keep SilverRock moving forward after Meriwether Co.
withdrew to pursue other interests, city Economist McMillen said." For the record, this is the same
John Gamlin we heard speak on Meriwether's behalf at the last open City Council Meeting. In other
words, Meriwether, the same developer that dropped Silver Rock to pursue "Other interests", wants
a 40- year time frame in the Development Agreement. That is alarming. What if Meriwether decides
to drop this one too? Yes, I am well aware that Developers, City and Public entities, Planning Business,
Consultants, Realtors, etc. have interacted, and networked, and fraternized with each other on a daily
basis for many, many, many years. In fact, most of LQ City Council members are involved in these
types of pursuits. When it comes to assembling DIRs for City Review, it is definitely a stacked deck in
favor of the Developer. The "no significant impact" stated over and over in the DIR clearly illustrated
this bias. The repetitive "No significant effect" would be laughable if the thousand pages plus DIR
wasn't so blatant in its lack of transparency, readability, and comprehension.
Having personally met and known many Developers, a good, responsible, and successful Developer
looks to invest and "develop" where there is a real need, the timing is right, and there is an
overwhelming neighborhood desire for the "Development" to happen. That is certainly not the case
here. All which makes me ask why the Developer and their financial backers bought a parcel that did
not have the desired Zoning already in place for their Project?
Who, in LQ government, gave them the "greenlight"? Why would La Quinta government even think
this is "in character" of the existing neighborhood zoning?
In summation, I beg of you, Mayor Evans, and La Quinta City Council Members to vote "no" on
granting the Property Commercial/Tourist zoning. A zone change permit would be absolute disaster
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in the making for the many thousands of residents close to this proposed Tourist/Commercial
Megadevelopment.
Response 72-ff:
Please see the response to this comment at Response 71-e.
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Comment Letter No. 73: Lisa Jeffery
Date: August 4, 2021
Affiliation: Area Resident
Comment 73-a:
My husband and I moved into The Citrus as permanent (year round) residents in May 2021. As we
were considering moving to La Quinta one of my biggest concerns is the availability of water for the
future. We moved here from the Bay Area and have gone through a few years of severe drought. It is
very scary to have to limit your use of water and a sobering reminder of how precious a resource
water is. We must use it wisely!
Response 73-a:
This comment is noted. Jeffery's concern for water use is addressed in Response 73-b.
Comment 73-b:
I recently learned of Coral Mountain Resort and I'm shocked that this would even be a consideration
here. California is in a drought now and we need to conserve water.
Please don't build a water park!
Response 73-b:
Please see Topical Response, 2.2.3 Water Resources in Section 2.2 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies.
Comment 73-c:
I personally would like to see Silver Rock development finished and eliminate the water features in
the landscape.
La Quinta has beautiful desert landscape. Let's emphasize that.
We must change our attitude toward our natural resources or we won't have a planet to live on.
Response 73-c:
The commenter's opinions are noted. As stated on page 3-11 of the Draft EIR (Chapter 3.0, Project
Description), landscaping must comply with the landscape ordinances adopted by CVWD and the City
of La Quinta to reduce outdoor water use in compliance with State law. The project will utilize native
and drought tolerant plants and landscape features compatible with the existing desert landscape.
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Comment Letter No. 74: Rosette Kivel
Date: August 4, 2021
Affiliation: Area Resident
Comment 74-a:
I am informing you once again to my opposition to the Wave Park. The dire water drought is a major
priority. We will run out of water for our agriculture as well as our personal use.
Response 74-a:
Please see the Water Resources Topical Response in Section 2.2.3 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies.
Comment 74-b:
The other problem is the impact on our tranquility at Trilogy. That would be traffic congestion as well
as noise pollution.
Do not all allow this Water Park to open.
Response 74-b:
As shown in Table 4.13-23 of the Draft EIR, with the project and City capital improvement plan (CIP)
improvements, all intersections in the project vicinity will operate at an acceptable level of service.
Please also see the Topical Response on Traffic in Section 2.2.5 for a summary of the Draft EIR
conclusion that with implementation of Mitigation Measures TRA -1 through TRA -14, the project will
not have any significant adverse traffic impacts. As it relates to noise pollution, please see the Topical
Response on Noise at Section 2.2.2, which explains that although the project will generate increased
noise levels on the project site and at some off-site locations, they will be within the thresholds
determined acceptable by the City for residential receptors.
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Comment Letter No. 75: Natalie Maupin
Date: August 4, 2021
Affiliation: Area Resident (Palm Desert)
Comment 75-a:
I am a resident of Palm Desert and have been watching the news publications about the wave pool
tentatively approved for the Coral Mountain area in La Quinta. I find it ironic that the LA Times
published an article, "As drought worsens, regulators impose unprecedented water restrictions on
California farms" while there are multiple recreational water parks under planning and/or
construction in the Coachella Valley.
I don't understand the logic in using hundreds of thousands of gallons of our precious table water in
a wave pool. This project should be placed on an indefinite hold until water levels are back to where
we are not "robbing Peter to pay Paul". Personally I think our farmers have a right to this water before
we build a wave pool.
I can find multiple articles about farmers who have basically let their farms go because they can't
maintain the crops with the amount of water they are allocated. Not all of these farms are located in
the Coachella Valley, but we are home to a variety of farms that provide food and jobs to our
residents. Can you explain and justify how a recreational venue warrants water over our farmers?
For reference, here is the article from the LA Times.
Response 75-a:
The commenter's opinions are noted. Please see the Water Resources Topical Response in Section
2.2.3 of this Chapter for information on the water demand estimate for the project, and CVWD's
groundwater management plan, including projections for long-term water demand and supplies in
drought conditions.
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Comment Letter No. 76: Liz Ervin
Date: August 5, 2021
Affiliation: Area Resident
Comment 76-a:
I am writing to you as a citizen of La Quinta. I moved to south La Quinta after extensive research
seeking a crime free and quiet neighborhood.
The location for the misguided "surf park" is presently zoned for low-mid density housing, not a
tourist and AIRBNB destination that would be NO benefit for the local community.
Response 76-a:
The commenter's opinion is noted. Please see Responses 15-d and 17-a as they relate to the proposed
Zone Change and processing of the project.
Comment 76-b:
It is inconceivable that this 'surf park' is being considered with the drought conditions. We have been
asked to limit our water consumption and every day on the news this is an important topic. In addition
we often get alerts from IID to reduce or electric consumption.
Response 76-b:
Please see Topical Response, 2.2.3 Water Resources in Section 2.2 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies.
The potential effect of the project on utilities, including IID's system, are analyzed in Section 4.15,
Utilities and Service Systems, in the Draft EIR based on consultation with IID. No significant impacts
on IID's service system were identified. Please also see Responses 52-k and 59-b.
Comment 76-c:
Please do not allow this to happen. It is up to you and would be very disappointed if this were to come
to fruition.
I was on a ZOOM call with the developers recently who addressed the EIR reports that were so biased
and incomplete. The developer was rude and not very interested in listening to the valid concerns of
local experts.
Please do not change the zoning for this property. I read on some of the city council bios that they
were here for the citizens of La Quinta so here is a chance to prove it.
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Response 76-c:
The commenter's opinions are noted.
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Comment Letter No. 77: Diane Rebryna
Date: August 5, 2021
Affiliation: Area Resident
Comment 77-a:
I am writing today as a concerned Trilogy resident to respond to the Draft Environmental Report as
well as to voice my opposition to the rezoning application above which would allow for the Coral
Mountain Resort development ("the Project") in South La Quinta.
PREAMBLE:
The key to the color coding within this response to the DEIR is here:
1. My comments, as the writer, are in BLACK
2. The reader will see comments in RED: These are supportive documentation for that section and are
excerpts from CA Environmental Quality Legislation (w/ writer's emboldening/underlining). This
legislation drives the CEQA Guidelines which in turn provide the framework for the Draft
Environmental Impact Report.
PUBLIC RESOURCES CODE - Public Resources Code
DIVISION 13. ENVIRONMENTAL QUALITY [21000 - 21189.70.10] (Division 13 added by Stats. 1970,
Ch. 1433.)
CHAPTER 1. Policy [21000 - 21006] (Chapter 1 added by Stats. 1970, Ch. 1433.)
3. The reader will see comments in PURPLE: These are excerpts from the 2021 CEQA Guidelines.
https://www.califaep.org/docs CEQA_Handbook_2021.pdf
4. The reader will see comments in BLUE: These are excerpts from the 2035 La Quinta General Plan
("the Plan") (w/ writer's emboldening/underlining)...
https://www.laquintaca.gov/business/design-and-development/planning-division/2035-
laquinta-general-plan
which is the "...plan ...crafted as the guiding policy document for the City per the vision expressed
by its citizens and established by the City Council." I-1...The General Plan includes ..."Goals,
polices, and programs (that) are all supported by factual data, community opinion, background
information, and detailed maps. Together, these constituent parts paint a picture of the
community's future development"
My comments with respect to the DEIR for the Project will be laid out in 3 parts:
A. Those regarding the DRAFT Environmental Impact Report Document
B. Those regarding the Project relevant to the DEIR, and
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C. Conclusion
Response 77-a:
This introductory comment is noted. Responses to the comments in this letter are provided below.
Comment 77-b:
A. My comments regarding the Draft Environmental Impact Report Document for Coral Mountain
Resort - issued June 22, 2021:
Section 21003 of the Legislation addresses the preparation of Environmental Impact Reports.
The Legislature finds and declares that it is a policy of the state that...
...(b) Documents prepared pursuant to this division be organized and written in a manner that will be
meaningful and useful to decision makers and to the public.
...(c) Environmental impact reports omit unnecessary descriptions of projects and emphasize feasible
mitigation measures and feasible alternatives to projects.
My concerns with the DEIR document itself are as follow:
I, and many other concerned residents, are of the opinion that this document was not organized and
written in a manner that was meaningful and useful to the public. Whether it will be useful to the
decision makers remains to be seen.
1. In short, the document is not succinct. The sections in the DEIR with respect to the "technical
studies" contained complex language that would have been better placed in appendices, to
allow for "a flow" in the main document and encourage a "rapid understanding" of the DEIR
by the average reader as required by the CEQA guidelines.
2. I have strong objections to the multiple vague statements that appear throughout the DEIR
(regarding identified factors)..." are not anticipated to", "would not significantly impact","
would not substantially change", "would not be significant" , "minimally impacted", "would
be imperceptible", "are not fully compliant", etc. These are SUBJECTIVE comments that are
not scientific and neutral. As a reader, comments like this do not inspire my confidence in the
findings.
Response 77-b:
In response to item 1, please refer to the Topical Response on the Ability to Comprehend the Draft
EIR in Section 2.2.7 of this Chapter. The Draft EIR has was written to disclose all of the project
components and technical methodologies utilized in order to comply with CEQA standards. The
environmental topics required to be addressed by CEQA, as well as the significance threshold criteria
established by CEQA require technical reports and supporting documentation in order to fully analyze
and conclude whether project impacts would result in less than significant, less than significant with
mitigation, or significant and unavoidable impacts.
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In response to item 2, please see Response 67-d for an explanation of how terms like those quoted in
this comment are frequently used in Environmental Impact Reports to describe conclusions and
evidence -based projections. Nevertheless the commenter's opinions on the use of these terms are
noted.
Comment 77-c:
3. I also have concerns with "elaborate and ornate descriptive language" used in what should be
presented as a neutral "for information" document. Often times such language was used to
describe the project.
For example, on page 7-57 of the DEIR, the following statement is made: "Develop a high-
quality private Wave Basin (The Wave) that provides unique recreational opportunities for
future residents of the project, and that attracts resort guests and creates a landmark facility
that will enhance the City's reputation as the "Gem of the Desert".
Only PLAIN SIMPLE LANGUAGE should be allowed, regardless of the context. Language like
this belongs in a promotional brochure for the project - not in a DEIR. I compared other DEIRs
for other projects in the Coachella Valley and could not see examples of this type of language
in the others.
Response 77-c:
This comment references the objectives of the project. Pursuant to the State CEQA Guidelines,
Section 15124(b), the description of the project must include a statement of objectives for the Coral
Mountain Resort project, including the underlying purpose of the project and its benefits, which can
be used by the decision makers to help identify and evaluate a reasonable range of alternatives. Here,
the project objective referenced addresses one of the primary purposes of the project, which is to
develop the Wave Basin to serve as the central recreational amenity to support a residential and
resort community by attracting resort guests and residents to the community. The language is
appropriate in the context provided.
Comment 77-d:
4. Many of the tables were redundant and confusing in their layout; they should have been placed
in the appendices for easy reference, and not allowed to clutter the document.
Response 77-d:
The commenter's opinion is noted. Please also see Topical Response in Section 2.2.7, Ability to
Comprehend the EIR.
Comment 77-e:
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5. At 1500 plus pages including appendices, the document was too long as per the CEQA guidelines
(300 pages is recommended for a complex project), and filled with redundant and repetitive
sections that were repeatedly "cut and pasted" throughout the entire document. In fact,
entire sections were literally repeated several times throughout the document.
Response 77-e:
Please see the Topical Response in Section 2.2.6, Length of Draft EIR, of this Chapter.
Comment 77-f:
6. Then document did not include an organized and detailed Table of Contents to allow for easy
reference by the reader and some of the numbering on the pages was not in sequence. There
were too many sections entitled "Conclusion(s)" throughout the document, contributing to
further confusion for the average reader. There were page numbering errors in some sections;
some intended citations were not cited.
Response 77-f:
Please see Responses 34-c, 34-d and 34-g.
Comment 77-g:
I would like it on record that I, and others, communicated the above concerns to the Consulting
Planner, and her response on July 13, 2021 was the following:
"Although the CEQA Guidelines suggest page limits, the complexity of this project requires that it be
analyzed thoroughly, resulting in a longer document. The language in the document, although
technical, is not unduly scientific or complex. CEQA documents usually are highly detailed and cover
many variables. Likewise, the various environmental impact areas may have some redundancy of
analysis, all in an effort to make the document as complete as possible. The City has completed the
EIR to address all currently known aspects of the project, and to provide decision makers and the
public with a comprehensive analysis of the potential direct, indirect and cumulative impacts
associated with its implementation. The City will not be retracting the document or reissuing it."
Response 77-g:
This comment is noted.
Comment 77-h:
Why this DEIR as presented is of concern:
This project is very complex and its completion would be impactful to the residents around it on many
levels. There are aged residents who reside near this proposed project in retirement communities.
Many can no longer can concentrate to the extent that they once could and are easily overwhelmed.
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Some said they were intimidated by the DEIR and wondered how to respond when they could not
understand it.
Could a document like this discourage the average reader to persevere and provide a public response
that is meaningful, organized and to the point ? ... again, that remains to be seen. It will be interesting
for the city officials to compare the number and nature of responses to the DEIR to those regarding
the Notice of Preparation.
Response 77-h:
This comment is noted. Please see Topical Responses Sections 2.2.6 and 2.2.7
Comment 77-i:
B. My comments and concerns regarding the Project relative to its presentation in the DEIR
In order to fully understand the intent and ramifications of a DEIR, I went to the Legislation and the
CEQA 2021 Guidelines, as referred to above.
I sought the definition of the "Environment"... which was defined as follows in 15360 of the CEQA
guidelines:
15360. ENVIRONMENT (NOTE: emboldening is writer's)
"Environment" means the physical conditions which exist within the area which will be affected by a
proposed project including land, air, water, minerals, flora, fauna, ambient noise, and objects of
historical or aesthetic significance. The area involved shall be the area in which significant effects
would occur either directly or indirectly as a result of the project. The "environment" includes both
natural and man-made conditions. Note: Authority cited: Section 21083, Public Resources Code;
Reference: Section 21060.5, Public Resources Code. (NOTE: emboldening is writer's)
I find it interesting that the "environment" as defined in CEQA Guideline 15360 includes reference to
both natural and man-made conditions. This definition of ENVIRONMENT will form the basis for my
comments going forward.
Response 77-i:
This comment is noted.
Comment 77-j:
The legislative background for the following section of my comments provided as an Overview, is
important:
The Legislature finds and declares as follows in Environmental Quality Section 21000:
(a) The maintenance of a quality environment for the people of this state now and in the future is a
matter of statewide concern.
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...(b) It is necessary to provide a high-quality environment that at all times is healthful and pleasing to
the senses and intellect of man
...d) The capacity of the environment is limited, and it is the intent of the Legislature that the
government of the state take immediate steps to identify any critical thresholds for the health and
safety of the people of the state and take all coordinated actions necessary to prevent such thresholds
being reached
The key words in the legislation are "high" and "quality" environment, and "threshold for the health
and safety" of the people.
These statements are similar in concept to the 2035 La Quinta General Plan.
"The long term Quality of Life" for La Quinta residents is emphasized repeatedly, particularly in the
Livable Community Element and Land Use Element of the 2035 La Quinta General Plan.
Also, I refer the reader specifically to the following goals and policies that are laid out in the Plan:
GOAL SC -1: A community that provides the best possible quality of life for all its residents.
GOAL LU -3 (11-26): Safe and identifiable neighborhoods that provide a sense of place.
Policy LU -3.1...11-26 Encourage the preservation of neighborhood character and assure a
consistent and compatible land use pattern.
Program LU -3.1.b: Apply the City's discretionary powers and site development review process
consistently to assure that subdivision and development plans are compatible with existing
residential areas.
GOAL LU -4... (11-26): Maintenance and protection of existing neighborhoods.
Policy LU -4.1... (11-26) Encourage compatible development adjacent to existing neighborhoods and
infrastructure.
Response 77-j:
This comment is noted.
Comment 77-k:
How do 1 see this Project?
Rezoning from Low Density Residential w/ golf ("LDR w/G") to Tourist Commercial ("TC") is NOT
consistent with the City of La Quinta's own plan and will lead to a "domino effect" that will negatively
and forever impact the existing surrounding residential communities and their residents.
TC zoning now will open the door to future TC development in SE La Quinta. An entire quadrant of
the City could change forever. Would the possibility of collection of Transient Occupancy Taxes
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supersede the City's responsibility to ensure that "subdivision and development plans are compatible
with the existing residential areas, as per the 2035 Plan?
Response 77-k:
The commenter's opinion is noted. Please see Responses 15-d and 17 as they relate to the Change of
Zone and processing of the proposed project applications.
Comment 77-1:
The salient points follow:
1. The Developers, as stated in the DEIR, are asking for Sub Phase Development based on
"consumer and market demand". This in itself is one of the most disconcerting aspects of this
whole proposal.
I am overwhelmed as I think of how plans for our lives will be totally predicated on the fact
that the "waves and phases" of construction noise and traffic could go on for years and years.
Residents of the surrounding residential communities may never see the completion of this
project in our time here. How does this ensure that we the residents will continue to enjoy
the best possible quality of life - particularly with the uncertainty with respect to the timing of
completion of the Project that we would be facing? (GOAL SC -1)
Response 77-1:
The projected construction period for the project is defined in Section 3.0 Project Description and all
analyses in the Draft EIR address the impacts associated with construction of the proposed project.
Please also see Response 67-f.
Comment 77-m:
2. Rezoning to TC, as stated in the DEIR, will essentially permit the majority (at 600 with a
minimum of one night's stay) of La Quinta's Short Term Vacation Rentals allowed for to be
concentrated at THIS Resort.
As per the City Ordinance No. 591, "no new STVR permits will be issued until further notice
unless the property is located within TC zones"...https://www.laquintaca.gov/connect/short-
term-vacation-rentals.
The large number of STVRs will allow for a constant revolving door of strangers and we, the
residents nearby, will not know our neighbors as we do now. Further, this resort will be open
24 hours per day, again with strangers entering and exiting and milling about. We will think
twice about those recreational runs, walks, hikes or bike rides outside of our gated
communities, particularly earlier in the morning or later in the day. Also, it is a known fact that
crime increases in communities where there is a significant transient population.
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What will happen to our "safe and identifiable neighborhoods that provide a sense of place"?
(see GOAL LU -3 {II -26}). Will these be "sacrificed" for the sake of TOTS for the City of La Quinta?
Response 77-m:
The commenter's concerns are noted. The comment does not provide substantial evidence that
public safety will be impacted by the proposed project. As it relates to the management of STVRs,
please see Response 52-g. The Draft EIR addressed public safety in Section 4.12, and correctly
determined that impacts would be less than significant.
Comment 77-n:
3. Rezoning from LDRw/G to T/C will allow the Developers to apply for Special Events via
Temporary Use Permits.
PAGE 3-35 of DEIR states the following..." Temporary Use Permits are required by the City
accommodate special, unique or limited duration activities that might otherwise be outside
of the provisions of normal zoning ... are reviewed administratively by the Design and
Development Director and do not require a public hearing"
What's to prevent "the 4" that mentioned in the DEIR from turning into 8, or even more, per
year? One the rezoning takes place, the residents nearby will never have further say on this
matter.
There will likely be major access and egress challenges to emergency management vehicles
around most of the limited roadways of the surrounding communities during these Special
Events (think of the La Q Festivals). This could impact our safety and well being, should there
be traffic tie ups both during and before and after Special Events for the "prep and take down
days" that will "bookend" the Special Events themselves. The community of Trilogy, for
example, has ONLY two access and egress roads — Madison and Monroe. That will never
change - whether or not this Project proceeds. Why compromise the "safety" of the local
residents with this Project? We are entitled to safe neighborhoods and all that this entails.
Response 77-n:
Please refer to Response 66-c as it relates to the number of TUPs, and the potential for more. As it
relates to traffic during special events please see Response 52-h.
Comment 77-0:
If one is to stand back and consider the entire concept of Rezoning in this location, it is easy to see
that this project makes no sense. This is definitely not in keeping very important component of the
2035 La Quinta General plan - that which speaks to the "maintenance and protection of existing
neighborhoods" and a "consistent and compatible land use pattern " (see GOAL LU -3 {II -26} above
and policies) (see GOAL LU -4 above{II-26}).
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Further, and from a practical perspective, this project does not and will never benefit the average La
Quinta resident. It is essentially for the rich and it is a private destination for its residents and guests.
An hour of private surfing at Lemoore CA for celebrities runs $10,000.00. In other words, this
recreational outlet is NOT available to and NOT affordable by the average La Quinta resident, is it?
We, the residents of the communities around it, would be required to absorb the negative aspects of
this destination resort without any of the benefits. If I lived in Anaheim near Disneyland, at least I
could plan an outing there with my kids and grandkids. Not so here.
Coral Mountain Resort does NOT fit - it is an entirely different concept of life - it will not be
residentially focused - which will basically be "injected" amongst the quiet residential communities
that surround it. This Project will be a "square peg in a round hole"!
Response 77-0:
The Draft EIR analyzes the project's consistency with the General Plan Land Use Goals on pages 4.10-
15 through 4.10-17, and concludes that the project is consistent with these goals due in part to the
mix of low density residential, neighborhood commercial, resort and open space uses. The low
density residential uses occupy approximately 232 acres of the project site and are situated on the
north and eastern portions of the site, which matches the uses across Avenue 58 and Madison Street.
The higher density resort uses are set well back from these arterial roadways and surrounding
residential communities and help achieve the General Plan Land Use Goals of providing a broad range
of housing types and a balanced and varied economic base for the City. The resort uses also support
General Plan Policy LU -6.3, which encourages "the expansion of the resort industry as a key
component of the City's economic base."
Comment 77-p:
Additional Legislative background for the following section is important when considering the CEQA
categories of Noise, Aesthetics (lights) and Hydrology:
The Legislature finds and declares as follows in Environmental Quality Sections ...
21000 (b) ...it is necessary to provide a high-quality environment that at all times is healthful and
pleasing to the senses and intellect of man.
21001(b) ...all action necessary to provide the people of this state with clean air and water, enjoyment
of aesthetic, natural, scenic, and historic environmental qualities, and freedom from excessive noise.
I would like to provide comments on some of the DEIR categories and the related issues that present
as follow:
Response 77-p:
The commenter's citations are noted.
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Comment 77-q:
1. NOISE
Section 21000(b) of the Legislation speaks to "...freedom from excessive noise".
From a practical perspective, we the residents of the surrounding communities are faced with some
very tangible aspects of surrounding aberrant noise, despite what the DEIR says. In Trilogy, we can
hear the music, thumping and beats of the festivals Coachella and Stagecoach. We can hear the racing
cars at Thermal. Coral Mountain Resort will be close by and what we will hear will be much different
from ambient noise of quiet residential communities.
First of all, many of the DEIR studies, such as the operational noise are based on unknown local
conditions. WE know that there is noise from reverberation at Coral Mountain. What truly will the
operational noise of the Project be?... with its train and tracks, that is the wave making apparatus, as
well as the noise generated by the greatly increased number of people in attendance? What about
the noise that will occur during operational hours from 7 AM - 10 PM every day, 365 days per year?
What about increased noise from traffic during the regular operation of the Project?
There will be increased noise when Special Events are held. What would a Special Event be without
music and more people in attendance? More people equates to more traffic. Additionally, noise
ordinances are always lifted for Special Events. These will definitely impact the quiet residential
communities around the Project.
I should also point out that the construction of a 1/2 mile long concrete Wave Basin could take many
many months with its use of larger, heavier and ultimately noisier construction equipment than would
be required for Low Density Residential construction. Commercial development is also included in
this category; again, this would be subject to Sub Phase Development considerations being asked for
by the Developer.
Finally, from its own 2035 Plan ..."The City's ongoing efforts to preserve the quality of life for all its
residents, present and future, must include the protection of a quiet noise environment" (NOISE IV -
15)
Regardless of the Developer's "studies", there is NO good reason to allow for this kind of noise in a
quiet residential community. There are too many unknowns. The noise issues raised would only come
about as a result of rezoning.
Response 77-q:
The Draft EIR analyzes these operational noise issues in Section 4.11, Noise, and based on evidence
from the project -specific Noise Study conducted by Urban Crossroads, concluded that operation of
the project would result in less than significant impacts. Please see the Topical Response on Noise at
Section 2.2.4, which provides a thorough explanation of how the operational noise from the Wave
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Basin was analyzed and determined to have no significant impacts on the surrounding communities.
Increased traffic noise (during regular operations and during special events) were also analyzed and
determined to be less than significant (see Tables 4.11-19 and 4.1-20 in the Draft EIR). Likewise,
construction noise was fully analyzed and determined to generate less than significant noise levels at
all 10 off-site sensitive receptor locations (see pages 4.11-32 — 4.11-35 of the Draft EIR). Please also
see Responses 52-h, 59-e and 62-f."
Comment 77-r:
2. LIGHTS
Sections 21000(b) and 21001(b) of the Legislation speak to "healthful and pleasing to the senses" and
"enjoyment—of the aesthetic and scenic qualities" 17 (seventeen) 80 foot light towers on until 10 PM
and the nighttime glare from the commercial development - both as a result of the rezoning - are
other unknowns that cannot be studied at this location. Think of the Indian Wells Tennis Gardens at
night; then, please compare to the Cove in La Quinta.
A T/C zoning change, along with the Developer's request for variances, will also allow for many other
types and heights of lights.
Commercial glare in La Quinta is appropriately saved for Hwy 111 and it muted there due to lighting
ordinances. Again, please compare Hwy 111 and the Cove.
Additionally, there is the matter of light diffusion in the nighttime skies in the presence of particulate
matter. This was not accounted for in the "studies" presented in the DEIR.
We, as residents close by have the beautiful dark desert skies now and we will forever be deprived of
this... and all of the variances being asked for as mitigation measures, including walls and setbacks,
will not change this in any way.
Response 77-r:
Please see the Light and Glare Topical Response in Section 2.2.1 of this Chapter for information
regarding lighting levels and the standards employed in the EIR to determine the level of significance.
Please also note that the Neighborhood Commercial proposed for the southwest corner of Madison
Street and Avenue 58 is currently permitted under current zoning for the site. Please see Responses
83-z, 83 -aa, and 83 -bb, as it relates to light diffusion. Finally, please note that the project does not
require variances, nor has it requested variances.
Comment 77-s:
3. HYDROLOGY / WATER
Section 21000(d) of the Legislation states..."The capacity of the environment is limited, and it is the
intent of the Legislature that the government of the state take immediate steps to identify any critical
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thresholds for the health and safety of the people of the state and take all coordinated actions
necessary to prevent such thresholds being reached".
Section 21000 (g) of the Legislation states ..."It is the intent of the Legislature that all agencies of the
state government which regulate activities of private individuals, corporations, and public agencies
which are found to affect the quality of the environment, shall regulate such activities so that major
consideration is given to preventing environmental damage, while providing a decent home and
satisfying living environment for every Californian"
I am totally perplexed as to how this Project with its enormous water usage with 18 million gallons of
water to fill it from our aquifers would even be considered in our desert environment with its high
temperatures, evaporation rate and winds, especially during a mega -drought.
Additionally, there is the issue of the Reasonable Use of Water - in CA law:
From Professor Gray's paper entitled The Reasonable Use Doctrine in California Law and Policy (2015
Brian E. Gray, UC Hastings College of the Law)
https://repository.uchastings.edu/faculty_scholarship/987/ ... , comes the following (note: italics and
underlining are writer's)
..."the cardinal principle of California water law is that all water rights, and all uses of water, must be
reasonable"... and that the Doctrine of "reasonable use" is both a policy mandate AND a limitation
on water rights, which applies to
All branches of government,
All levels of government administration of state's water resources, and
Public and private users of the State's waters.
..."because all uses of water must be consistent with this interdependent and variable definition of
reasonable use, the law renders all water rights fragile. A water right that was reasonable when first
recognized, and which may have been exercised reasonably for many years, may become
unreasonable as hydrologic conditions change, as California's economy evolves, as population grows
and new demands for water arise, as ecological needs are better understood, and as the
environmental laws that protect the state's aquatic ecosystems and native species are applied in ways
that limit the impoundment and diversion of water for consumptive uses"
Further, the City of La Quinta lays out the following in the 2035 Plan, where water conservation is
stressed to protect future resources ; to wit, the following...
Conservation of Natural Resources 11-136 ...The conservation of natural resources is a major
component of a livable community...
Imported water from the Colorado River and new replenishment programs implemented by the
CVWD have helped alleviate declines, but both rely on outside sources of water. In 2010,
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approximately 300,000 acre-feet of water per year have been allocated from the Colorado River
to the eastern Coachella Valley, primarily for agricultural irrigation. Although continued
importation of water will help to replenish the aquifer, a more resourceful alternative is to reduce
the amount of water pumped by the CVWD, which will have a direct impact on overdraft.
Conservation techniques have already been implemented, and new measures are being
developed to lower the amount of water used by each household and business in the City. 11-137
Water conservation in La Quinta is essential to reduce the overdraft of local groundwater, and
protect future resources. 11-138
Water conservation must include all types of water use — from landscaping to indoor fixtures, and
must include new and existing development. The programs described above provide the
foundation for reducing water demand. This Element can allow the City to expand programs that
promote water conservation now and into the future 11-138
Policy UTL-1.2: The City should encourage the conservation of water. (V-15)
GOAL WR -1: The efficient use and conservation of the City's water resources. (V-16)
Two additional concerns with respect to Hydrology of this Project must be addressed:
1. As an aside, but still on the topic of water usage for a Project like this in the desert, I would like the
reader to compare this Project to another responsibly developed and sustainable desert surf park in
the world that is located in the United Arab Emerites (WADI). It has a dedicated 124 mile pipeline
built to pipe ocean water to the area which is then cooled to address high water temperature
concerns for humans AND the proliferation of micro-organisms, both which can cause significant
human illness and even death. https://surfparkcentral.com/wadi-adventure-wave-pool-and-surf-
park-in-al-ain-uae/ Please see Appendix A attached to this letter which is a copy of my letter dated
July 19, 2021 to the Public Health Officer of Riverside County with questions regarding the filtration,
cleaning and disinfecting regimes, including required documentation regarding the protocols. Please
include this letter in the public comments part of my response to the DEIR. Hopefully these questions
raised in the letter to Dr. Leung will be clearly addressed in the Final EIR.
And,
2. The Developer repeatedly argues that a golf course uses more water than the Wave Basin will use.
I say - leave the existing zoning in place and negotiate with a Developer to construct alternative
recreational outlets for the residents who purchase there. Alternatively, a responsible developer can
construct a golf course that observes contemporary conservation measures such as extensive
xeriscaping (as has been accomplished via conversion in many California golf courses) and recycled
water. This is the "wave" of the future !.
Supportive legislation for 2. Above is as follows:
Section 21002 of the Legislation states...
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"The Legislature finds and declares that it is the policy of the state that public agencies should not
approve projects as proposed if there are feasible alternatives or feasible mitigation measures
available which would substantially lessen the significant environmental effects of such projects,
...and that the procedures required by this division are intended to assist public agencies in
systematically identifying both the significant effects of proposed projects and the feasible
alternatives or feasible mitigation measures which will avoid or substantially lessen such
significant effects".
Water is a VITAL component to the health and safety of the people. There is no other "recreational
activity' which would even be considered if there was an equivalent current and potential future
threat to the environment looming in our midst. A development that uses water in this capacity is an
irresponsible development.
There is a global movement under way to be respectful of our natural resources and to conserve
water; all with good reason, and we must as the City of La Quinta has stressed in its own plan, protect
future resources as we think of our children, their children and all future generations.
Response 77-s:
Please see the Water Resources Topical Response in Section 2.2.3 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies. Also see Response 65-c as it relates to the
WADI project in the UAE, and please see Responses 19-b and 49-b regarding the availability and use
of recycled water.
Finally, as it relates to the letter to the Public Health Officer of Riverside County which is attached as
Appendix A to her letter, please see Response No. 77-u below.
Comment 77-t:
C. Conclusion:
In closing, I would like to refer to the CEQA Guidelines Section 15064, where it is stated (c) In
determining whether an effect will be adverse or beneficial, the Lead Agency shall consider the views
held by members of the public in all areas affected as expressed in the whole record before the lead
agency, and
CEQA Guidelines Section 15065, Mandatory Findings of Significance, (4) where it is stated that
consideration should be given to "The environmental effects of a project ... ( and whether they can )
cause substantial adverse effects on human beings, either directly or indirectly"...
We, the residents of the communities nearby, are the "human beings" that will be impacted by all of
the aforementioned effects of the proposed rezoning of this parcel of land to Tourist Commercial.
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With respect to the irresponsible use of water, especially during this unpredictable MEGA drought, it
must be recognized that on a global level all "human beings" are being impacted.
It is acknowledged that change is necessary and often desirable when considering urban planning
issues. It is also understood that a City that is responsive to its residents needs to look to additional
sources of revenue. Please note that the residents who live by this Parcel of land are not against
development, they are against development that is incongruous and irresponsible with respect to
water usage.
As in all things in life, there must be a balance established - pros and cons must carefully be weighed.
The cons outweigh the pros with respect to this Project.
On the basis of what has been presented in the DEIR, please say NO to the rezoning of this parcel of
land to Tourist Commercial.
Thank you for your consideration.
Response 77-t:
This comment is noted. Please see Responses 67-e as it relates to CEQA's mandatory findings of
significance, and please see Response 41-c as it relates to General Plan consistency. Please also see
Responses 52-b and 52-c regarding the policy balancing and findings that are required to be made by
the City Council.
Comment 77-u:
I am writing to you on behalf of a number of concerned residents who reside in La Quinta, CA.
There is a proposed Development called Coral Mountain Resort and its "anchor" is a surf wave basin
that is almost 17 acres in size and filled with 18 million gallons of water from the aquifer— so in other
words, potable water.
The DRAFT Environmental Report was recently released for this Project and public comment in invited
until August 6, 2021.
It is here: https://www.laquintaca.gov/our-city/city-departments/design-and-
development/planningdivision/the-wave-at-coral-mountain
We have questions for Riverside County Department of Public regarding the following please:
1. Background Information
Articles abound online regarding the death of a young man who apparently contracted the "brain
eating ameba" also known as Naegleria fowleri from a surfing experience at Waco TX. The water in
this wave basin had apparently been described as a "pathogen soup".
https://www.tracksmag.com.au/news/surfer-dies-from-brain-eating-amoeba-513336
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https://raisedwaterresearch.com/bsr-covers-up-evidence-in-surfers-death-lawyer-alleges/
The CDC describes Naegleria fowleri "as a free-living microscopic ameba that can cause a rare and
devastating infection of the brain called primary amebic meningoencephalitis".
https://www.cdc.gov/parasites/naegleria/index.html. The website also goes on to say that this
microorganism usually infects people when contaminated water enters the body through the nose.
WEB MD says "Naegleria loves very warm water. It can survive in water as hot as 113 degrees
Fahrenheit"... "most cases of N.fowleri disease occur in Southern or Southwestern states... "The nose
is the pathway of the amoeba, so infection occurs most often from diving, water skiing, or performing
water sports in which water is forced into the nose".
https://www.webmd.com/brain/brain-eating-amoeba
Given that this young man's death occurred, ostensibly from an exposure to the parasite while surfing
in an artificial basin, the Developers and operators of surf/wave parks apparently are "ramping up
their efforts" to prevent this from occurring again. Some public health agencies have also stepped in
to ensure that this is the case with enhanced filtration requirements, as well as the requirements for
daily testing with water quality reports, detailing chlorine, pH, sediment and E. coli levels.
Response 77-u:
While Rebryna provides a copy of the letter she sent to Riverside County, she does not provide any
response from the Riverside County Public Health Officer. In addition, no comment letter from the
Riverside County Health Department has been received by the City raising any public health concerns
regarding the project or the proposed Wave Basin. Comment 77-u references articles about "brain
eating ameba" that can survive in very hot water and led to the death of a surfer who visited a surf
water park in Waco, Texas. However, Rebryna does not provide any studies or data showing
similarities between the conditions of the water park in Waco, Texas at the time of the infection and
the proposed water conditions that will occur at the project Wave Basin. According to the CDC, the
Naegleria fowleri amoeba thrive in "poorly maintained or minimally chlorinated swimming pools,"
and according to the environmental health manager for the Waco -McLennan County Public Health
District, at the time of the infection, the water at the water park in Waco "mostly went untreated
except for occasional dumps of chlorine." (see https://www.theinertia.com/surf/brain-eating-
amoeba-fabrizio-stabile-mother-suing-waco-wave-pool-bsr-cable-park/). The proposed Wave Basin,
on the other hand, will be subject to all applicable health and safety requirements of the Riverside
County and State of California Departments of Health, including proper maintenance of the water in
the Wave Basin. As stated on page 4.8-19 of the Draft EIR, the project will be required to comply
with regulations established by the California Department of Public Health and the Riverside County
Municipal Code. Adherence to federal, State, and regional regulatory standards will ensure impacts
related to the water quality in the Wave Basin will be less than significant.
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Comment 77-v:
2. The reasons for our letter and for my contacting you are as follow:
A. The desert is HOT (120 days over 100 degrees last year) and the hottest months are June, July
and August. We have been told repeatedly that there are NO plans by the Developer to cool
the surf/wave basin in the summer months.
We have concerns about the increased potential for proliferation of microorganisms in the
heat of summer in the desert.
The only other desert pool that we know of is in WADI UAE where a 100 plus mile dedicated
pipeline is built to bring desalinated water in that is then cooled onsite for use at its surf /
wave basin.
We have concerns about the health and safety of the people who recreate in this very hot
water.
Response 77-v:
The information provided regarding the United Arab Emirates facility is acknowledged. As it relates
to the temperature of the water, please see Response 42-d. As it relates to protozoa and viruses,
please see Response 77-u.
Comment 77-w:
B. We have reviewed the DRAFT EIR to determine if there is evidence of a detailed cleaning and
disinfection plan in place for the ongoing maintenance of the pool, particularly with number
of hot days that we have here in the desert; there is none.
There is also no information on the presence of a filtration system that swimming pools
require.
From a public safety perspective, we would feel much more reassured about the operation
and maintenance of this surf/wave basin if a detailed maintenance protocol was made publicly
available, given this extraordinarily unusual HOT environment for his type of recreational
outlet.
There is nothing in the DEIR that outlines the required cleaning and maintenance schedules
or whether or not periodic complete pool emptying and refilling is required.
There seems to be a somewhat perfunctory description of the intended disinfection regime
(4.8.18... Coral Mountain Resort DRAFT EIR) There is a generalized reference made to Section
65529 (Public Pool Disinfection of Title 22 of the California Code of Regulations CCR) in that
the pool must be "disinfected continuously".
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We see evidence of "materials" that will be used in June July and August (with particular
reference to sodium hypochlorite - NaCIO) as well as halogens, however no evidence of a plan
per se.
How is the contamination of the water with bodily fluids addressed? ... e.g. blood, urine, feces
Response 77-w:
The operation and maintenance of the Wave Basin will comply with State and County health
standards to ensure that people are not exposed to dangerous swimming conditions. As stated on
page 4.8-19 of the Draft EIR, the project will be required to comply with regulations established by
the California Department of Public Health and the Riverside County Municipal Code. The project will
be required to use pool disinfecting and cleaning supplies, and shall be required to follow the
procedures established in the Municipal Code and Chapter 6.95 of the HSC. These standards are
designed to prevent contaminants, including protozoa and viruses, from surviving in the water. As it
relates to daily additions to the wave pool, please see Response 65-d. As it relates to chlorine use, the
Wave Basin is anticipated to use approximately 216,000 gallons of sodium hypochlorite and 14,440
gallons of sulfuric acid annually, which are both commonly used chemicals in swimming pools (for
maximum accuracy, estimates are based on actual rates used at the wave basin in Lemoore, not usage
rates at typical swimming pools). Emptying and refiling the Wave Basin is not required for cleaning
or maintenance activities.
Comment 77-x:
C. We also question whether the operator of the wave basin will be able to maintain an accurate
concentration of the required disinfecting agents particularly because of high rates of water
evaporation due to the extraordinary heat, high winds and the wave action itself in these
desert conditions. How will accurate records be kept of the conditions that are present at the
pool? As stated above, the standard of care looks more and more like records MUST be kept,
with frequent assessment and input data for surf/wave basin water.
D. Who will administer the records and data? Who will ensure compliance?
Response 77-x:
This comment questions the accuracy of future records of maintenance activities but does not raise
any environmental issues. Accordingly, no further response is required.
Comment 77-y:
E. We are concerned that Kelly Slater et al has essentially stated in the past that "treating and filtering
water pursuant to existing regulations makes a public surf park in California not viable", as per a quote
from the inertia https://www.theinertia.com/surf/kelly-slater-wavecompany-pool-regulations-surf-
pool-wave-basin-california/. Thus our question - if this was argued before by this surf ranch pool, will
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this aspect of pool maintenance now be taken seriously by the operators? It appears that it wasn't in
WACO, prior to that young man's death.
Response 77-y:
Please see Response 77-w regarding compliance with all applicable State and County health and
safety regulations.
Comment 77-z:
Thank you for allowing me to lay out our concerns regarding the maintenance of the surf wave basin
with respect to appropriate cleaning and disinfecting regimes, particularly as related to the possibility
of proliferation of pathogens in water that is not cooled and/or properly treated in this hot desert
environment. Because of the lack of cooling, we are also concerned about the safety of the people
who surf in that type of hot desert environment.
Response 77-z:
This comment summarizes the concerns raised in the letter but does not raise any new information
or concerns. Please see Responses 77-u through 77-y.
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Comment Letter No. 78: Harvey Reed
Date: August 5, 2021
Affiliation: Area Resident
Comment 78-a:
Please accept this email as notification of my opposition to the proposed location of the Coral
Mountain Resort. Changing the zoning of the proposed location from "Low Density Residential -Open
Space Recreation" to "Tourist -Commercial" is inconsistent with current and planned land use. A
zoning change will also negatively affect the quality of life for thousands of La Quinta residents who
live adjacent to the proposed location.
The Draft Environmental Impact Report (DEIR) describes the proposed private resort as having 80 -
foot tall light poles, a public address system, an immense hydraulic and mechanical system pulling a
wave sled and other industrial equipment operating from 7:OOAM— 10:OOPM, 365 days a year. Based
on operations at the developer's other wave park resorts, jet skis will also operate on the Wave Basin
during the same time. According to the DEIR, this private resort will host special events throughout
the year lasting up to four days in length with an estimated 2,500 outside attendees per day.
Response 78-a:
The commenter describes his understanding of the project, which is noted. As it relates to the
requested Zone Change and the process for same, please see Responses 15-d and 17-a.
Comment 78-b:
It should be noted that the developers have built wave park resorts in areas that are not surrounded
by residential communities (please see attached photos). They now desire to build what they describe
as "The world's largest Wave Basin" in the center of a residential area in La Quinta.
In the DEIR, the developers briefly admit that, "The project site is surrounded by developed residential
communities..." What the DEIR does not articulate is that the residential communities of The Quarry,
Santerra, Coral Mountain Estates, Andalusia, and Trilogy are adjacent to the proposed location. New
home developments are currently planned immediately south of the proposed location including the
Estate Collection at Coral Mountain and the 1,200 residential Travertine community. When those
developments are completed, the proposed wave park will literally be surrounded by residential
communities. The location of the proposed wave park is currently zoned "Low Density Residential,
Open Space -Recreational" which is consistent with the design and use of existing adjacent residential
communities and those being planned.
Response 78-b:
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The Draft EIR analyzes the project's consistency with the surrounding residential communities in
Chapter 4.10, and concludes that the project is compatible with both the surrounding land uses and
the applicable General Plan land use goals and policies. (See Draft EIR at pp. 4.10-15 — 4.10-17 and
4.10-30 — 4.10-31). Please also see Responses 41-c and 52-f.
Comment 78-c:
The location, size, design and operating characteristics of this proposed project are not compatible
with existing and future land uses. Furthermore, the project will create traffic, lighting and noise
conditions which will negatively impact thousands of La Quinta residents living in the adjacent
residential communities.
Please consider different locations that are appropriate for this project.
Response 78-c:
The commenter's opinions are noted. The Draft EIR addressed additional light, noise and traffic
impacts in Section 4.1, Aesthetics, Section 4.11, Noise, and 4.13, Transportation, (respectively).
Findings and conclusions regarding project impacts were based on technical studies and plans
prepared by topic experts, correctly provided an analysis of impacts, mitigation measures where
necessary and feasible, and disclosed significant impacts under Aesthetics. With regard to land use
compatibility concerns, please see Responses 41-c and 52-f. With regard to lighting, noise and traffic
concerns, please see the Topical Responses on these issues in Sections 2.2.1, 2.2.4, and 2.2.5,
respectively. With regard to alternative locations for the project, an alternative location for the
proposed project was discussed in Chapter 7.0, Alternatives, of the Draft EIR.
Comment 78-d:
In this comment, Reed provides Google Earth images and screenshots of aerials displaying locations
of other Wave Basins. In the aerial screenshots, Reed indicates that the existing wave facilities are
not located near residential, while the project site is located in proximity to residential communities.
Response 78-d:
This comment is noted.
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Comment Letter No. 79: Mitchell Tsai — Southwest Regional Council of Carpenters
Date: August 5, 2021
Affiliation: Representative of Southwest Regional Council of Carpenters
Comment 79-a:
On behalf of the Southwest Regional Council of Carpenters ("Commenters" or "Southwest
Carpenters"), my Office is submitting these comments on the City of La Quinta's ("City" or "Lead
Agency") Draft Environmental Impact Report ("DEIR") (SCH No. 2021020310) for the proposed Coral
Mountain Resort Project ("Project").
The City proposes to adopt the Project, carving out 386 acres of a 929 -acre area of the City, to
promote future development of the Coral Mountain Resort. The Project would allow for the
development of 600 residential units, a 150 -room resort hotel plus complementary uses and
amenities, a recreational surf facility, 57,000 square feet of commercial development, 60,000 square
feet of neighborhood commercial uses, and 23.6 acres of recreational uses. As part of the Project, the
City would initiate a general plan amendment and zoning change to designate the Project area for
"Tourist Commercial" uses; a specific plan amendment to exclude the Project area from a previous
specific plan; the adoption of the Project's specific plan; the adoption of a tentative tract map; site
development permits; and the adoption of a development agreement with the Project applicant.
The Southwest Carpenters is a labor union representing more than 50,000 union carpenters in six
states and has a strong interest in well ordered land use planning and addressing the environmental
impacts of development projects.
Individual members of the Southwest Carpenters live, work, and recreate in the City and surrounding
communities and would be directly affected by the Project's environmental impacts.
Commenters expressly reserve the right to supplement these comments at or prior to hearings on
the Project, and at any later hearings and proceedings related to this Project. Cal. Gov. Code §
65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens for Local Control v. Bakersfield (2004)
124 Cal. App. 4th 1184, 1199-1203; see Galante Vineyards v. Monterey Water Dist. (1997) 60 Cal. App.
4th 1109, 1121.
Commenters incorporate by reference all comments raising issues regarding the EIR submitted prior
to certification of the EIR for the Project. Citizens for Clean Energy v City of Woodland (2014) 225 Cal.
App. 4th 173, 191 (finding that any party who has objected to the Project's environmental
documentation may assert any issue timely raised by other parties).
Moreover, Commenters request that the Lead Agency provide notice for any and all notices referring
or related to the Project issued under the California Environmental Quality Act ("CEQA"), Cal Public
Resources Code ("PRC") § 21000 et seq, and the California Planning and Zoning Law ("Planning and
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Zoning Law"), Cal. Gov't Code §§ 65000-65010. California Public Resources Code Sections 21092.2,
and 21167(f) and Government Code Section 65092 require agencies to mail such notices to any
person who has filed a written request for them with the clerk of the agency's governing body.
Response 79-a:
This introductory comment states that the commenter represents the Southwest Regional Council of
Carpenters and requests notice of further proceedings relating to the project. As this comment does
not raise any specific concerns or questions regarding the potential environmental impacts of the
project, no further response to this comment is provided.
Comment 79-b:
The City should require the Applicant provide additional community benefits such as requiring local
hire and use of a skilled and trained workforce to build the Project. The City should require the use of
workers who have graduated from a Joint Labor Management apprenticeship training program
approved by the State of California, or have at least as many hours of on-the-job experience in the
applicable craft which would be required to graduate from such a state approved apprenticeship
training program or who are registered apprentices in an apprenticeship training program approved
by the State of California.
Community benefits such as local hire and skilled and trained workforce requirements can also be
helpful to reduce environmental impacts and improve the positive economic impact of the Project.
Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of
the Project Site can reduce the length of vendor trips, reduce greenhouse gas emissions and providing
localized economic benefits. Local hire provisions requiring that a certain percentage of workers
reside within 10 miles or less of the Project Site can reduce the length of vendor trips, reduce
greenhouse gas emissions and providing localized economic benefits. As environmental consultants
Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value
has the potential to result in a reduction of construction -related GHG emissions, though the
significance of the reduction would vary based on the location and urbanization level of the
project site.
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for
Greenhouse Gas Modeling.
Skilled and trained workforce requirements promote the development of skilled trades that yield
sustainable economic development. As the California Workforce Development Board and the UC
Berkeley Center for Labor Research and Education concluded:
... labor should be considered an investment rather than a cost — and investments in growing,
diversifying, and upskilling California's workforce can positively affect returns on climate
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mitigation efforts. In other words, well trained workers are key to delivering emissions reductions
and moving California closer to its climate targets.
Recently, on May 7, 2021, the South Coast Air Quality Management District found that that the "[u]se
of a local state -certified apprenticeship program or a skilled and trained workforce with a local hire
component" can result in air pollutant reductions.
Cities are increasingly adopting local skilled and trained workforce policies and requirements into
general plans and municipal codes. For example, the City of Hayward 2040 General Plan requires the
City to "promote local hiring ... to help achieve a more positive jobs -housing balance, and reduce
regional commuting, gas consumption, and greenhouse gas emissions."
In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy into its Downtown
Specific Plan and municipal code, requiring developments in its Downtown area to requiring that the
City "[c]ontribute to the stabilization of regional construction markets by spurring applicants of
housing and nonresidential developments to require contractors to utilize apprentices from state -
approved, joint labor-management training programs, ..."4 In addition, the City of Hayward requires
all projects 30,000 square feet or larger to "utilize apprentices from state -approved, joint labor-
management training programs."
Locating jobs closer to residential areas can have significant environmental benefits. As the California
Planning Roundtable noted in 2008:
People who live and work in the same jurisdiction would be more likely to take transit, walk, or
bicycle to work than residents of less balanced communities and their vehicle trips would be
shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle
hours traveled.
In addition, local hire mandates as well as skill training are critical facets of a strategy to reduce vehicle
miles traveled. As planning experts Robert Cervero and Michael Duncan noted, simply placing jobs
near housing stock is insufficient to achieve VMT reductions since the skill requirements of available
local jobs must be matched to those held by local residents.7 Some municipalities have tied local hire
and skilled and trained workforce policies to local development permits to address transportation
issues. As Cervero and Duncan note:
In nearly built -out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs
rather than to develop new housing." The city's First Source program encourages businesses to
hire local residents, especially for entry- and intermediate -level jobs, and sponsors vocational
training to ensure residents are employment -ready. While the program is voluntary, some 300
businesses have used it to date, placing more than 3,000 city residents in local jobs since it was
launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy
about negotiating corporate participation in First Source as a condition of approval for
development permits.
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The City should consider utilizing skilled and trained workforce policies and requirements to benefit
the local area economically and mitigate greenhouse gas, air quality and transportation impacts.
The City should also require the Project to be built to standards exceeding the current 2019 California
Green Building Code to mitigate the Project's environmental impacts and to advance progress
towards the State of California's environmental goals.
Response 79-b:
The commenter's opinions regarding City policy are noted. The comment regarding the use of workers
who have graduated from a Joint Labor Management apprenticeship program, or have on-the-job
experience does not explain or establish how such a requirement would substantially lessen or avoid
any significant environmental effects of the project as identified in the DEIR.
The commenter requests that a specified percent of workers must reside within 10 miles of the
project. Unfortunately, this opinion does not identify the current average commute distance for
construction workers in the La Quinta area, nor does it quantify or demonstrate that any reduction in
GHG emissions would result from such a restriction. It also appears that the expertise of Mr.
Hagemann is in geology and hydrology, and not transportation or GHG emissions. Similarly, the
expertise of Mr. Rosenfield appears to be in chemistry and contamination issues, rather than
transportation issues. Neither individual appears to have any professional licenses, certifications or
other credentials that would qualify them as experts in the field of reducing vehicle miles traveled.
The comment also describes certain approaches taken in two Bay Area cities to promote hiring local
workers. Again, there is no substantial evidence provided by the commenter demonstrating that such
a requirement in the City of La Quinta would reduce GHG emissions relating to construction worker
vehicle miles traveled. By way of contrast to the comment's unsubstantiated claim, and as described
at length in Section 4.7 (Greenhouse Gas Emissions), the project has included a number of established
project design features (PDFs) that are recognized to reduce GHG emissions and can be quantified in
the CaIEEMod model used to calculate GHG emissions (see DEIR pp. 4.7-11 — 4.7-13). These PDFs
include a number of energy efficiency and vehicle miles traveled (VMT) reduction features, consistent
with the CARB 2017 Scoping Plan (see DEIR Appendix!, at pp. 58-67). In addition, the DEIR identifies
Mitigation Measure GHG-1, which requires the applicant to purchase a minimum of 72,000 MTCO2e
carbon credits from a CARB-approved carbon registry prior to issuance of occupancy certificates (see
DEIR p. 4.7-26).
Given that construction emissions only constitute approximately 2.5% of the project's total projected
GHG emissions, it is exceedingly unlikely that requiring a specific percentage of local construction
workers would cause any appreciable reduction in the project's overall GHG emissions (as shown in
Table 4.7-3 in the DEIR, the construction emissions amount to 414.62 MTCO2e/year out of total
project emissions of 16,725.03 MTCO2e/year). By comparison, the project design features
incorporated into the project reduce the GHG emissions by 4,988.36 MTCO2e/year, and Mitigation
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Measure GHG-1 requires the purchase of carbon credits equal to an additional 2,400 MTCO2e/year
(see DEIR pp. 4.7-17-4.7-18 and 4.7-26).
Finally, the comment states that the City should require the project to exceed (rather than comply
with) the applicable 2019 California Green Building Code. Such a requirement may be the
commenter's public policy preference, but it is not a matter of CEQA compliance and is not required
by California's GHG emissions reduction requirements or the City's GHG reduction plan.
Comment 79-c:
I. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE CALIFORNIA ENVIRONMENTAL QUALITY
ACT
A. Background Concerning the California Environmental Quality Act
CEQA has two basic purposes. First, CEQA is designed to inform decision makers and the public about
the potential, significant environmental effects of a project. 14 California Code of Regulations ("CCR"
or "CEQA Guidelines") § 15002(a)(1).8 "Its purpose is to inform the public and its responsible officials
of the environmental consequences of their decisions before they are made. Thus, the EIR 'protects
not only the environment but also informed self-government.' [Citation.]" Citizens of Goleta Valley v.
Board of Supervisors (1990) 52 Cal. 3d 553, 564. The EIR has been described as "an environmental
'alarm bell' whose purpose it is to alert the public and its responsible officials to environmental
changes before they have reached ecological points of no return." Berkeley Keep Jets Over the Bay v.
Bd. of Port Comm'rs. (2001) 91 Cal. App. 4th 1344, 1354 ("Berkeley Jets"); County of Inyo v. Yorty
(1973) 32 Cal. App. 3d 795, 810.
Second, CEQA directs public agencies to avoid or reduce environmental damage when possible by
requiring alternatives or mitigation measures. CEQA Guidelines § 15002(a)(2) and (3). See also,
Berkeley Jets, 91 Cal. App. 4th 1344, 1354; Citizens of Goleta Valley v. Board of Supervisors (1990) 52
Ca1.3d 553; Laurel Heights Improvement Ass'n v. Regents of the University of California (1988) 47
Ca1.3d 376, 400. The EIR serves to provide public agencies and the public in general with information
about the effect that a proposed project is likely to have on the environment and to "identify ways
that environmental damage can be avoided or significantly reduced." CEQA Guidelines § 15002(a)(2).
If the project has a significant effect on the environment, the agency may approve the project only
upon finding that it has "eliminated or substantially lessened all significant effects on the environment
where feasible" and that any unavoidable significant effects on the environment are "acceptable due
to overriding concerns" specified in CEQA section 21081. CEQA Guidelines § 15092(b)(2)(A—B).
While the courts review an EIR using an "abuse of discretion" standard, "the reviewing court is not to
'uncritically rely on every study or analysis presented by a project proponent in support of its
position.' A 'clearly inadequate or unsupported study is entitled to no judicial deference." Berkeley
Jets, 91 Cal.App.4th 1344, 1355 (emphasis added) (quoting Laurel Heights, 47 Ca1.3d at 391, 409 fn.
12). Drawing this line and determining whether the EIR complies with CEQA's information disclosure
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requirements presents a question of law subject to independent review by the courts. Sierra Club v.
Cnty. of Fresno (2018) 6 Cal. 5th 502, 515; Madera Oversight Coalition, Inc. v. County of Madera (2011)
199 Cal.App.4th 48, 102, 131. As the court stated in Berkeley Jets, 91 Cal. App. 4th at 1355:
A prejudicial abuse of discretion occurs "if the failure to include relevant information precludes
informed decision-making and informed public participation, thereby thwarting the statutory
goals of the EIR process.
The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and
developers to overcome. The EIR's function is to ensure that government officials who decide to build
or approve a project do so with a full understanding of the environmental consequences and, equally
important, that the public is assured those consequences have been considered. For the EIR to serve
these goals it must present information so that the foreseeable impacts of pursuing the project can
be understood and weighed, and the public must be given an adequate opportunity to comment on
that presentation before the decision to go forward is made. Communities for a Better Environment
v. Richmond (2010) 184 Cal. App. 4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth,
Inc. v. City of Rancho Cordova (2007) 40 Ca1.4th 412, 449-450).
Response 79-c:
The commenter's explanation of the purpose of CEQA is noted. This comment does not identify a
specific concern or question regarding the adequacy of the Draft EIR in identifying and analyzing the
potential environmental impacts of the project. For this reason, no further response to this comment
is provided.
Comment 79-d:
B. CEQA Requires Revision and Recirculation of an Environmental Impact
Report When Substantial Changes or New Information Comes to Light Section 21092.1 of the
California Public Resources Code requires that "[w]hen significant new information is added to an
environmental impact report after notice has been given pursuant to Section 21092 ... but prior to
certification, the public agency shall give notice again pursuant to Section 21092, and consult again
pursuant to Sections 21104 and 21153 before certifying the environmental impact report" in order to
give the public a chance to review and comment upon the information. CEQA Guidelines § 15088.5.
Significant new information includes "changes in the project or environmental setting as well as
additional data or other information" that "deprives the public of a meaningful opportunity to
comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate
or avoid such an effect (including a feasible project alternative)." CEQA Guidelines § 15088.5(a).
Examples of significant new information requiring recirculation include "new significant
environmental impacts from the project or from a new mitigation measure," "substantial increase in
the severity of an environmental impact," "feasible project alternative or mitigation measure
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considerably different from others previously analyzed" as well as when "the draft EIR was so
fundamentally and basically inadequate and conclusory in nature that meaningful public review and
comment were precluded." Id.
An agency has an obligation to recirculate an environmental impact report for public notice and
comment due to "significant new information" regardless of whether the agency opts to include it in
a project's environmental impact report. Cadiz Land Co. v. Rail Cycle (2000) 83 Cal.App.4th 74, 95
[finding that in light of a new expert report disclosing potentially significant impacts to groundwater
supply "the EIR should have been revised and recirculated for purposes of informing the public and
governmental agencies of the volume of groundwater at risk and to allow the public and
governmental agencies to respond to such information."]. If significant new information was brought
to the attention of an agency prior to certification, an agency is required to revise and recirculate that
information as part of the environmental impact report.
Response 79-d:
The commenter's view of recirculation requirements under CEQA are noted. The comment does not
identify a specific concern or question regarding the adequacy of the Draft EIR in identifying and
analyzing the potential environmental impacts of the project. This comment does not identify a
specific concern or question regarding the adequacy of the Draft EIR in identifying and analyzing the
potential environmental impacts of the project. For this reason, no further response to this comment
is provided.
Comment 79-e:
C. Due to the COVID-19 Crisis, the City Must Adopt a Mandatory Finding
of Significance that the Project May Cause a Substantial Adverse Effect on Human Beings and Mitigate
COVID-19 Impacts CEQA requires that an agency make a finding of significance when a Project may
cause a significant adverse effect on human beings. PRC § 21083(b)(3); CEQA Guidelines §
15065(a)(4).
Public health risks related to construction work requires a mandatory finding of significance under
CEQA. Construction work has been defined as a Lower to Highrisk activity for COVID-19 spread by the
Occupations Safety and Health Administration. Recently, several construction sites have been
identified as sources of community spread of COVID-19.
SWRCC recommends that the Lead Agency adopt additional CEQA mitigation measures to mitigate
public health risks from the Project's construction activities. SWRCC requests that the Lead Agency
require safe on-site construction work practices as well as training and certification for any
construction workers on the Project Site.
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In particular, based upon SWRCC's experience with safe construction site work practices, SWRCC
recommends that the Lead Agency require that while construction activities are being conducted at
the Project Site:
Construction Site Design:
• The Project Site will be limited to two controlled entry points.
• Entry points will have temperature screening technicians taking temperature readings when the
entry point is open.
• The Temperature Screening Site Plan shows details regarding access to the Project Site and
Project Site logistics for conducting temperature screening.
• A 48-hour advance notice will be provided to all trades prior to the first day of temperature
screening.
• The perimeter fence directly adjacent to the entry points will be clearly marked indicating the
appropriate 6 -foot social distancing position for when you approach the screening area. Please
reference the Apex temperature screening site map for additional details.
• There will be clear signage posted at the project site directing you through temperature
screening.
• Provide hand washing stations throughout the construction site.
Testing Procedures:
• The temperature screening being used are non -contact devices.
• Temperature readings will not be recorded.
• Personnel will be screened upon entering the testing center and should only take 1-2 seconds
per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on
the forehead before temperature screening.
• Anyone who refuses to submit to a temperature screening or does not answer the health
screening questions will be refused access to the Project Site.
• Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ZONE 1]
and personnel gate [ZONE 2]
• After 7:30 am only the main gate entrance [ZONE 1] will continue to be used for temperature
testing for anybody gaining entry to the project site such as returning personnel, deliveries, and
visitors.
• If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a
second reading will be taken to verify an accurate reading.
• If the second reading confirms an elevated temperature, DHS will instruct the individual that
he/she will not be allowed to enter the Project Site. DHS will also instruct the individual to
promptly notify his/her supervisor and his/her human resources (HR) representative and
provide them with a copy of Annex A.
Planning
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• Require the development of an Infectious Disease Preparedness and Response Plan that will
include basic infection prevention measures (requiring the use of personal protection
equipment), policies and procedures for prompt identification and isolation of sick individuals,
social distancing (prohibiting gatherings of no more than 10 people including all -hands meetings
and all -hands lunches) communication and training and workplace controls that meet standards
that may be promulgated by the Center for Disease Control, Occupational Safety and Health
Administration, Cal/OSHA, California Department of Public Health or applicable local public
health agencies.
The United Brotherhood of Carpenters and Carpenters International Training Fund has developed
COVID-19 Training and Certification to ensure that Carpenter union members and apprentices
conduct safe work practices. The Agency should require that all construction workers undergo COVID-
19 Training and Certification before being allowed to conduct construction activities at the Project
Site.
Response 79-e:
The comment cites two articles regarding COVID-19 risks at construction sites, but both are from the
very early stages of the pandemic (April and June 2020) before testing protocols and vaccinations
became available, and before natural immunities developed. The comment does not present any
evidence demonstrating significant COVID-19 risks at construction sites in Riverside County as of late
2021 that are not adequately addressed with current federal, state and Riverside County
requirements. For example, construction sites are already subject to Cal OSHA's requirements for a
written COVID-19 Prevention Program and an Injury and Illness Prevention Program to protect
employees from all worksite hazards, including infectious diseases (see, e.g., California Code of
Regulations, Title 8, Subchapter 7, §§ 3203 and 3205; and Cal OSHA Safety and Health Guidance
COVID-19 Infection Prevention in Construction, dated October 27, 2020, at
www.dir.ca.gov/dosh/coronavirus/COVID-19-Infection-Prevention-in-Construction.pdf).
The comment also cites to PRC Section 21083(b)(3) which, along with CEQA Guideline Section
15065(a)(4), provide that a public agency must prepare an EIR where it finds that there is substantial
evidence in the record that the project will cause substantial adverse effects. Here, the City did
require preparation of an EIR to analyze all potentially significant effects of the project, as well as
mitigation measures and alternatives that minimize or avoid such effects to the maximum extent
feasible. The evidence in the record does not support the requests made in this comment.
Comment 79-f:
D. The DEIR's Project Objectives are Unduly Narrow and Circumscribe Appropriate Project
Alternatives
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A project description must state the objectives sought by the proposed project. The statement of
objectives should include the underlying purpose of the project, and 't should be clearly written to
guide the selection of mitigation measures and alternatives to be evaluated in the EIR. (CEQA
Guidelines § 15124(b).) An EIR's description of the underlying purpose of the project is the touchstone
for its identification of specific project objectives, and the statement of project objectives can help to
define the contours of the project's purpose. (Center for Biological Diversity v. County of San
Bernardino (2016) 247 Cal. App. 4th 326, 347.) While a lead agency has discretion to formulate the
project objectives, they cannot be so narrowly defined that they preclude discussion of project
alternatives that could still achieve the underlying purpose of the project. (North Coast Rivers Alliance
v. Kawamura (2015) 243 Cal. App. 4th 647, 668.) This is so because project alternatives that do not
achieve the project's underlying purpose need not be considered. (In re Bay -Delta Programmatic
Envt'I Impact Report Coordinated Proceedings (2008) 43 Cal. 4th 1143, 1166.) And the statement of
objectives should be based upon the underlying purpose of the project—not the nature of the project
itself. (Habitat & Watershed Caretakers v. City of Santa Cruz (2013) 213 Cal. App. 4th 1277, 1299.)
Here, the DEIR inappropriately narrows the objectives of the project based upon the nature of the
project, and not on any underlying purpose. The Project's objectives include the "[development of] a
high-quality private Wave Basin (The Wave) that provides unique recreational opportunities for
future residents of the project, and that attracts resort guests and creates a landmark facility that will
enhance the City's reputation as the 'Gem of the Desert." (DEIR, 3-8.) If this remains a project
objective, the DEIR need not consider project alternatives that do not provide "highquality private
Wave Basins." Certainly, there is no specific requirement that the tourism or residential housing
needs of the City or region demand a surf simulation facility. The Objective should be reformulated
so that a meaningful analysis of project alternatives can be considered.
Response 79-f:
The private Wave Basin amenity is identified in the Draft EIR only as the last of seven separate project
objectives set forth on page 3-8 of the DEIR, and no single objective was used to eliminate potential
project alternatives. In fact, the DEIR evaluated five project alternatives, only one of which includes
a private Wave Basin. These alternatives include a No Project/No Build Alternative, a No
Project/Existing Entitlements Alternative, a Reduced Density Alternative, a Golf/Resort Hotel
Alternative, and a Lake Amenity/No Hotel Alternative. This range of alternatives fully complies with
the requirements of CEQA Guideline 15126.6. The DEIR analyzes the comparative environmental
effects of several different development scenarios on the project site, including the existing General
Plan land uses, an alternative resort hotel and residential development with a championship golf
course as the central amenity, and a residential only development with a private lake as the central
amenity. The commenter's assertion that the seventh objective is unduly restricting is not supported
by substantial evidence.
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Comment 79-g:
E. The DEIR Fails to Support Its Findings with Substantial Evidence
When new information is brought to light showing that an impact previously discussed in the DEIR
but found to be insignificant with or without mitigation in the DEIR's analysis has the potential for a
significant environmental impact supported by substantial evidence, the EIR must consider and
resolve the conflict in the evidence. See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal. App. 5th 1,
13, 17; see also Protect the Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App.
4th 1099, 1109. While a lead agency has discretion to formulate standards for determining
significance and the need for mitigation measures—the choice of any standards or thresholds of
significance must be "based to the extent possible on scientific and factual data and an exercise of
reasoned judgment based on substantial evidence. CEQA Guidelines § 15064(b); Cleveland Nat'l
Forest Found. v. San Diego Ass'n of Gov'ts (2017) 3 Cal. App. 5th 497, 515; Mission Bay Alliance v.
Office of Community Inv. & Infrastructure (2016) 6 Cal. App. 5th 160, 206. And when there is evidence
that an impact could be significant, an EIR cannot adopt a contrary finding without providing an
adequate explanation along with supporting evidence. East Sacramento Partnership for a Livable City
v. City of Sacramento (2016) 5 Cal. App. 5th 281, 302.
In addition, a determination that regulatory compliance will be sufficient to prevent significant
adverse impacts must be based on a project -specific analysis of potential impacts and the effect of
regulatory compliance. Californians for Alternatives to Toxics v. Department of Food & Agric. (2005)
136 Cal. App. 4th 1; see also Ebbetts Pass Forest Watch v Department of Forestry & Fire Protection
(2008) 43 Cal. App. 4th 936, 956 (fact that Department of Pesticide Regulation had assessed
environmental effects of certain herbicides in general did not excuse failure to assess effects of their
use for specific timber harvesting project).
Response 79-g:
This comment sets forth the commenter's view of the applicable legal requirements for evaluating a
project's environmental effects and determining the significance of such effects, however, it does not
identify a specific concern or question regarding the adequacy of the Draft EIR in identifying and
analyzing the potential environmental impacts of the project. For this reason, no further response is
provided.
Comment 79-h:
1. The DEIR Fails to Support its Findings on Greenhouse Gas and Air Quality Impacts with Substantial
Evidence.
CEQA Guidelines § 15064.4 allow a lead agency to determine the significance of a project's GHG
impact via a qualitative analysis (e.g., extent to which a project complies with regulations or
requirements of state/regional/local GHG plans), and/or a quantitative analysis (e.g., using model or
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methodology to estimate project emissions and compare it to a numeric threshold). So too, CEQA
Guidelines allow lead agencies to select what model or methodology to estimate GHG emissions so
long as the selection is supported with substantial evidence, and the lead agency "should explain the
limitations of the particular model or methodology selected for use." CEQA Guidelines § 15064.4(c).
CEQA Guidelines sections 15064.4(b)(3) and 15183.5(b) allow a lead agency to consider a project's
consistency with regulations or requirements adopted to implement a statewide, regional, or local
plan for the reduction or mitigation of GHG emissions.
CEQA Guidelines §§ 15064.4(b)(3) and 15183.5(b)(1) make clear qualified GHG reduction plans or
CAPs should include the following features:
(1) Inventory: Quantify GHG emissions, both existing and projected over a specified time period,
resulting from activities (e.g., projects) within a defined geographic area (e.g., lead agency
jurisdiction);
(2) Establish GHG Reduction Goal: Establish a level, based on substantial evidence, below which
the contribution to GHG emissions from activities covered by the plan would not be
cumulatively considerable;
(3) Analyze Project Types: Identify and analyze the GHG emissions resulting from specific actions
or categories of actions anticipated within the geographic area;
(4) Craft Performance Based Mitigation Measures: Specify measures or a group of measures,
including performance standards, that substantial evidence demonstrates, if implemented on
a project -by -project basis, would collectively achieve the specified emissions level;
(5) Monitoring: Establish a mechanism to monitor the CAP progress toward achieving said level
and to require amendment if the plan is not achieving specified levels;
Collectively, the above -listed CAP features tie qualitative measures to quantitative results, which in
turn become binding via proper monitoring and enforcement by the jurisdiction—all resulting in real
GHG reductions for the jurisdiction as a whole, and the substantial evidence that the incremental
contribution of an individual project is not cumulatively considerable.
Here, the DEIR's analysis of GHG impacts is unsupported by substantial evidence, as it relies on
outdated modeling. The DEIR's analysis of air quality and GHG impacts throughout the DEIR relies on
data created using CaIEEMod version 2016.3.2. (See, e.g., DEIR, 4.1-13). A newer version of this
software (currently CaIEEMod version 2020.4.0) became available prior to the release of the DEIR.
The DEIR provides no discussion or justification for use of the outdated 2016 version of the software.
The use of outdated modeling software may result in underestimation of the Project's GHG emissions,
calling the DEIR's conclusions into question.
The DEIR's reliance on inaccurate modeling also affects its analysis of air quality impacts and energy
impacts. The DEIR potentially vastly undercounts the Project's air pollutant emissions.
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Moreover, in its discussion of the GHG impact Significance Threshold chosen for its GHG analysis, the
DEIR chooses to use a target of 3.65 MTCO2e/yr per service population, stating that this screening
target was chosen as a linear interpolation between the 2020 and 2030 2017 Scoping Plan
reduction/efficiency targets based on the projected 2026 buildout of the Project. (DEIR, 4.7-10).
However, the DEIR fails to provide any reasoning for this choice in either the DEIR itself or the
Appendix I Greenhouse Gas Report. Given that the 2017 Scoping Plan has a target of 2.88 MTCO2e/yr
to be attained by 2030,11 it is unclear how a proration of GHG emissions targets between 2020 and
2030 would be consistent with meeting the goals of AB 32 and SB 32.
Response 79-h:
The GHG analysis properly utilized the CaIEEMod version 2016.3.2, which was released by SCAQMD,
CAPCOA and other California air districts on October 17, 2017, and was the most current available
version when the GHG Analysis was completed, as confirmed on page 47 of the GHG Analysis (see
DEIR Appendix I). The 2020.4.0 version referenced in this comment was not released until June 2021,
which is the same month the Draft EIR was released for public review. Accordingly, the 2020.4.0
version was not available when the GHG Analysis was commenced or completed. EIR studies, once
commenced, are not required to incorporate every new version or update of a model that may be
released thereafter. Otherwise, technical reports could be subject to never-ending rounds of
revisions to incorporate the latest model update, which would be inconsistent with the Legislature's
directive to carry out the CEQA review process "in the most efficient, expeditious manner on order to
conserve the available financial, governmental, physical, and social resources with the objective that
those resources may be better applied toward the mitigation of actual significant effects on the
environment." Public Resources Code § 21103(f).
In addition, the lead agency "has the discretion to select the model or methodology it considers the
most appropriate to enable decision makers to intelligently take into account the project's
incremental contribution to climate change." See CEQA Guidelines § 15064.4 (c). (Also see discussion
below regarding GHG mitigation measures.
If the emissions modeling was updated using the latest version of CaIEEMod, emissions would not
increase, but in fact would incrementally decrease as a result of the updated emissions factors in the
updated version, since the changes were related to increased efficiencies (Title 24, vehicle fuel
economy), lower utility intensity factors and similar changes.
Furthermore, the DEIR identifies GHG emissions as a significant and unavoidable impact, which would
be the conclusion under either version of the model. Consequently, use of different versions of the
model would not change the impact disclosure to the public.
With respect to the appropriate screening target for project -level GHG emissions, the GHG analysis
appropriately utilized a 2026 buildout year target of 3.65 MTCO2e, based on SCAQMD's "widely
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accepted screening threshold." (See DEIR Appendix 1, at pp. 44-45). As explained on page 45 of the
GHG Analysis (DEIR Appendix 1), "the City has determined that the SCAQMD's project level efficiency
threshold methodology can be used to set an appropriate significance criterion by which to determine
whether the project emits a significant amount of GHG," and "the SP threshold for the project's
buildout year of 2026 was calculated by linear interpolation between the 2020 target of 4.8
MTCO2e/year and the 2030 target of 2.88 MTCO2e/year." Thus, contrary to the assertion in this
comment, the DEIR does provide the reasoning for the significance criterion of 3.65MTCO2e per year,
consistent with the City's discretion under CEQA Guidelines § 15064.4.
Comment 79-1:
2. The DEIR is Required to Consider and Adopt All Feasible Air Quality and GHG Mitigation Measures
A fundamental purpose of an EIR is to identify ways in which a proposed project's significant
environmental impacts can be mitigated or avoided. Pub. Res. Code §§ 21002.1(a), 21061. To
implement this statutory purpose, an EIR must describe any feasible mitigation measures that can
minimize the project's significant environmental effects. PRC §§ 21002.1(a), 21100(b)(3); CEQA
Guidelines §§ 15121(a), 15126.4(a).
If the project has a significant effect on the environment, the agency may approve the project only
upon finding that it has "eliminated or substantially lessened all significant effects on the environment
where feasible"12 and find that 'specific overriding economic, legal, social, technology or other
benefits of the project outweigh the significant effects on the environment."13 "A gloomy forecast of
environmental degradation is of little or no value without pragmatic, concrete means to minimize the
impacts and restore ecological equilibrium." Environmental Council of Sacramento v. City of
Sacramento (2006) 142 Cal.App.4th 1018, 1039.
Here, the DEIR finds that the Project will have significant and unavoidable impacts on air quality and
greenhouse gas emissions, yet proposes mitigation measures that fall short of the "all feasible
mitigation measures" standard set by CEQA. Mitigation Measure AQ -2 requires future developments
to employ U.S. EPA Tier 3 construction equipment. However, it fails to justify with substantial
evidence why U.S. EPA Tier 4 Final -compliant should not be required. Further, Mitigation Measure
AQ -3 demands the use of low-VOC architectural coatings within the Project area, but the DEIR does
not contemplate the feasibility of a requirement that "Super -Complaint" architectural be utilized to
further decrease Air Quality impacts.
Additionally, the DEIR notes that the Project will require the "design [of] building shells and building
components... to meet 2019 Title 24 Standards," (DEIR, 4.1-14), but does not specify which standards
it is specifically referring to—energy efficiency standards or CalGreen building standards. Though the
DEIR states that both should apply, it does not state the Project's level of compliance with Tile 24
standards. The Title 24 "CalGreen" building standards include two different standard "tiers" (Tier 1
and Tier 2) for both residential and non-residential buildings. (Cal. Code of Regulations, Title 24, Part
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11, Appendix A4 at A4.601 and Appendix A5 at A5.601). The DEIR does not address which tier is
applicable within the Project's specific plan area, and does not state that that the more stringent Tier
2 standards for residential and non-residential development should be followed. The City should
reevaluate the mitigation measures proposed in the DEIR to ensure the adoption of all feasible
mitigation measures as required by CEQA.
Response 79-i:
The comment incorrectly states that the EIR determined that impacts to Air Quality will be significant.
Although the comment suggests two additional and more stringent air quality mitigation measures,
no further air quality mitigation measures are required or warranted because with implementation
of the mitigation measures identified in the EIR, along with all applicable SCAQMD regulatory
requirements, impacts of the project on air quality will be reduced to less than significant levels, and
the project will not have any significant and unavoidable air quality impacts (see DEIR at pp. 4.2-42 —
4.2-44).
The comment also questions the project's "level of compliance" with 2019 Title 24 building standards.
As set forth in La Quinta Municipal Code Section 8.07.010, the City has adopted "each and all of the
regulations, provisions, conditions and terms" of the 2019 California Green Building Standards Code.
Pursuant to LQMC section 8.02.010, the City also adopted the 2019 California Building Code. The
project is subject to and will comply with all applicable requirements of both the California Building
Code and CalGreen Building Code. As stated above, by complying with all applicable regulatory
requirements and implementing Mitigation Measures AQ -1 through AQ -3, the project will reduce
impacts to less than significant levels and avoid any significant air quality impacts.
With respect to GHG emissions, the comment raises no questions or objections with respect to any
of the GHG mitigation measures identified in the Draft EIR. The DEIR identifies mitigation measures
that mitigate impacts from GHG emissions to a level of less than significant, but conservatively
considers GHG emissions to be significant and unavoidable because "the use of carbon credits has
not been broadly adopted in the Coachella Valley." Contrary to the assertion in this comment, the
DEIR did not fail to identify measures to adequately mitigate all GHG impacts, but rather, identified
mitigation measures that could reduce the GHG impacts to a less than significant level, and also
concluded that without a longer track record of using carbon credits in the Coachella Valley as
mitigation for private development projects, the impact should be conservatively identified as
significant and unavoidable in case the proposed mitigation proves infeasible for any reason. This
approach serves one of the fundamental purposes of an EIR, which is to fully and robustly disclose
potential impacts to agency decision -makers and the public, rather than under -disclose such impacts
in the hope that untested mitigation will render such impacts less than significant.
Comment 79-j:
3. The DEIR Improperly Labels Mitigation Measures as "Project Design Features"
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The DEIR improperly labels mitigation measures for "Project Design Features" or "PDFs" which the
DEIR purports will reduce environmental impacts. (See, e.g., DEIR, 4.1-13 through 4.1-15 (Air Quality);
see also DEIR, 4.5-18 through 4.5-19 (Energy); DEIR, 4.7-11 through 13 (Greenhouse Gas Emissions).)
Many of the DEIR's conclusions regarding mitigation of environmental impacts below levels of
significance rely on the implementation of these PDFs, and that as such no additional mitigation is
required.
However, it is established that "'[a]voidance, minimization and / or mitigation measure' ... are not
'part of the project.' ... compressing the analysis of impacts and mitigation measures into a single
issue . . disregards the requirements of CEQA." (Lotus v. Department of Transportation (2014) 223
Cal. App. 4th 645, 656.)
When "an agency decides to incorporate mitigation measures into its significance determination, and
relies on those mitigation measures to determine that no significant effects will occur, that agency
must treat those measures as though there were adopted following a finding of significance." (Lotus,
supra, 223 Cal. App. 4th at 652 [citing CEQA Guidelines § 15091(a)(1) and Cal. Public Resources Code
§ 21081(a)(1).])
By labeling mitigation measures as project design features, the City violates CEQA by failing to disclose
"the analytic route that the agency took from the evidence to its findings." (Cal. Public Resources
Code § 21081.5; CEQA Guidelines § 15093; Village Laguna of Laguna Beach, Inc. v. Board of
Supervisors (1982) 134 Cal. App. 3d 1022, 1035 [quoting Topanga Assn for a Scenic Community v.
County of Los Angeles (1974) 11 Cal. 3d 506, 515.])
The DEIR's use of "Project Design Features" further violates CEQA because such measures would not
be included in the Project's Mitigation Monitoring and Reporting Program CEQA requires lead
agencies to adopt mitigation measures that are fully enforceable and to adopt a monitoring and/or
reporting program to ensure that the measures are implemented to reduce the Project's significant
environmental effects to the extent feasible. (PRC § 21081.6; CEQA Guidelines § 15091(d).) Though
they are presumably enforceable by the City pursuant to the terms of the Project's Development
Agreement, the PDFs should be properly adopted as mitigations and subject to a mitigation
monitoring and reporting program under CEQA.
Response 79- j:
First, the DEIR clearly distinguishes between PDFs, which are a part of the project being proposed by
the applicant and explicitly listed in the Specific Plan, thus providing assurance as to their
implementation, and mitigation measures, which are identified to lessen or avoid significant impacts
of the project. Nothing in CEQA precludes consideration of the characteristics of a project in
evaluating its environmental effects. Moreover, because some PDFs are factored into the quantitative
analysis of impacts, as required to use the CaIEEMod quantitative modeling for air quality and GHG
impacts, all PDFs identified in the DEIR are also being made fully enforceable by the City through the
project Development Agreement, as disclosed in the EIR. The Coral Mountain Specific Plan lists PDFs
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in Section 1.7 of the document included to reduce GHG emissions and promote energy efficiency
project -wide through sustainability features. If the Specific Plan is approved by the City, the project
would be required to implement the PDFs in order to be consistent with the Specific Plan.
In addition, the commenter's reliance on Lotus is misplaced. In that case, the Lead Agency failed to
complete the analysis required to determine the level of significance of the impacts on trees,
specifically redwood trees. Here, the EIR fully discloses the potential impacts associated with air
quality, energy and greenhouse gas emissions, and as a result of that analysis, determines whether
impacts are or are not significant, leading to the imposition of mitigation measures. Unlike Lotus, the
City correctly analyzed the impacts and determined mitigation measures based on those impacts.
Comment 79-k:
4. The DEIR Fails to Support Its Findings on Population and Housing and Recreation with Substantial
Evidence
The City's Notice of Preparation ("NOP") concluded that the Project will have a less than significant
impact on population and housing, and thus precluded the DEIR from undertaking any further analysis
of the direct or indirect effects of the Project on population growth in the City. Thus, the DEIR does
not analyze the issue. Analysis of Population and Housing impacts was ruled out by NOP, on the
grounds that projected population growth related to the Project still puts the City under its 2035
population forecast. (DEIR, Appendix A, NOP at pp. 39-40.) La Quinta's General Plan Environmental
Impact Report forecasts a population of 46,297 people by 2035 (Id.), whereas predicted growth
related to the project is 1,698 new residents, (DEIR, 6-6), raising the population to 42,358 (2,181 new
residents in the NOP (raising the population to 42,841)). However, SCAG's comment on the City's NOP
forecasts a lower population of 45,034 by 2035. (DEIR, Appendix A, Letter from Southern California
Association of Governments to Nicole Sauviat Criste (April 1, 2021) at p. 4.)
The Project will ultimately result in a net increase in housing, and may have cumulatively considerable
impacts with other housing projects in the area, especially the adjacent Andalusia project. An EIR's
discussion of cumulative impacts is required by CEQA Guidelines §15130(a). The determination of
whether there are cumulative impacts in any issue area should be determined based on an
assessment of the project's incremental effects "viewed in connection with the effects of past
projects, the effects of other current projects, and the effects of probable future projects." (CEQA
Guidelines §15065(a)(3); Banning Ranch Conservancy v City of Newport Beach (2012) 211 Cal. App.
4th 1209, 1228; see also CEQA Guidelines §15355(b).)
The DEIR demurs on any cumulative impacts analysis based on the assumption that the Project "is
not anticipated to result in an indirect growth inducing impact because the existing infrastructure has
been sized to accommodate long term growth... and because the projected population growth is
already included in the City of La Quinta's General Plan." (DEIR, 6-7). The DEIR cannot simply ignore
the fact that 1,698 new residents will potentially be drawn to the City by the Project and not consider
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the cumulative effect of that projected population growth with that of other pending projects. This is
a potentially significant impact that the DEIR should analyze.
In addition, neither the DEIR nor the NOP contain any substantive discussion of Recreation impacts.
(See NOP at pp. 41-42; DEIR, 6-7 through 6-8). The CEQA Guidelines identify a threshold of significance
related to whether or not a project will include recreational facilities or require the construction or
expansion of recreational facilities that might have an adverse physical effect on the environment.
The Project dedicates 23.6 acres of previously -open space to the development of recreational
facilities on in the Project area, including the potential development of rope courses. This has
reasonably foreseeable environmental impacts and requires analysis in the DEIR. Payment of Quimby
fees (a mitigation) does not excuse the DEIR from analysis of environmental impacts the Project will
have via the creation of recreational spaces.
Response 79-k:
Contrary to the commenter's assertion, the DEIR and the Initial Study circulated with the NOP both
addressed these subjects. As set forth on pages 6-6 and 6-7 of the DEIR, the project will add
approximately 1,698 new residents to the City, but this growth is already fully accounted for in the
City's General Plan and the project is not installing infrastructure that will remove barriers allowing
or facilitating additional growth. Further, the project is proposed on a property for which an approved
Specific Plan exists, which permits up to 750 residential units, and which has been included in the
City's General Plan Land Use plan since its annexation approximately 20 years ago. Therefore, the
project will not induce substantial unplanned population growth, nor will it displace substantial
numbers of existing people or housing (as the project site is currently vacant, undeveloped land).
Likewise, the DEIR discusses the project's potential to increase the use of existing parks and
recreational facilities on pages 6-7 and 6-8 of the DEIR and concludes that the project will not have a
significant effect because it is constructing substantial recreational amenities for project residents
and guests, and because the project will pay Quimby fees and other development impact fees to help
fund the development of other types of public recreational facilities in the City. The onsite
recreational facilities are included in the project description analyzed in the DEIR, and any potentially
significant impacts of those facilities are addressed in Chapter 4 of the DEIR.
Comment 79-1:
F. The DEIR Fails to Demonstrate Consistency with SCAG's RTP/SCS Plans
Senate Bill No. 375 requires regional planning agencies to include a sustainable communities strategy
in their regional transportation plans. Gov. Code § 65080, sub.(b)(2)(B).) CEQA Guidelines § 15125(d)
provides that an EIR "shall discuss any inconsistencies between the proposed project and...regional
plans. Such regional plans include...regional transportation plans." Thus, CEQA requires analysis of
any inconsistencies between the Project and the relevant RTP/SCS plan.
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In April 2012, SCAG adopted its 2012-2035 RTP/ SCS ("2012 RTP/SCS"), which proposed specific land
use policies and transportation strategies for local governments to implement that will help the
region achieve GHG emission reductions of 9 percent per capita in 2020 and 16 percent per capita in
2035.
In April 2016, SCAG adopted the 2016-2040 RTP/SCS ("2016 RTP/SCS")14, which incorporates and
builds upon the policies and strategies in the 2012 RTP/SCS15, that will help the region achieve GHG
emission reductions that would reduce the region's per capita transportation emissions by eight
percent by 2020 and 18 percent by 2035.16 SCAG's RTP/SCS plan is based upon the same
requirements outlined in CARB's 2017 Scoping Plan and SB 375.
On September 3, 2020, SCAG adopted the 2020 — 2045 RTP / SCS titled Connect SoCal ("2020 RTP/
SCS").17 The 2020 RTP / SCS adopts policies and strategies aimed at reducing the region's per capita
greenhouse gas emissions by 8% below 2005 per capita emissions levels by 2020 and 19% below 2005
per capita emissions levels by 2035. 18
For both the 2012 and 2016 RTP/SCS, SCAG prepared Program Environmental Impact Reports ("PEIR")
that include Mitigation Monitoring and Reporting Programs ("MMRP") that list project -level
environmental mitigation measures that directly and/or indirectly relate to a project's GHG impacts
and contribution to the region's GHG emissions.19 These environmental mitigation measures serve
to help local municipalities when identifying mitigation to reduce impacts on a project -specific basis
that can and should be implemented when they identify and mitigate project -specific environmental
impacts.
Here, the DEIR fails to analyze the Project's is consistency with any of SCAG's aforementioned RTP/SCS
Plans. The DEIR must demonstrate that the Project is consistent with the RTP/SCS Plans' project -level
goals, including:
Land Use and Transportation
• Providing transit fare discounts2l;
• Implementing transit integration strategies22; and
• Anticipating shared mobility platforms, car -to -car communications, and automated vehicle
technologies
GHG Emissions Goals
• Reduction in emissions resulting from a project through implementation of project features,
project design, or other measures, such as those described in Appendix F of the State CEQA
Guidelines,25 such as:
o Potential measures to reduce wasteful, inefficient and unnecessary consumption of energy
during construction, operation, maintenance and/or removal. The discussion should explain
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why certain measures were incorporated in the Project and why other measures were
dismissed.
o The potential siting, orientation, and design to minimize energy consumption, including
transportation energy.
o The potential for reducing peak energy demand.
o Alternate fuels (particularly renewable ones) or energy systems.
o Energy conservation which could result from recycling efforts.
• Off-site measures to mitigate a project's emissions.
• Measures that consider incorporation of Best Available Control Technology (BACT) during
design, construction and operation of projects to minimize GHG emissions, including but not
limited to:
o Use energy and fuel-efficient vehicles and equipment;
o Deployment of zero- and/or near zero emission technologies;
o Use cement blended with the maximum feasible amount of flash or other materials that
reduce GHG emissions from cement production;
o Incorporate design measures to reduce GHG emissions from solid waste management through
encouraging solid waste recycling and reuse;
o Incorporate design measures to reduce energy consumption and increase use of renewable
energy;
o Incorporate design measures to reduce water consumption;
o Use lighter -colored pavement where feasible;
o Recycle construction debris to maximum extent feasible;
• Adopting employer trip reduction measures to reduce employee trips such as vanpool and
carpool programs, providing end -of -trip facilities, and telecommuting programs.
• Designate a percentage of parking spaces for ride -sharing vehicles or high -occupancy vehicles,
and provide adequate passenger loading and unloading for those vehicles;
• Land use siting and design measures that reduce GHG emissions, including:
o Measures that increase vehicle efficiency, encourage use of zero and low emissions vehicles,
or reduce the carbon content of fuels, including constructing or encouraging construction of
electric vehicle charging stations or neighborhood electric vehicle networks, or charging for
electric bicycles; and
o Measures to reduce GHG emissions from solid waste management through encouraging solid
waste recycling and reuse.
Hydrology & Water Quality Goals
• Incorporate measures consistent in a manner that conforms to the standards set by regulatory
agencies responsible for regulating water quality/supply requirements, such as:
o Reduce exterior consumptive uses of water in public areas, and should promote reductions in
private homes and businesses, by shifting to drought -tolerant native landscape
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plantings(xeriscaping), using weatherbased irrigation systems, educating other public
agencies about water use, and installing related water pricing incentives.
o Promote the availability of drought -resistant landscaping options and provide information on
where these can be purchased. Use of reclaimed water especially in median landscaping and
hillside landscaping can and should be implemented where feasible.
o Implement water conservation best practices such as low -flow toilets, water -efficient clothes
washers, water system audits, and leak detection and repair.
o Ensure that projects requiring continual dewatering facilities implement monitoring systems
and long-term administrative procedures to ensure proper water management that prevents
degrading of surface water and minimizes, to the greatest extent possible, adverse impacts
on groundwater for the life of the project. Comply with appropriate building codes and
standard practices including the Uniform Building Code.
o Maximize, where practical and feasible, permeable surface area in existing urbanized areas to
protect water quality, reduce flooding, allow for groundwater recharge, and preserve wildlife
habitat. Minimized new impervious surfaces to the greatest extent possible, including the use
of in -lieu fees and off-site mitigation.
o Avoid designs that require continual dewatering where feasible.
o Where feasible, do not site transportation facilities in groundwater recharge areas, to prevent
conversion of those areas to impervious surface.
• Incorporate measures consistent in a manner that conforms to the standards set by regulatory
agencies responsible for regulating and enforcing water quality and waste discharge
requirements, such as:
o Complete, and have approved, a Stormwater Pollution Prevention Plan ("SWPPP") before
initiation of construction.
o Implement Best Management Practices to reduce the peak stormwater runoff from the
project site to the maximum extent practicable.
o Comply with the Caltrans stormwater discharge permit as applicable; and identify and
implement Best Management Practices to manage site erosion, wash water runoff, and spill
control.
o Complete, and have approved, a Standard Urban Stormwater Management Plan, prior to
occupancy of residential or commercial structures.
o Ensure adequate capacity of the surrounding stormwater system to support stormwater
runoff from new or rehabilitated structures or buildings.
o Prior to construction within an area subject to Section 404 of the Clean Water Act, obtain all
required permit approvals and certifications for construction within the vicinity of a
watercourse (e.g., Army Corps § 404 permit, Regional Waterboard § 401 permit, Fish &
Wildlife § 401 permit).
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o Where feasible, restore or expand riparian areas such that there is no net loss of impervious
surface as a result of the project.
o Install structural water quality control features, such as drainage channels, detention basins,
oil and grease traps, filter systems, and vegetated buffers to prevent pollution of adjacent
water resources by polluted runoff where required by applicable urban stormwater runoff
discharge permits, on new facilities.
o Provide structural stormwater runoff treatment consistent with the applicable urban
stormwater runoff permit where Caltrans is the operator, the statewide permit applies.
o Provide operational best management practices for street cleaning, litter control, and catch
basin cleaning are implemented to prevent water quality degradation in compliance with
applicable stormwater runoff discharge permits; and ensure treatment controls Are in place
as early as possible, such as during the acquisition process for rights-of-way, not just later
during the facilities design and construction phase.
o Comply with applicable municipal separate storm sewer system discharge permits as well as
Caltrans' stormwater discharge permit including long-term sediment control and drainage of
roadway runoff.
o Incorporate as appropriate treatment and control features such as detention basins,
infiltration strips, and porous paving, other features to control surface runoff and facilitate
groundwater recharge into the design of new transportation projects early on in the process
to ensure that adequate acreage and elevation contours are provided during the right-of-way
acquisition process.
o Design projects to maintain volume of runoff, where any downstream receiving water body
has not been designed and maintained to accommodate the increase in flow velocity, rate,
and volume without impacting the water's beneficial uses. Pre -project flow velocities, rates,
volumes must not be exceeded. This applies not only to increases in stormwater runoff from
the project site, but also to hydrologic changes induced by flood plain encroachment. Projects
should not cause or contribute to conditions that degrade the physical integrity or ecological
function of any downstream receiving waters.
o Provide culverts and facilities that do not increase the flow velocity, rate, or volume and/or
acquiring sufficient storm drain easements that accommodate an appropriately vegetated
earthen drainage channel.
o Upgrade stormwater drainage facilities to accommodate any increased runoff volumes. These
upgrades may include the construction of detention basins or structures that will delay peak
flows and reduce flow velocities, including Expansion and restoration of wetlands and riparian
buffer areas. System designs shall be completed to eliminate increases in peak flow rates from
current levels.
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o Encourage Low Impact Development ("LID") and incorporation of natural spaces that reduce,
treat, infiltrate and manage stormwater runoff flows in all new developments, where practical
and feasible.
• Incorporate measures consistent with the provisions of the Groundwater Management Act and
implementing regulations, such as:
o For projects requiring continual dewatering facilities, implement monitoring systems and long-
term administrative procedures to ensure proper water management that prevents degrading
of surface water and minimizes, to the greatest extent possible, adverse impacts on
groundwater for the life of the project, Construction designs shall comply with appropriate
building codes and standard practices including the Uniform Building Code.
o Maximize, where practical and feasible, permeable surface area in existing urbanized areas to
protect water quality, reduce flooding, allow for groundwater recharge, and preserve wildlife
habitat. Minimize to the greatest extent possible, new impervious surfaces, including the use
of inlieu fees and off-site mitigation.
o Avoid designs that require continual dewatering where feasible.
o Avoid construction and siting on groundwater recharge areas, to prevent conversion of those
areas to impervious surface.
o Reduce hardscape to the extent feasible to facilitate groundwater recharge as appropriate.
• Incorporate mitigation measures to ensure compliance with all federal, state, and local
floodplain regulations, consistent with the provisions of the National Flood Insurance Program,
such as:
o Comply with Executive Order 11988 on Floodplain Management, which requires avoidance of
incompatible floodplain development, restoration and preservation of the natural and
beneficial floodplain values, and maintenance of consistency with the standards and criteria
of the National Flood Insurance Program.
o Ensure that all roadbeds for new highway and rail facilities be elevated at least one foot above
the 100 -year base flood elevation. Since alluvial fan flooding is not often identified on FEMA
flood maps, the risk of alluvial fan flooding should be evaluated and projects should be sited
to avoid alluvial fan flooding. Delineation of floodplains and alluvial fan boundaries should
attempt to account for future hydrologic changes caused by global climate change.
Transportation, Traffic, and Safety
• Institute teleconferencing, telecommute and/or flexible work hour programs to reduce
unnecessary employee transportation.
• Create a ride -sharing program by designating a certain percentage of parking spaces for ride
sharing vehicles, designating adequate passenger loading and unloading for ride sharing
vehicles, and providing a web site or message board for coordinating rides.
• Provide a vanpool for employees.
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• Provide a Transportation Demand Management (TDM) plan containing strategies to reduce on-
site parking demand and single occupancy vehicle travel. The TDM shall include strategies to
increase bicycle, pedestrian, transit, and carpools/vanpool use, including:
o Inclusion of additional bicycle parking, shower, and locker facilities that exceed the
requirement.
o Direct transit sales or subsidized transit passes.
o Guaranteed ride home program.
o Pre-tax commuter benefits (checks).
o On-site car -sharing program (such as City Car Share, Zip Car, etc.).
o On-site carpooling program.
o Distribution of information concerning alternative transportation options
o Parking spaces sold/leased separately.
o Parking management strategies; including attendant/valet parking and shared parking spaces.
• Promote ride sharing programs e.g., by designating a certain percentage of parking spaces for
high -occupancy vehicles, providing larger parking spaces to accommodate vans used for ride -
sharing, and designating adequate passenger loading and unloading and waiting areas.
• Encourage the use of public transit systems by enhancing safety and cleanliness on vehicles and
in and around stations, providing shuttle service to public transit, offering public transit
incentives and providing public education and publicity about public transportation services.
• Build or fund a major transit stop within or near transit development upon consultation with
applicable CTCs.
• Work with the school districts to improve pedestrian and bike access to schools and to restore
or expand school bus service using lower -emitting vehicles.
• Purchase, or create incentives for purchasing, low or zero -emission vehicles.
• Provide the necessary facilities and infrastructure to encourage the use of low or zero -emission
vehicles.
• Promote ride sharing programs, if determined feasible and applicable by the Lead Agency,
including:
o Designate A certain percentage of parking spaces for ride -sharing vehicles. o Designate
adequate passenger loading, unloading, and waiting areas for ride -sharing vehicles.
o Provide a web site or message board for coordinating shared rides.
o Encourage private, for-profit community car -sharing, including parking spaces for car share
vehicles at convenient locations accessible by public transit.
o Hire or designate a rideshare coordinator to develop and implement ridesharing programs.
• Support voluntary, employer -based trip reduction programs, if determined feasible and
applicable by the Lead Agency, including:
o Provide assistance to regional and local ridesharing organizations.
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o Advocate for legislation to maintain and expand incentives for employer ridesharing
programs.
o Require the development of Transportation Management Associations for large employers
and commercial/ industrial complexes.
o Provide public recognition of effective programs through awards, top ten lists, and other
mechanisms.
• Implement a "guaranteed ride home" program for those who commute by public transit,
ridesharing, or other modes of transportation, and encourage employers to subscribe to or
support the program.
• Encourage and utilize shuttles to serve neighborhoods, employment centers and major
destinations.
• Create a free or low-cost local area shuttle system that includes a fixed route to popular tourist
destinations or shopping and business centers.
• Work with existing shuttle service providers to coordinate their services.
• Facilitate employment opportunities that minimize the need for private vehicle trips, such as
encourage telecommuting options with new and existing employers, through project review and
incentives, as appropriate.
• Organize events and workshops to promote GHG-reducing activities.
• Implement a Parking Management Program to discourage private vehicle use, including:
o Encouraging carpools and vanpools with preferential parking and a reduced parking fee.
o Institute a parking cash -out program or establish a parking fee for all single -occupant vehicles.
Utilities & Service Systems
• Integrate green building measures consistent with CALGreen (Title 24, part 11), U.S. Green
Building Council's Leadership in Energy and Environmental Design, energy Star Homes, Green
Point Rated Homes, and the California Green Builder Program into project design including, but
not limited to the following:
o Reuse and minimization of construction and demolition (C&D) debris and diversion of C&D
waste from landfills to recycling facilities.
o Inclusion of a waste management plan that promotes maximum C&D diversion.
o Development of indoor recycling program and space.
o Discourage exporting of locally generated waste outside of the SCAG region during the
construction and implementation of a project. Encourage disposal within the county where
the waste originates as much as possible. Promote green technologies for long-distance
transport of waste (e.g., clean engines and clean locomotives or electric rail for waste -by -rail
disposal systems) and consistency with SCAQMD and 2016 RTP/SCS policies can and should
be required.
o Develop ordinances that promote waste prevention and recycling activities such as: requiring
waste prevention and recycling efforts at all large events and venues; implementing recycled
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content procurement programs; and developing opportunities to divert food waste away from
landfills and toward food banks and composting facilities.
o Develop alternative waste management strategies such as composting, recycling, and
conversion technologies.
o Develop and site composting, recycling, and conversion technology facilities that have
minimum environmental and health impacts.
o Require the reuse and recycle construction and demolition waste (including, but not limited
to, soil, vegetation, concrete, lumber, metal, and cardboard).
o Integrate reuse and recycling into residential industrial, institutional and commercial projects.
o Provide recycling opportunities for residents, the public, and tenant businesses.
o Provide education and publicity about reducing waste and available recycling services.
o Implement or expand city or county -wide recycling and composting programs for residents
and businesses. This could include extending the types of recycling services offered (e.g., to
include food and green waste recycling) and providing public education and publicity about
recycling services.
The DEIR fails to mention or demonstrate consistency with the above listed measures and strategies
of the SCAG RTP/SCS Plans. The DEIR should be revised to indicate what specific project -level
mitigation measures that will be followed to demonstrate consistency with the RTP/SCS Plans.
Response 79-1:
The Draft EIR addresses consistency with the SCAG 2016-2040 Regional Transportation
Plan/Sustainable Communities Strategy (SCAG RTP/SCS) developed pursuant to SB No. 375 in the Air
Quality, Energy, GHG Emissions and Transportation Chapters.
As explained on pages 4.1-15 through 4.1-18 of the DEIR, SCAQMD's 2016 Air Quality Management
Plan (AQMP) incorporates the information in the SCAG 2016 RTP/SCS, and SCAQMD provides detailed
criteria for evaluating a project's consistency with the AQMP, which is provided on these pages of the
DEIR. (Also see DEIR pp. 4.5-10 — 4.5-15 and 4.5-34 — 4.5-38, describing the relationship between the
SCAG 2016-2040 RTP/SCS, the 2016 AQMP, and the City of La Quinta GHG Reduction Plan, as well as
the project's consistency with the goals and standards in those plans.)
The project's consistency with the SCAG 2016-2040 RTP/SCS developed pursuant to SB No. 375 is also
addressed in detail in Section 4.7, GHG Emissions, of the DEIR. As explained on page 4.7-5, the
California Air Resources Board (CARB), in consultation with SCAG and other Metropolitan Planning
Organizations, provided regional reduction targets for GHG emissions for the years 2020 and 2035,
to implement the land use allocations in the regional transportation plans adopted pursuant to SB
No. 375. The 2017 Scoping Plan Update prepared by CARB incorporates these sustainable
communities strategies. On pages 4.7-20 through 4.7-25, the DEIR provides a thorough analysis of
the project's consistency with CARB's 2017 Scoping Plan, including the sustainability strategies
incorporated therein.
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Finally, the DEIR further addresses the project's consistency with the transportation goals and related
policies in the SCAG 2016-2040 RTP/SCS in Section 4.13, Transportation, at pages 4.13-5 through
4.13-8 and 4.13-47 through 4.13-48. As discussed therein, CVAG's Regional Transportation Plan is
implemented, in part, through Congestion Management Plans (CMPs), which link land use,
transportation and air quality strategies together with programs to allocate transportation funds to
alleviate traffic congestion and reduce related impacts such as air quality and GHG emissions. The
Riverside County Transportation Commission (RCTC) is responsible for implementing the CMP, in
consultation with CVAG, the City of La Quinta and other local agencies, including through the
collection and use of its Transportation Uniform Mitigation Fee (TUMF) and Measure A funds to
construct transportation improvements, consistent with the sustainable communities strategies
developed pursuant to SB No. 375. The project is required to pay both TUMF and the City's
development impact fees to fund such improvements, and also incorporates project design features
that implement the alternative transportation strategies included in the 2016 RTP/SCS and the 2016
AQMP (see DEIR at pp. 4.13-47 — 4.13-48).
This comment recites numerous SCAG policies but fails to identify any specific objections or concerns
regarding the DEIR's detailed analysis of the project's consistency with the sustainable communities
strategies developed pursuant to SB No. 375, as discussed above.
In this comment, the commenter also requests incorporating a general list of measures conforming
to the regulatory standards regarding hydrology and water quality. The provided list is only partially
applicable to the project and does not contribute any content that has not already been covered in
Section 4.9, Hydrology and Water Quality, of the DEIR.
As discussed on page 4.9-18 of the DEIR, the project is required to develop and implement a City -
approved project -specific Water Quality Management Plan (WQMP) to comply with the current
standards of the Whitewater River Region Water Quality Management Plan for Urban Runoff,
Whitewater River Watershed Municipal Separate Storm Sewer System (MS4) Permit, and Section
8.70.070 of the City of La Quinta Municipal Code, all of which stem from the Clean Water Act (CWA)
and the National Pollutant Discharge Elimination System (NPDES) program. The list of hydrology and
water quality measures mandated in the Whitewater River Region as part of the project specific
WQMP are discussed on pages 4.18 through 4.9-21 and 4.9-28 of the DEIR.
The evaluation of how the project complies with the water quality standards and waste discharge
requirements is provided on pages 4.9-16 through 4.9-17 of the DEIR. This discussion covers the
permit procedures and compliance plan parameters regarding the NPDES General Permit for Storm
Water Discharges Associated with Construction and Land Disturbance Activities, Order No. 2009-
0009-DWQ, as amended by 2010-0014-DWQ and 2012-006-DWQ.
Pages 4.9-20 through 4.9-22 of the DEIR address groundwater quality and recharge methods to be
implemented by the project in relation to the Indio Subbasin resources. This includes avoiding any
physical interference with any existing recharge infrastructure associated with the regional
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groundwater management efforts. Moreover, this discussion identifies the low impact development
(LID), structural and non-structural source control measures aimed at protecting groundwater quality,
as a function of the project specific WQMP.
Pages 4.9-24 through 4.9-26 of the DEIR address the aspect of stormwater management, flood control
and floodplain compliance, as applicable to the project location under the City's engineering
standards and Flood Insurance Rate Map (FIRM) documentation from the Federal Emergency
Management Agency (FEMA).
Therefore, contrary to the commenter's assertion, the project's consistency with SCAG sustainable
communities strategies have been integrated into the EIR in the resource issue area where they apply.
In addition, Section 3 of this Final EIR contains a summary of this consistency analysis. Also see
Response 4-a.
Comment 79-m:
G. Failure to Include Consultation and Preparation Section
CEQA requires all EIRs contain certain contents. See CEQA Guidelines §§ 15122 — 15131. CEQA
expressly requires an EIR "identify all federal, state, or local agencies, other organizations, and private
individuals consulted in preparing the draft EIR, and the persons, firm, or agency preparing the draft
EIR, by contract or other authorization." CEQA Guidelines § 15129. This information is critical to
demonstrating a lead agency fulfilled its obligation to "consult with, and obtain comments from, each
responsible agency, trustee agency, any public agency that has jurisdiction by law with respect to the
project, and any city or county that borders on a city or county within which the project is located ...."
PRC § 21104(a).
Failure to provide sufficient information concerning the lead agency's consultation efforts could
undermine the legal sufficiency of an EIR. Courts determine de novo whether a CEQA environmental
document sufficiently discloses information required by CEQA as "noncompliance with the
information disclosure provisions" of CEQA is a failure to proceed in a manner required by law. PRC §
21005(a); see also Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502, 515.
Here, the DEIR fails to identify which federal agencies, state agencies, local agencies, or other
organizations, if any, that were consulted in the preparation of this DEIR. The DEIR should be revised
to identify the organizations the City consulted with in the preparation of the DEIR in compliance with
Section 21104(a) of the Public Resources Code.
Response 79-m:
As explained in CEQA Guidelines §§ 15082 — 15087, the consultation process for an EIR includes the
Notice of Preparation and all response thereto, consultation during the 45 -day public review period,
as well as any additional informal consultation by the lead agency. Here, the NOP and all responses
thereto are provided in Appendix A of the DEIR, which include consultation with Riverside County
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Airport Land Use Commission, Desert Recreation District, Imperial Irrigation District (IID), Native
American Heritage Commission, Riverside County Flood Control and Water Conservation District,
SCAG, and SCAQMD. During the drafting of the DEIR, IID and the Coachella Valley Water District
(CVWD) were consulted to determine plans for the project's connection to the existing offsite
substation, and domestic water and wastewater systems. In addition, the Final EIR will include a list
of all public agencies and other organizations who consulted with the City regarding the EIR, including
during the 45 -day public review period pursuant to CEQA Guideline 15086.
This comment also cites to Public Resources Code §§ 21104 and 21105, but these statutes apply only
to state lead agencies, not local agencies like the City of La Quinta (for the avoidance of doubt, the
City did comply with the consultation requirements set forth in Public Resources Code § 21153, which
are consistent with the CEQA Guidelines cited above).
Comment 79-n:
II. THE PROJECT VIOLATES THE STATE PLANNING AND ZONING LAW AS WELL AS THE CITY'S GENERAL
PLAN
A. Background Regarding the State Planning and Zoning Law
Each California city and county must adopt a comprehensive, long-term general plan governing
development. Napa Citizens for Honest Gov. v. Napa County Bd. of Supervisors (2001) 91 Cal.App.4th
342, 352, citing Gov. Code §§ 65030, 65300. The general plan sits at the top of the land use planning
hierarchy, and serves as a "constitution" or "charter" for all future development. DeVita v. County of
Napa (1995) 9 Ca1.4th 763, 773; Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Ca1.3d
531, 540.
General plan consistency is "the linchpin of California's land use and development laws; it is the
principle which infused the concept of planned growth with the force of law." See Debottari v. Norco
City Council (1985) 171 Cal.App.3d 1204, 1213.
State law mandates two levels of consistency. First, a general plan must be internally or "horizontally"
consistent: its elements must "comprise an integrated, internally consistent and compatible
statement of policies for the adopting agency." See Gov. Code § 65300.5; Sierra Club v. Bd. of
Supervisors (1981) 126 Cal.App.3d 698, 704. A general plan amendment thus may not be internally
inconsistent, nor may it cause the general plan as a whole to become internally inconsistent. See
DeVita, 9 Ca1.4th at 796 fn. 12.
Second, state law requires "vertical" consistency, meaning that zoning ordinances and other land use
decisions also must be consistent with the general plan. See Gov. Code § 65860(a)(2) [land uses
authorized by zoning ordinance must be "compatible with the objectives, policies, general land uses,
and programs specified in the [general] plan."]; see also Neighborhood Action Group v. County of
Calaveras (1984) 156 Cal.App.3d 1176, 1184. A zoning ordinance that conflicts with the general plan
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or impedes achievement of its policies is invalid and cannot be given effect. See Lesher, 52 Ca1.3d at
544.
State law requires that all subordinate land use decisions, including conditional use permits, be
consistent with the general plan. See Gov. Code § 65860(a)(2); Neighborhood Action Group, 156
Cal.App.3d at 1184.
A project cannot be found consistent with a general plan if it conflicts with a general plan policy that
is "fundamental, mandatory, and clear," regardless of whether it is consistent with other general plan
policies. See Endangered Habitats League v. County of Orange (2005) 131 Cal.App.4th 777, 782-83;
Families Unafraid to Uphold Rural El Dorado County v. Bd. of Supervisors (1998) 62 Cal.App.4th 1332,
1341-42 ("FUTURE").
Moreover, even in the absence of such a direct conflict, an ordinance or development project may
not be approved if it interferes with or frustrates the general plan's policies and objectives. See Napa
Citizens, 91 Cal.App.4th at 378-79; see also Lesher, 52 Ca1.3d at 544 (zoning ordinance restricting
development conflicted with growth -oriented policies of general plan).
As explained in full below, the Project is inconsistent with the City's General Plan. As such, the Project
violates the State Planning and Zoning law.
Response 79-n:
This comment does not identify any alleged inconsistency between the project and the City of La
Quinta General Plan, nor does it identify a specific question or concern regarding the adequacy of the
DEIR in identifying and analyzing the potential environmental impacts of the project. For that reason,
no further response to this comment is provided.
Comment 79-o:
B. The Project is Inconsistent with the General Plan, and thus the DEIR's Conclusions Regarding
Impacts on Land Use and Planning are Unsupported by Substantial Evidence
The DEIR fail to establish the Project's consistency with several General Plan goals, policies, and
programs including the following:
• Policy LU -2.3: The City's outdoor lighting ordinance will be maintained;
• Goal LU -3 and associated policies and programs: Safe and identifiable neighborhoods that
provide a sense of place;
• Policy LU -5.1: Use development incentives to achieve a mix of housing, including affordable
housing;
• Policy CIR-1.14: Private streets shall be developed in accordance with development standards
set forth in the Municipal Code, relevant Public Works Bulletins, and other applicable
standards and guidelines;
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• Policy SC -1.2: Reduce water consumption at a minimum consistent with the Greenhouse Gas
Reduction Plan (also see Air Quality Element);
• Policy SC -1.4: Reduce Greenhouse Gas emissions at a minimum consistent with the Greenhouse
Gas Reduction Plan (also see Air Quality Element);
• Goal H-2 and associated policies and programs: Assist in the creation and provision of resources
to support housing for lower and moderate income households;
• Goal H-3 and associated policies and programs: Create a regulatory system that does not unduly
constrain the maintenance, improvement, and development of housing affordable to all La
Quinta residents;
• Goal H-5 and associated policies and programs: Provide equal housing opportunities for all
persons;
• Goal AQ -1 and associated policies and programs: A reduction in all air emissions generated
within the City;
• Goal BIO -1 and associated policies and programs: The protection and preservation of native and
environmentally significant biological resources and their habitats;
• Policy WR -1.6: Encourage the use of permeable pavements in residential and commercial
development projects;
• Goal OS -2 and associated policies and programs: Good stewardship of natural open space and
preservation of open space areas;
• Goal OS -3 and associated policies and programs: Preservation of scenic resources as vital
contributions to the City's economic health and overall quality of life;
• Policy UTL-1.3: New development shall reduce its projected water consumption rates over
"business -as -usual" consumption rates.
The Project fails to discuss its conformity with each of the aforementioned Goals, Policies, and
Programs laid out in the City's General Plan, even though the Project will have reasonably foreseeable
impacts on land use, traffic, housing and population, biological resources, vehicle trip generation, air
quality, and GHG emissions. This discussion is relevant not only to compliance with land use and
zoning law, but also with the contemplation of the Project's consistency with land use plans, policies,
and regulations adopted for the purpose of avoiding or mitigating environmental impacts.
The DEIR should be amended to include analysis of the Project's comportment with the Goals,
Policies, and Programs listed above. Further, the DEIR should be revised to analyze the Project's
consistency with the City's upcoming 6th Cycle Housing Element Update and its related Regional
Housing Needs Assessment.
Response 79-o:
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The project's consistency with the City of La Quinta General Plan, including all of the areas noted
above (with the exception of Biological Resources), are specifically addressed in Section 4.10, Land
Use and Planning, of the DEIR at pages 4.10-15 through 4.10-24. Further General Plan consistency
analysis is provided in the corresponding DEIR Chapter for each of the topic areas identified in this
comment, including Section 4.3, Biological Resources, which analyzes the project's consistency with
the CVMSHCP, as called for under General Plan Goal BIO -1 and supporting Policy BIO -1.1. The
comment does not identify or explain any specific alleged inconsistencies between the project and
the City of La Quinta General Plan, nor does it raise any questions or concerns regarding the General
Plan consistency analysis described above.
This comment also incorrectly frames the required analysis under CEQA. While the comment asserts
that "[t]he DEIR fail [sic] to establish the Project's consistency with several General Plan goals, policies,
and programs include the following ... [followed by a list of General Plan policies and goals]," it fails
to provide any substantial evidence of any inconsistencies with such goals and policies. The California
courts have consistently held that an EIR does not need to evaluate the project's consistency with
every General Plan goal, policy and program. Rather, "[b]ecause EIRs are required only to evaluate
'any inconsistencies' with plans, no analysis should be required if the project is consistent with the
relevant plans." Stop Syar Expansion v. County of Napa (2021) 63 Cal.App.4th 444, 460 (quoting
Pfeiffer v. City of Sunnyvale City Council (2011) 200 Cal.App..4th 1552, 1556; and see South of Market
Community Action Network v. City and County of San Francisco (2019) 33 Cal.App.5th 321, 352-354. -
As described above and in Response No. 79-1, the Draft EIR thoroughly analyzes the project's
consistency with the General Plan and other applicable plans.
Comment 79-p:
III. CONCLUSION
Commenters request that the City revise and recirculate the Project's DEIR and/or prepare an
environmental impact report which addresses the aforementioned concerns. If the City has any
questions or concerns, feel free to contact my Office.
Response 79-p:
As previously stated, the commenter requests that the City revise and recirculate, or prepare a new
EIR. However, the comments received on the Draft EIR, the responses thereto, and the limited
revisions made to the DEIR in response to the comments received all provide clarifications and
amplifications to the DEIR, but do not add "significant new information" as defined in CEQA
Guidelines § 15088.5. Specifically, no new information has been added that changes the DEIR in way
that would deprive the public of a meaningful opportunity to comment upon a substantial adverse
environmental effect of the project or a feasible way to mitigate or avoid such an effect, which is the
standard for recirculation under CEQA. Examples of such "significant new information" would include
a new or substantially more severe adverse environmental effect than previously disclosed in the
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Draft EIR, which is not the case here, where additional information is provided in response to the
comments to clarify or amplify the information provided in the Draft EIR with further detail or
discussion. Accordingly, recirculation of the Draft EIR is not required or appropriate here.
Please also see Response No. 79-d above for a further discussion of the standards for requiring
recirculation of a Draft EIR.
Comment 79-q:
This letter from SWAPE, which is attached to Comment Letter No. 79, purports to be a "draft technical
report explaining the significance of worker trips required for construction of land use development
projects with respect to estimation of greenhouse gas (GHG) emissions." The letter describes the
authors' understanding of how the CaIEEMod calculates construction -related VMT and asserts that a
requirement that all workers must live within 10 miles of the project site would decrease
construction -related GHG emissions by approximately 600 metric tons, or 20 MTCO2e/year on an
amortized basis.
Response 79-q:
This opinion does not identify any data or information relating to the proposed project, including the
current average commute distance for construction workers in the La Quinta area, nor does it quantify
or demonstrate that any reduction in GHG emissions would result from such a restriction for this
project location. This is particularly evident given that the letter is dated three months prior to the
release of the EIR, and in the commenter's statement that the analysis was based, in part, on a project
in the City of Claremont, California, which is located in Los Angeles County, at least 60 miles from the
proposed project. The commenter provides no substantial evidence that there is any similarity
between Claremont and La Quinta, or that the Specific Plan he analyzed is in any way consistent with
the Specific Plan proposed for the project site.
The opinion also fails to evaluate the number and specialties of available construction workers who
live within 10 miles of the project site, as well as the statutory and Constitutional validity of imposing
such a requirement on a private development project (and on qualified construction workers living
outside the 10 -mile limit). Without such information, the letter is purely speculative as to whether it
could be feasibly implemented.
In addition, even if the proposed 10 -mile limit on construction workers could legally and feasibly be
implemented, it would only reduce GHG emissions by approximately 70 MTCO2e/year according to
the authors' calculation. By comparison, the project design features incorporated into the project
reduce the GHG emissions by 4,988.36 MTCO2e/year, and Mitigation Measure GHG-1 requires the
purchase of carbon credits equal to an additional 2,400 MTCO2e/year (see DEIR pp. 4.7-17-4.7-18 and
4.7-26).
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The comment letter does not provide any substantial evidence that any portion of the project EIR has
been completed incorrectly, and no further consideration is required.
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Comment Letter No. 80: Sally Arroyo
Date: August 6, 2021
Affiliation: Area Resident
Comment 80-a:
Thank you allowing us again to be part of the process in assessing the suitability of the Coral Mountain
Resort "The Wave."
After reading through the entire DEIR carefully many times it is clearly apparent that although it seems
that the consulting firms and the City of La Quinta think they have done their due diligence with their
studies, they failed to consider the human factor --- their residents, their constituents and this
beautiful area. They are apparently only concerned with development, revenues and the allure of
world-wide recognition.
We also found the alternative comparisons interesting in that based on the findings there really is
only one alternative and that is the alternative that the developer and the City of La Quinta want, The
Wave Basin and Resort. We also found that many of the findings were deemed "less than significant."
This may be the standard term/language used within the parameters of Federal, State, County and
City study mandates, but we nearby citizens and homeowners and our opinions are not less than
significant and absolutely reject the conclusions of these findings.
Response 80-a:
The commenter's opinions are noted. The Draft EIR was written to disclose the project components
and to analyze and disclose whether the project would result in significant environmental impacts.
Findings and analyses were based on technical studies prepared by technical experts in the various
topic areas, including traffic, noise, lighting, biological resources and cultural/tribal cultural resources.
The methodologies used for the technical reports are based on local, regional and state
methodologies and satisfy CEQA criteria for determining significance thresholds. Per the CEQA
Checklist provided in Appendix G of the CEQA Guidelines, analysis of projects determines "no impact,"
"less than significant impact," "less than significant impact with the implementation of mitigation
measures," and "significant and unavoidable impacts" conclusions based on the thresholds provided
by local, regional, and state agencies, as well as technical reports generated for specific project.
Comment 80-b:
The developer purchased this property knowing the current zoning. Promises and projections were
then made at meetings held for local residents to drum up support for the project. Those who
attended those meetings have reported that they now feel they were misled. The words in some of
the correspondence were "bait and switch." The City of La Quinta appears to have bought into this
bad idea and has gone along with it by moving to allow proposed zone changes, special events and
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everything else that nearby homeowners find unacceptable. This development will have no
advantage for La Quinta residents who will not reside in the resort or use its amenities, only
disadvantages such as more traffic, more noise, more water usage from our aquifer, more light
pollution, etc. It does feel like the City and the developer are attempting to sell us on what we
absolutely don't want. Let's reject the tourist commercial zoning as well as this whole project.
Response 80-b:
The commenter's opinions are noted. Please see Responses 15-d and 17-a as they relate to the Zone
Change and processing of the proposed project.
Comment 80-c:
In an era of massive climate change the City of La Quinta should still be asking the major question of
where the water would come from to sustain the resort. Surf parks require massive amounts of water
and this resort will waste even more. This is irresponsible. We have seen estimates of 18 million
gallons to fill the pool. In addition, this project will have to recover/refill water lost to evaporation
that nearly equals the amount used to fill the pool. Add this to the amount of water used by residents,
guests and commercial establishments as well as the golf course. Golf courses have the advantage of
being able to use desertscaping and grey water for non -potable uses, resulting in less water use. Also,
the DEIR did not validly compare best water uses for golf courses. The surf park will not be using grey
water in their pool and while they should have a filtration system, that still does not lessen the water
lost through evaporation. CVWD recommends that two new wells be drilled. These wells would tap
into our aquifer, which is not being replenished fast enough so it is a finite resource that people living
here desperately need. CVWD is not thinking far enough into even the near future. Climate change is
drying up the entire West. We need the aquifer to augment receiving less river water. We have had
recently two of our hottest days on record for the Coachella Valley. Projections are that it is only going
to get worse and this represents what is happening everywhere in the West.
Response 80-c:
Please see Topical Response, 2.2.3 Water Resources in Section 2.2 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies. As stated in that section, CVWD is required to
plan for the long term, and has done so to address SGMA requirements. This includes projections that
address climate change and long-term drought conditions.
Comment 80-d:
The light comparison alleging that 17 extremely bright lights, strong enough for water safety and
lighting up waves, mounted atop 80 foot poles are similar to 17 palm tree landscape lights pointed
up at tree trunks is fiction. Anyone who has seen the difference will tell you that there is no
comparison. Not only will these lights cause light pollution for our area obliterate any California and
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La Quinta dark sky ordinances, but the toll on wildlife such as bats, night birds, night wildlife and
migrating birds would be extremely harmful. These lights would be especially harmful because the
resort borders the Santa Rosa and San Jacinto Mountains National Monument and "flying" wildlife
will continue to fly over this project area.
Response 80-d:
Please see Topical Responses on Light and Glare in Section 2.2.1 and Biological Resources in Section
2.2.2 of this Chapter for a summary of the analysis in the Draft EIR regarding the potential for
significant light and glare impacts from the lighting plan proposed for the Wave Basin, including the
potential for impacts to wildlife, as well as how the proposed lighting system fully complies with all
applicable dark sky requirements. Please also see Appendices B.1 and B.2 of this Final EIR, as well as
Response 13-r.
Comment 80-e:
The sound study tries to minimize the impact of noise by asserting that Coral Mountain will absorb
equipment noises. But Coral Mountain covers a tiny part of the project perimeter so nearly all of the
neighborhoods around the development would get noise from surf -purposed loudspeakers that will
be nearly always on and noise from planned special events. The planned sound from the Wave Basin
will travel throughout our corridor from 7:00 a.m. to 10:00 p.m. seven days a week and Coral
Mountain will not absorb it. Then add in the sounds from the loudspeakers for the surfing and for the
events and there will be a constant barrage of noise. Combine that with traffic noise. Most of our
traffic is from maintenance workers going to and from work, weekdays early in mornings and
afternoons. One cannot really call our traffic scenario rush hour traffic. We also have a low level of
24-hour traffic from 58th and Madison and occasional distant daytime target practice from the range
near Lake Cahuilla. At night we get some traffic noise, but while even that is irritating, we are
fortunate to hear mostly wildlife sounds. We have consistent traffic now which increases during "The
Season" but regardless with a development of this scale, our traffic and noise will be much worse.
Medical studies have shown that exposure to noises, while subjective, is detrimental to one's health.
This is especially true for those who already suffer hypertension. Most older adults have high blood
pressure and many of those who own homes here are older. More noise and the stress related to the
noise leads to a host of medical issues. Simultaneous noise from different sources, like individual cars,
crowds and loudspeakers can multiply many times by factors of 10. Noise from all the separate
sources from this project could increase total noise logarithmically, meaning by factors of 10, on a
constant daily basis, especially in evenings when we all love our desert quiet. Think of living near a
freeway and barely noticing noise made by a few cars versus the jet engine roar made by many cars.
This is the type of situation that this project could cause. It must be noted that this area is generally
very quiet so even one speeding car on 58th or Madison is grating. It would be totally unacceptable
to spoil the general silence of the desert.
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Response 80-e
Please see Topical Responses 2.2.4 Noise in Section 2.2 of this Chapter for a summary of the analysis
in the Draft EIR regarding the potential for significant noise impacts from the proposed Wave Basin
and other components of the project. Please see Responses 52-h, 59-e, and 2-h as it relates to the
equipment and project noise sources analyzed, and Response 52-h as it relates to the noise levels
studied surrounding the project site, including traffic noise, and their relationship to the City's noise
standards. In summary, the project's impacts on off-site traffic noise are provided in the Draft EIR at
pages 4.11-35 — 4.11-42, and as shown on Tables 4.11-17 through 4.11-20. The project will not cause
a significant increase in off-site traffic noise at any stage during buildout or at full buildout, Including
during special events, and therefore, will not cause any adverse health effects on nearby residents.
Comment 80-f:
In the DEIR it was pointed out that there will be no property tax revenue to the City through 2035.
Nothing about this project will contribute to the enjoyment of life for the residents of La Quinta. What
happens, if as one resident wrote, this ends up being an empty hole in the ground and a failed
development. We can see the headlines now "The City of La Quinta Gem of an Empty Promise and a
Concrete Hole." Word to the wise, think before you buy into this fad. If the City of La Quinta wants
the Wave Basin so badly then perhaps they should make arrangements to have the Wave Basin at
their SilverRock Resort.
We could go on and on but will stop here.
Response 80-f:
The commenter's opinion is noted.
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Comment Letter No. 81: Fritz E. Bachli
Date: August 6, 2021
Affiliation: Area Resident
Comment 81-a:
The following perspective on the "Wave Project" is based on my educational background in the field
of Environmental Sciences and thirteen years of living experience here at Trilogy. I am not surprised
about the many concerns residents are voicing in opposition to the 'Wave Park'? The City of La Quinta
must be concerned about the environmental complaints which are piling up at the City Hall?"
Response 81-a:
This introductory comment is noted. Please see the responses to the comments in this letter below.
Comment 81-b:
Even re -zoning appears not a welcoming answer to accommodate the 'Wave Park!' However,
common sense reminds us: 'If it's not a fit — leave it!' It's surprising that the Project applicant has not
been able to locate a suitable alternative location in our city or elsewhere?
The purpose of zoning is simple. It is designed to ensure balanced communities. Zoning allows the
government to control development of the land and ensure the public is satisfied with their
community. The Draft EIR claims that improving community health is one of the priorities of city
government in order to sustain life which can be enjoyed by residents? If citizens believe it's not a fit
—the city hall should listen and not promote it!
Hopefully my contributions will support the NOPs (Notice of Preparation) filed by concerned citizens.
Response 81-b:
A comparative analysis of the zone change proposed for the project is included on pages 4.10-24 to
4.10-30 of Section 4.10 of the Draft EIR. Within this section, the Draft EIR compares the consistency
of the development standards for each proposed planning area with the City zoning code. Based on
the consistency analysis presented in Section 4.10, the project will be consistent with the goals and
policies outlined in the La Quinta General Plan. The Coral Mountain Resort Specific Plan will result in
changes to development standards, but as demonstrated in Section 4.10, those changes will not be
substantial and will result in less than significant impacts. Please also see Responses 15-d and 17-a as
it relates to the Zone Change.
Comment 81-c:
Following are three key points taken directly from the Draft EIR which are of major concern to me as
a Trilogy Resident?
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1. NOISE
-The project will not generate operational noise levels that have any significant impact on any
sensitive receptors including residents in the surrounding communities.
Areas in the vicinity of the planned project are repeatedly defined as "Golf Course and Residential
Communities!" Trilogy, perhaps other communities as well, belong to a category of housing which is
not recognized as such in the Draft EIR? Trilogy with 1238 homes, housing approx. 2500 residents,
existed long before the planned construction of a Wave Park! The City Council of LQ should recognize
that 55+ Communities are the choice for many aging people who want to focus attention to their
mental, emotional and physical wellbeing. These adults enjoy the serenity of quiet neighborhoods.
55+ adults often decide that the value of time is for elderly individuals the greatest asset that they
possess. Disappointing enough, the Draft EIR does not recognize the needs expressed by residents
who selected a 55+ community?
Trilogy residents are accustomed to noise levels of approx. 30 dBA! It will literally be a "bad
awakening" when they must live in an environment where 60 to 80 dBA is defined as the new normal!
(Measuring Instrument: METERK / MK 09 / Sound Level Meter).
Response 81-c:
Please see Topical Response on Noise in Section 2.2.4 of this Chapter for a summary of the analysis in
the Draft EIR regarding the potential for significant noise impacts from project. Please also see
Response 52-h. The noise study concluded that operational noise generated by the project would
result in less than significant impacts with the implementation of mitigation. The project will not result
in noise levels of 60 to 80 dBA as presented in this comment. As shown in Table 4.11-25, operational
noise levels from the project will range from 39.8 dBA to 52.2 dBA at the 10 off-site sensitive receptor
locations surrounding the project site, which are well below the City's established acceptable noise
level of 65.0 dBA. Further, as shown in Table 4.11-26, the project's operational noise levels will not
significantly increase ambient noise levels at any of the 10 sensitive receptor locations (as noted in
Table 4.11-26, current daytime ambient noise levels at the 10 off-site locations ranged from 43.8 dbA
to 62.5 dBA).
Comment 81-d:
2. AIR QUALITY
The National Heart Association classified the Southern Californian Counties as some, if not the worst,
air quality regions in our nation!
-The Wave Park is seven miles of the 1-10 freeway. The site is found outside the designated
"blowsand" area but is still exposed to seasonal wind activities capable of producing fugitive dust
from undeveloped ground conditions?"
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The Draft EIR is incomplete without reporting available Health Data documented in the annual
Eisenhower Hospital and Imperial County Health Assessments and Improvement updates? This is a
substantial oversight and a sign of ignorance towards the constituents exposed and complaining
about an ever-increasing air contamination problem in the area?
Response 81-d:
The project's air quality impacts are analyzed in Chapter 4.2 of the Draft EIR and in the technical Air
Quality report included as Appendix C. As indicated on page 4.2-33 of Section 4.2, Air Quality, in the
Draft EIR, the blowsand zone is determined and designated by South Coast AQMD. The description of
the project's proximity to this zone is accurate, while acknowledging that the project and other parts
of the Coachella Valley outside of this designated zone are also exposed to seasonal wind conditions
capable of producing fugitive dust.
The adverse health effects to humans from air contaminants, as well as the status of the Salton Sea
Air Basin (SSAB) where the project is located, are discussed in the Draft EIR at pp. 4.2-4 through 4.2-
12. As explained therein, the determination of whether a region's air quality is healthy or unhealthy
is determined by comparing contaminant levels in ambient air samples with state and federal
standards. The SSAB is within the healthy limits established for all criteria pollutants except PM10
(particulate matter) and ozone (see Table 4.2-1). For ozone, the EIR points out that SCAQMD has
determined that local sources of air pollution generated in the Coachella Valley have a limited impact
on ozone levels, because the local ozone exceedances are primarily caused by the direct transport of
ozone and its precursors from the South Coast Air Basin; and that the Coachella Valley is intended to
be in attainment by 2023 (see pages 4.2-9 — 4.2-10). For PM 10, the Coachella Valley is currently
designated as a serious nonattainment area, and is subject to the EPA -approved Coachella Valley
PM10 State Implementation Plan to reduce PM 10 levels to healthy levels. Please also see Section
2.2 of the Air Quality Study, attached as Appendix C to the Draft EIR, for a thorough discussion of the
health effects associated with each of the criteria pollutants identified by the SCAQMD.
The underlying health concerns associated with particulate matter are fundamental factors toward
the establishment of criteria air pollutant standards and South Coast AQMD Rules 403 and 403.1, the
latter of which is specific to the Coachella Valley region. As indicated on page 4.1-9, the Approved
Coachella Valley PM10 State Implementation Plan (CVSIP) is in effect to establish the necessary
controls toward particulate matter attainment. As shown in Tables 4.2-5 and 4.2-6, the project's
construction -related PM10 emissions will be substantially below the regional thresholds of
significance established by SCAQMD. Likewise, the operational emissions for PM10 will also be
substantially below the regional thresholds of significance (see Tables 4.2-7 and 4.2-8). The same is
true when special events are included (see Tables 4.2-9 and 4.2-10).
3 Air Quality is Chapter 4.2 of the Draft EIR, but some of the pages, including the pages referenced here, were mis-
numbered as pages 4.1-1 through 4.1-34 in the Draft EIR.
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The Draft EIR also looked at potential human health impacts in the immediate vicinity of the project
on pages 4.2-31 — 4.2-40, including at ten off-site sensitive receptor locations in the vicinity of the
project. With implementation of Mitigation Measure AQ -2, the project will not exceed SCAQMD's
localized significance threshold for PM10 or any other criteria pollutant during construction (see Table
4.2-13, and as explained on pages 4.2-40, the project will not have any significant air quality impacts
on local residents in the community. Accordingly, the Draft EIR properly analyzed the potential human
health impacts relating to air quality contaminants, and determined that the project would not cause
any significant impacts. The commenter's reference to the annual community health assessments
from Eisenhower Hospital and Imperial County are noted, but are not necessary for the air quality
analysis in the Draft EIR, which is based on ambient air quality information for the area and the
project -specific air quality emissions that could have significant adverse effects on that ambient air
quality, and thus adverse health effects.
Comment 81-e:
Fugitive dust readings on my own patio and tests conducted at locations of Trilogy residents who are
hypersensitive to dust and suffering from pulmonary diseases are often exposed to PM -2.5 particles
at a level of 31.0 mg/3 and in terms of PM -10 particles of 110.2 mg/m3. (Measuring Instrument: Dylos
1700) Such levels can be compared with a very bad "hair day" in Beijing / China! Elevated PM -10 and
PM- 2.5 levels are associated with increases of asthmatic conditions, increase in Emergency Room
visits and increased mortality rates.
Response 81-e:
As explained on pages 4.2-31-4.2-36 of the Draft EIR, potential localized air quality impacts, including
from PM10 and PM2.5 emissions during grading and construction operations, were analyzed using
maximum daily emissions calculations from the CaIEEMod program and applicable SCAQMD data, and
then maximum emissions levels were calculated at the nearest sensitive receptor location, which is
the existing residence on Avenue 60, approximately 37 feet from the project boundary. As shown in
Table 4.2-13, the project, with implementation of Mitigation Measure AQ -2, will not exceed any
SCAQMD localized threshold and will not have any significant air quality impacts on the surrounding
residential communities. As the residences in Trilogy are much further away from the project grading
operations, any emissions reaching Trilogy residents would be even less than at the sensitive receptor
locations studied. Please also see Sections 3.6 through 3.9 of the Air Quality Study, which is included
as Appendix C to the Draft EIR.
Comment 81-f:
Air Quality Standards considered safe and obtained from AQMD are taken from monitoring stations
in Palm Springs 18 miles southeast from the project, the Indio station is 6 miles away and the distance
to Mecca amounts to 11 miles. Air quality is a very local phenomenon and measurements taken miles
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away from the project are not representative of the actual situation as it is occurring at the project
site and at individual sites of sensitive receptors.
Response 81-f:
Although the level of ambient air quality is determined by SCAQMD on an area wide basis (the
Coachella Valley is in the Salton Sea Air Basin), as described in the Draft EIR on pages 4.2-4 and 4.2-5,
the Air Quality Study prepared for the project also carefully evaluated localized air quality impacts
pursuant to SCAQMD guidance (see Responses 81-d and 81-e).
Comment 81-g:
Special events, four times a year, with a daily expectancy of 2500 "Wave Park" guests, thousands of
visitors per year will unquestionably contribute to a further overload of environmental conditions for
the area right across the street from the Trilogy community!
Response 81-g:
Potential air quality impacts during special events were specifically evaluated in the Air Quality Study
and were found to be less than significant. Table 4.2-10 identifies the project -related air quality
emissions for special events for each of the criteria pollutants, and shows that they will not exceed
SCAQMD's established thresholds.
Comment 81-h:
Mobile measuring devices which provide immediate on-site particle readings are becoming
household items! Some time ago, I demonstrated to an AQMD team from the City Hall of La Quinta
during a visit to the Golf Course Perimeter a slide presentation and test methods I used to measure
PM -10 and PM -2.5 particle loads at the Trilogy community. They were surprised about the immediate
results with handheld high quality measuring devices and the accurate readings when compared with
fixed measuring stations.
Response 81-h:
The comment is noted. Please also see Responses 81-d — 81-f above regarding the Air Quality Study's
analysis as completed pursuant to SCAQMD guidance and established thresholds of significance.
Comment 81-i:
-SCAQMD has the legal obligation to enforce air pollution regulations!"
From the moment a legitimate complaint is filed, and actions taken by the AQMD may literally take
weeks, months or even years. Very frustrating process which might have been improved when
compared in previous years?
Response 81-i:
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The commenter's frustration with SCAQMD's enforcement practices is noted. However, as noted
above, the project will not generate significant levels of air quality emissions during construction or
operations, and will not have any significant adverse air quality impacts. In addition, per Rule 403.1,
all grading/site disturbance notification signs posted on development sites have a hotline/contact
number to call with complaints
Comment 81-j:
-LST's (Localized Significance Threshold) limits were developed in response to environmental justice
and health concerns raised by the public regarding the exposure to individuals to criteria pollutants
in local communities.
Is Trilogy qualifying for such an exemption?
Response 81-j:
The reference to an "exemption" for Trilogy regarding LST limits is not clear. As discussed in Responses
81-d and 81-e, the project will not exceed SCAQMD's localized significance thresholds for any criteria
pollutants during construction or project operations, including at the closet existing residence,
located 37 feet to the east of the project boundary.
Comment 81-k:
3) WATER
The Wave Park could result in cumulatively significant impacts to water supplies and infrastructure if
not reviewed by the City and CVWD?
I wish there would be more concrete definition in the (Draft EIR) like this one. An eye opener for
ordinary residents without in depth knowledge in the field of water issues!
A surfer confessed to me that Wave Parks are fun. But pulling ground water especially in the desert
and deleting aquifers is against all common-sense Environmental principles. Such water is not being
used to benefit a society. It's being used for middle, upper financial elite classes for leisurely escapism.
AKA a vacation while the world burns, farm animals have to be slottered due to lack of food and
water. The greenhouse effect takes its tall!
Response 81-k:
Please see the Water Resources Topical Response in Section 2.2.3 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies.
Comment 81-1:
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THE PROJECTED WAVE PARK IS NOT A PLANNED COMMUNITY THAT COMPLIMENTS EXISTING
DEVELOPMENTS IN THE SURROUNDING AREA AND IS CONTRIBUTING TO THE ALREADY EXISTING
ENVIRONMENTAL OVERLOAD IN THE SURROUNDING ENVIRONMENT.
The commenter includes pictures from Trilogy and the air quality measurement equipment
referenced in Comment 81-e.
Response 81-1:
The commenter's opinion is noted. Please see Responses 81-b through 81-k as they relate to the
specific concerns.
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Comment Letter No. 82: Ramon Baez
Date: August 6, 2021
Affiliation: Area Resident
Comment 82-a:
Reference: email from Ramon Baez dated 3/10/2021 (attached); email from Mr. Rob Michiels dated
7/21/2021 (attached)
Response 82-a:
This comment is noted. The email messages referenced in this comment are responded to in
Responses 82-e through 82-g below.
Comment 82-b:
As I stated in the attached referenced email dated March 10, 2021, we enjoy the tranquility and
serenity of the Andalusia Country Club. Prior to the scoping meeting, we were opposed to this project
and now after a careful review of the DEIR and having discussions with the developer representatives
we are even more opposed to many facets of this project. We believe it will be incompatible to the
2035 General Plan and the culture of the community within the South East La Quinta area. We actually
do not believe it is compatible to any residential area of the Coachella valley.
We are not NIMBY type people. My wife and I are big supporters of development but it needs to be
compatible to the overall community and provide value to the overall community.
Response 82-b:
The commenter's opinion is noted. The Draft EIR analyzes project compatibility with the La Quinta
General Plan in Section 4.10, Land Use and Planning. Please also see Responses 41-c, 52-f and 83-w
through 83-hh for further information regarding the project's consistency with the City's 2035
General Plan.
Comment 82-c:
We believe that this project will have a significant negative impact to the overall environment with
everything we have read from a traffic, noise and light pollution.
Response 82-c:
The commenter's opinion is noted. This comment presents an opinion, however, and not substantial
evidence that the project will result in substantially greater impacts than identified in the Draft EIR.
Please also see the Topical Responses on Light and Glare, Noise, and Traffic in Sections 2.2.1, 2.2.4,
and 2.2.5, respectively, for further information on these topics.
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Comment 82-d:
By rezoning this area to tourist commercial, we will no longer have a similar community adjacent to
us but will have a Surf Amusement Park with planned surf festivals and tournaments several times a
year. We are sure that there is not one planned community in the La Quinta area that would want
such a project to be erected adjacent to them.
Response 82-d:
The commenter's opinion is noted. The project proposes a mixed-use resort community which
includes low density residential land uses within the project site. Low density housing will occupy
approximately 232.3 acres of the site (approximately 60 percent of the project). The proposed zone
change is analyzed in Section 4.10, Land Use and Planning, of the Draft EIR, which concluded that the
land use and zone changes proposed for the project would result in less than significant impacts.
A comparative analysis of the zone change proposed for the project is included on pages 4.10-24 to
4.10-30 of Section 4.10 of the Draft EIR. Within this section, the Draft EIR compares the consistency
of the development standards for each proposed planning area with the City zoning code. Based on
the consistency analysis presented in Section 4.10, the project will be consistent with the goals and
policies outlined in the La Quinta General Plan. The Coral Mountain Resort Specific Plan will result in
changes to development standards, but as demonstrated in Section 4.10, those changes will not be
substantial and will result in less than significant impacts because the project will look similar to the
other gated private resort communities in this portion of the City with perimeter walls, landscaping
and low-density residential development along Madison Street and Avenue 58. Please also see
Responses 15-d, 17-a, and 41-c as they relate to the Zone Change and processing of the project as
well as the land use compatibility concerns raised in this comment.
Comment 82-e:
We respectfully request that the Planning Commission and the City Council not approve the rezoning
being requested by the developers to allow the construction of the Wave Basin and providing them
the ability to build 750 STVRs in the middle of a low-density residential area which are truly
neighborhoods. My fellow Andalusia resident, Mr. Rob Michiels, submitted questions concerning the
DEIR (see attachment dated July 21, 2021) that we believe need to be answered for all of us that are
very concerned about this very complex project.
Response 82-e:
The commenter's opinion is noted. As it relates to the allowance of STVRs on the property, please see
Response 52-g The responses to the referenced questions are provided in Responses 52-b Through
52-p.
Comment 82-f:
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Comment 82-f refers to Mr. Rob Michiels letter (Comment Letter No. 52), which Baez included for
reference.
Response 82-f:
This comment is noted. Please refer to Comment Letter No. 52, Rob Michiels, for the letter and
associated responses.
Comment 82-g:
Comment 82-g refers to Mr. Rob Michiels letter sent July 20, 2021, which Baez included for reference.
Response 82-g:
This comment is noted. Please refer to Comment Letter 45 and 46, Rob Michiels, for the letter and
associated responses.
Comment 82-h:
Comment 82-h refers to a previous letter Baez sent to the City during the public comment period in
March associated with the Notice of Preparation (NOP) of the Draft EIR. Baez included the letter for
reference. In this comment, Baez expresses his opposition to the project for similar reasons discussed
in Comment 82-c.
Response 82-h:
This comment is noted. Please see the Topical Response on Light and Glare in Section 2.2.1, as it
relates to lighting at the project site. The March comment letter was included in Appendix A, Notice
of Preparation, and considered in the preparation of the Draft EIR.
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Comment Letter No. 83: Bruce Bauer SBEMP Attorneys
Date: August 6, 2021
Affiliation: SBEMP Attorneys representing the La Quinta Residents for Responsible Development
Comment 83-a:
Our office represents residents in the City of La Quinta (City), La Quinta Residents for Responsible
Development (LQRRD), who are rightfully concerned about the development of a proposed project
within the City that portends fundamental changes in the character of the City. That proposed project,
described below, is the subject of a Draft Environmental Impact Report, SCH# 2021020310, prepared
by MSA Consulting Inc. (DEIR). Please consider the enclosed comments with respect to that DEIR and
consider, in particular, the concerns we have raised concerning the issues of traffic, noise, air quality,
water, and the Applicant's request to amend the City's General Plan.
Response 83-a:
This introductory comment describing La Quinta Residents for Responsible Development (LQRRD)
does not identify a specific concern or question regarding the adequacy of the Draft EIR. Specific
responses relating to the environmental issue areas are addressed below. For this reason, no further
response to this comment is provided.
Comment 83-b:
I. THE PROPOSED WAVE FESTIVAL PROJECT
The subject of the DEIR is a proposal to be build an enormous development on land that is currently
slated in the City's General Plan for low-density residential development. The existing local area is
characterized by developed golf course and residential communities to the north, west, east, and
southeast, the Santa Rosa Mountains to the west and south, Monroe Street and vacant and
agricultural lands to the east, and open space to the south. (DEIR, p. 14, Section 1.2.1.) The area is in
keeping, then, with what most people expect in the residential areas of a beautiful desert city in the
Coachella Valley: (1) low density; (2) quiet; (3) low traffic; and (4) unencumbered mountain vistas that
are illuminated by the stars at night.
Instead of this low-density, and low-key, development that residents of the City were told would be
developed nearby, The Wave Development, LLC (Applicant), proposes a large-scale commercial
enterprise, replete with recurring festivals, that includes a 150 -room hotel and 600 residential units
(all of which will be permitted to have short -terms rentalsl). As part of this project, the focal point of
all of these short-term rental units will be an enormous 18 million gallon2, 16 -acre, artificial surf basin
that will have artificial waves generated by a large locomotive -like engine. This Wave Basin will be, in
turn, illuminated with 80 -foot light towers, lighting up the darkened desert night sky, encircling the
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basin. Additionally, Applicant proposes, as part of the Wave Festival Project, large scale commercial
development including, separately, 57,000 square feet and 60,000 square feet of commercial uses.
DEIR, p. 67, Section 2.51. The project will be referred hereinafter to the "Wave Festival Project."
The Wave Festival Project's Wave Basin will be the focal point of a parade of at least four (4) events
a year of a four-day duration. As indicated by Applicant, there will be four (4) entertainment/special
events (of four (4) days duration or 16 days and nights of special events per year) (the "Special Events.)
Each day of these Special Events might easily bring in thousands of visitors per day (with each such
event the Applicant would be permitted to have 2,500 guests per day — this would be in addition to
the guests that are staying at the resort's villas and hotel, myriad employees and vendors attending
to all those guests, and does not include the days that will be needed for staging and dismantling of
each of the Special Events.)
Applicant then is seeking permission to allow approval of the Wave Festival Project with an enormous
amount of overnight guests in excess of 4,000 per night ((one can estimate that it might have 600
overnight guests for its planned 150 -room hotel (4 pillows per room x 150 rooms), plus 3,600
overnight guests for the planned 600 -villas (averaging 3 bedrooms each, 6 pillows X 600=3,600
overnight)), for a total over 4,000 overnight guests coming and going. There will then also be the
2,500 allowed visitors coming and going. The Wave Festival Project then promises to bring significant
changes to the City and its surrounding and adjoining communities compared to what was previously
approved for this area. Naturally, a project of this nature, that will continue to morph and increase
exponentially, should be given additional scrutiny.
The proposed Wave Festival Project is both out of scope of the nature of its proposed setting as set
forth in the City's General Plan as discussed below. The enormity of this request, and the scale of
change from the City's existing land use designation for the proposed site, is evidenced by the fact
that Applicant is seeking an extraordinary number of approvals including as follows:
(1) a General Plan Amendment (GPA 2019-0002);
(2) Zone Change (ZC 2019-0004);
(3) Specific Plan (SP 2020-0002);
(4) Tentative Tract Map (TTM 2019-0005);
(5) Site Development Permit (SDP 2021-0001); and,
(6) a Development Agreement (DA 2021-0002).
It is clear that the Wave Festival Project bears NO relationship to the development that had been
originally entitled for that area. The Wave Festival Project is not akin to a low-density golf -centered
master -planned community. No one can seriously contend such. The Wave Festival Project is, in
reality, a commercial entertainment -based venue endeavor and not a residential development. The
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Wave Festival Project will be comprised of a commercial /high-density project that will cause far more
impact on the surrounding communities that could ever have been conceived in prior entitlements
and is being severely understated by the Applicant so that approval can be obtained. The quiet and
serene atmosphere currently enjoyed by the City's residents will forever be destroyed. As such, we
do not believe the Wave Festival Project, as proposed, should move forward with the City, as
analyzed, since it is not in keeping with the character and entitlements envisioned by the City and its
residents. However, should the City consider the Wave Festival Project it must do so under only the
most exacting review standards.
Response 83-b:
The commenter's opinions are noted. This introductory comment restating and partially
recharacterizing the project description from the Draft EIR (calling it a "Wave Festival Project"), and
expressing LQRRD's opposition to the project, does not identify a specific concern or question
regarding the adequacy of the Draft EIR. For this reason, no further response to this comment is
provided.
Comment 83-c:
II. CEQA AND LEGAL REQUIREMENTS.
The California Environmental Quality Act (CEQA) requires state and local government agencies to
inform decision makers and the public about the potential environmental impacts of proposed
projects, and to reduce those environmental impacts to the extent feasible. CEQA requires that an
agency analyze the potential environmental impacts of its proposed actions in an environmental
impact report ("EIR") (except in certain limited circumstances). See, e.g., Pub. Res. Code § 21100.
The EIR is the very heart of CEQA. (Dunn -Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652.) "The
'foremost principle' in interpreting CEQA is that the Legislature intended the act to be read so as to
afford the fullest possible protection to the environment within the reasonable scope of the statutory
language." (Comms. For a Better Env't. v. Calif. Resources Agency (2002) 103 Cal.App.4th 98, 109.)
CEQA has two primary purposes. First, CEQA is designed to inform decisionmakers and the public
about the potential, significant environmental effects of a project. (14 Cal. Code Regs. § 15002(a)(1).)
Its purpose is to inform the public and its responsible officials of the environmental consequences of
their decisions before they are made. Thus, the EIR 'protects not only the environment but also
informed self-government." (Citizens of Goleta Valley v. Board of Supervisors, supra, 52 Ca1.3d at
564.) The EIR has been described as "an environmental 'alarm bell' whose purpose it is to alert the
public and its responsible officials to environmental changes before they have reached ecological
points of no return." (Berkeley Keep Jets Over the Bay v. Bd. Of Port Comm'rs (2001) 91 Cal.App.4th
1344, 1354; County of Inyo v. Yorty (1973) 32 Cal.App.3d 795, 810).
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Second, CEQA requires public agencies to avoid or reduce environmental damage when "feasible" by
requiring "environmentally superior" alternatives and all feasible mitigation measures. (14 Cal. Code
Regs. § 15002(a)(2) and (3); see also Berkeley Keep Jets Over the Bay, supra, 91 Cal.App.4th 1344,
1354; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Ca1.3d 553, 564.) The EIR serves to
provide agencies and the public with information about the environmental impacts of a proposed
project and to "identify ways that environmental damage can be avoided or significantly reduced."
(14 Cal. Code Regs. § 15002(a)(2).) If the project will have a significant effect on the environment, the
agency may approve the project only if it finds that it has "eliminated or substantially lessened all
significant effects on the environment were feasible" and that any unavoidable significant effects on
the environment are "acceptable due to overriding concerns." (Pub. Res. Code § 21081; 14 Cal. Code
Regs. § 15092(b)(2)(A) and (B).)
The DEIR that has been submitted is 738 -page document that has not afforded the public a reasonable
manner to decipher it, nor has it properly analyzed the Wave Festival Project for a myriad of reasons
as discussed below.
Response 83-c:
This comment recites the language of certain CEQA Guidelines and case law, but does not identify a
specific concern or question regarding the adequacy of the Draft EIR. For this reason, no further
response to this comment is provided. Please also see Topical Responses 2.2.6, Length of the Draft
EIR, and 2.2.7, Ability to Comprehend the Draft EIR.
Comment 83-d:
III. THE DEIR FAILS TO ADEQUATELY DISCLOSE, ANALYZE, AND MITIGATE ALL POTENTIALLY
SIGNIFICANT IMPACTS.
As discussed below, and in the attached expert comment letters of traffic (comment letter dated
August 3, 2021) and sound (comment letter dated August 2, 2021) experts, Minagar & Associates,
Inc., the DEIR fails to adequately analyze and mitigate the Wave Festival Project's impacts.
CEQA requires that a lead agency analyze all potentially significant environmental impacts of its
proposed actions in an EIR. (Pub. Res. Code § 21100(b)(1); 14 Cal. Code Regs. § 15126(a); Berkeley
Keep Jets Over the Bay, supra, 91 Cal.App.4th at 1354.) The EIR must not only identify the impacts
but must also provide "information about how adverse the impacts will be." (Santiago County Water
Dist. v. County of Orange (1981) 118 Cal.App.3d 818, 831.) The lead agency may deem a particular
impact to be insignificant only if it produces rigorous analysis and concrete substantial evidence
justifying the finding. (Kings County Farm Bureau v. City of Hanford (1990) 221 Cal.App.3d 692.)
While the courts review an EIR using an "abuse of discretion" standard, "the reviewing court is not to
'uncritically rely on every study or analysis presented by a project proponent in support of its position.
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A 'clearly inadequate or unsupported study is entitled to no judicial deference."' (Berkeley Keep Jets
Over the Bay, supra, 91 Cal.App.4th at 1355, quoting Laurel Heights Improvement Ass'n v. Regents of
Univ. of Cal. (1988) 47 Ca1.3d 376, 391, 409, fn. 12.) A prejudicial abuse of discretion occurs "if the
failure to include relevant information precludes informed decision-making and informed public
participation, thereby thwarting the statutory goals of the EIR process." (San Joaquin Raptor/Wildlife
Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 722; Galante Vineyards v. Monterey
Peninsula Water Mgmt. Dist. (1997) 60 Cal.App.4th 1109, 1117.)
Response 83-d:
This comment does not identify a specific concern or question regarding the adequacy of the Draft
EIR. For this reason, no further response to this comment is provided.
Comment 83-e:
A. Traffic Impacts Have Not Been Adequately Analyzed or Mitigated.
Traffic impacts have not been adequately analyzed or mitigated in the DEIR. The DEIR greatly
understates traffic counts. It is well known that festivals of the nature that the Applicant proposes
with the Special Events bring in large crowds. Given the short-term rental nature of the residences to
be constructed, it is likely they will be densely occupied during those timeframes. Therefore, the
reliance on existing data of traffic counts is not reliable and trustworthy information. In normal
developments in the City, many neighborhoods are thinly occupied because they are often second
homes. Therefore, data utilizing existing traffic counts only reflect that sort of development. However,
the development sought in connection with the Wave Festival Project should more closely be attuned
to traffic counts for like developments (here a commercial entertainment development) and
particularized times of the year such as when festivals such as Coachella and Stagecoach occur. Also,
the DEIR has not considered when the Special Events will occur. The timing of the Special Events is
especially important given other busy events that occur during the calendar as pointed out above.
Response 83-e:
This comment asserts that the Draft EIR "understates traffic counts" because the counts only reflect
existing conditions, and do not take into account the potential for short-term rentals, or special events
at the proposed project. This comment appears to conflate the Draft EIR analysis of existing traffic
conditions and the potential traffic from the proposed project.
To accurately determine the existing traffic conditions, the Draft EIR and accompanying traffic study
included traffic counts taken on four different dates, all of which occurred prior to the start of the
COVID-19 pandemic, as described on page 4.13-10 of the Draft EIR. In addition, the counts were
adjusted upward in accordance with the established City of La Quinta traffic study requirements to
account for both seasonality and annual background growth. See La Quinta Engineering Bulletin #06-
13 and Appendix L.1 of the EIR. The Draft EIR and traffic study did not understate the traffic counts
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taken by Urban Crossroads, and accordingly, the existing conditions baseline analysis in the traffic
study and EIR is appropriate and correct and consistent with the CEQA Guidelines Section 15125 (1)
which states that an EIR agency should describe physical environmental conditions as they exist at
the time the notice of preparation is published.
The trip generation rates established by the Institute of Transportation Engineers (ITE), the recognized
standard source reference used by cities across California, were used to estimate the number of trips
the proposed project would generate based on each of the proposed uses. These rates include
residential rates, resort/hotel rates, recreational rates, and commercial rates, which were applied to
each of the proposed project uses, which is the standard professional practice for traffic studies. The
scope of the analysis, including the ITE land use categories, was established through compliance with
the City's Engineering Bulletin and the Traffic Impact Analysis scoping process, which was reviewed
and approved by the City of La Quinta (see Appendix 1.1 to the Traffic Impact Analysis, Appendix L.1
of the Draft EIR).
As it relates to the assertion that the traffic analysis does not consider when the proposed special
events will occur during the course of the year, the comment is incorrect. First, the City's requirement
under Engineering Bulletin #06-13 is that peak season factors be assumed for both existing and future
conditions, thus the percentage adjustments required for seasonality. The trip generation rates for
the special events are based on the maximum capacity of those events, which is 2,500 attendees, and
are calculated in addition to the trips generated by the balance of the project's land uses, as shown
in Table 4.13-26 of the Draft EIR. Therefore, contrary to the commenter's opinion, all land uses and
high season impacts have been calculated in the traffic study's analysis.
Comment 83-f:
Traffic counts utilized in the DEIR include Thursday, August 15, 2017, Tuesday, April 9, 2019, Tuesday,
May 7, 2019, and Tuesday, September 10, 2019. These counts were not taken during either during
the busiest part of the year, for City residents, i.e., the "High Season" in the middle of the winter
months when snowbirds have returned to the City (from October through March.) Those more
realistic dates should have been utilized to conduct a meaningful traffic analysis. The base traffic
volumes used in the analysis are therefore an underestimation of the actual volumes.
Response 83-f:
Please see Response 83-e.
Comment 83-g:
As opined by Minagar & Associates in their comment letter of August 3, 2021 (see, Exhibit 2 hereto),
the analysis contained in the DEIR is also defective in several key respects:
• For a large mixed-use of the size contemplated by the Wave Festival Project, utilization of
traffic counts from Thursday, August 15, 2017, Tuesday, April 9, 2019, Tuesday, May 7, 2019,
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and Tuesday, September 10, 2019 is not prudent. Current traffic counts could have been easily
taken right after the scoping agreement on February 12, 2020, and before the start of COVID-
19 pandemic on March 15, 2020. It goes without saying that the traffic volumes are the
foundation of every traffic impact study. Once their validity is questioned, then the public trust
is eroded.
Response 83-g:
Please see Response 83-e. A complete response to the comments in the Minegar & Associates letter
was prepared by the traffic consultants, Urban Crossroads, which is attached as Appendix L.3 to this
Final EIR and is incorporated into this response. As described in that document and in Response 83-
e, the traffic counts were adjusted per the standards established by the City for seasonality, and the
annual growth rates applied based on prior year averages, also consistent with City standards. The
traffic count data is therefore accurate and appropriate for use in the traffic analysis and the Draft
EIR.
Comment 83-h:
• For the trip generation estimation for the Special Events during weekends, since the national
ITE Trip Generation Manual does not provide the required rates, why surveys of similar
facilities weren't used to establish the rates?
Response 83-h:
As explained in greater detail in the Urban Crossroads Memo included in Appendix L.3, the project
contains a unique mix of uses. The most appropriate way to calculate trip generation rates is to assign
the most applicable established ITE rate for each individual use (i.e., single-family residential, resort
hotel, neighborhood commercial, recreational uses, etc.).
In this case, the ITE rates applicable to each of the project uses were reviewed and approved by City
of La Quinta staff and documented in the scoping agreement, consistent with the City's requirements
under EB #06-13 (see Appendix 1.1 of the Traffic Impact Analysis, Appendix L.1 of the Draft EIR). Due
to a lack of truly similar facilities, trip generation rates for the special events were based on the
maximum capacity of 2,500 visitors and an average vehicle occupancy of 2.4 persons per vehicle, in
reliance on the expertise and judgment of the traffic engineers (see p 115 of Traffic Impact Analysis,
Appendix L.1 of Draft EIR).
The trip generation calculations for the special events are considered conservative because they
assume there will be 2,500 additional visitors for the special events, in addition to the hotel guests,
residences and other project visitors, as shown on Table 4.13-26 in the Draft EIR, even though it is
expected that many attendees of the special events will be staying in the project residences and hotel
rooms, rather than commuting to the special event from off the project site.
Comment 83-i:
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• Why for the 2,500 -Guest Wave Basin Facility, the old trip generation rates from SANDAG
Manual for a recreation park (developed) from over 20 years ago was used to generate new
traffic estimates? Surveys of similar facilities could have been performed.
Response 83-i:
It is not clear whether this comment pertains to the special events, which can host up to a maximum
of 2,500 guests, pursuant to a special use permit issued by the City of La Quinta, or whether it pertains
to the ordinary operations of the Wave Basin. The trip generation for special events is addressed in
Response No. 83-h above, and in either case, there are no similar existing facilities that could be
surveyed and provide meaningful data on trip generation for the proposed Wave Basin, which is a
private recreational amenity in a resort and master planned community.
With respect to ordinary Wave Basin operations, the trip generation rates for the Wave Basin are
derived from the San Diego Association of Governments established rates for a public recreational
park, because this was determined in the professional judgment of the traffic engineers to provide an
appropriate and conservative trip generation rate for the proposed private Wave Basin project
component. Based on the SANDAG's recreational park rates of 50 daily trips per acre of park, the
Wave Basin itself Is assigned a total of 600 daily trips, which is considered very conservative because
the Wave Basin requires approximately 50 employees daily and can only accommodate a maximum
of 130 total surfers per day (maximum of 30 surfers in the Wave Basin at any one time). All other
visitors to the Wave Basin area are captured by the other categories of uses in the vicinity of the Wave
Basin, including the Wave Club, the Resort Hotel, and the Farm. Please see Table 4.3-11 of the Draft
EIR for the trips generated by these additional uses.
Comment 83-j:
• There are a number of discrepancies among the land use sizes of The Wave Basin Facility, The
Wave Village, The Farm and related uses for the purposes of trip generation calculations in
different reports.
Response 83-j:
The comment asserts discrepancies, but does not identify any, making a direct response impossible.
As explained on pp. 3-19 and 3-20 of the Draft EIR, the Wave Basin facility is approximately 16.62
acres, and the water body footprint is approximately 12.14 acres. The total Wave Basin subarea of
Planning Area III totals approximately 31.2 acres, and includes the equipment, storage and related
facilities required to operate the Wave Basin. Only the trips directly associated with the Wave Basin
itself are included in the 12 -acre calculation, and all other visitors to the Wave Basin area are captured
by the other categories of uses in Planning Area III, including the Wave Club, the Resort Hotel, and
the Farm. Please see Table 4.3 of the TIA for the trips generated by these additional uses.
Consequently, the discussion of the relevant acreages in the Draft EIR is consistent and correct.
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Comment 83-k:
• For the claimed VMT mitigation reductions, the specific source and category from the State of
California's CAPCOA Manual must be documented for verification.
Response 83-k:
As set forth on pages 4.13-54 and 4.13-55 of the Draft EIR, reductions in VMT were evaluated using
the State of California CAPCOA guidance (Quantifying Greenhouse Gas Mitigation Measures). As
further expanded upon in the Urban Crossroads Memo attached to this Final EIR as Appendix L.3,
there were three separate sources of VMT reductions taken from the State of California CAPCOA,
which are as follows:
The first VMT reduction factor applied recognizes the proximity of different land uses. This
CAPCOA reduction measure is LUT -3 which indicates a range of 9-30% VMT reduction is
applicable for a mixed-use project. A conservative reduction of only 3% was assumed in
the project's VMT analysis. It is likely that the mix of uses in the project will result in a
greater reduction in vehicle trips and VMT.
The second VMT reduction factor applied recognizes design elements that allow for
connections between different uses and areas that will reduce the need to use a vehicle
for short trips. The CAPCOA measure is SDT-1 which indicates a range of 0-2% applicable
VMT reduction, and SDT-2 which indicates a range of .25-1.00% applicable VMT reduction.
A reduction of 2% was applied in recognition of the of the high level of multi -modal
connectivity that will be provided based on the design of the project's.
The third VMT reduction applied is for marketing strategies for commute trip reductions.
The CAPCOA measure is TRT -7, which indicates a range of 0.8-4.0% applicable VMT
reduction. A conservative reduction of 1% was assumed in the project's VMT analysis.
Comment 83-1:
B. Water Supply Impacts Have Not Been Adequately Analyzed or Mitigated.
The seriousness of the state's water concerns means that large-scale projects like this in the middle
of the desert must be carefully planned to ensure adequate supplies of water, even in times of severe
drought. Cities and counties are required to verify that adequate long-term water supplies exist for
large development projects. (Water Code § 10910; Gov. Code § 66473.7.) These laws, working in
conjunction with CEQA, force municipalities to consider how they will supply water to new projects.
Thus, when an agency considers a detailed project proposal that would require additional water, the
public must have an opportunity to consider, in a detailed EIR, the project's water supply and
mitigation measures and alternatives that would lessen the related impacts. (Pub. Res. Code §
21093(a); 14 Cal. Code Regs. § 15152(a) -(c).) This detailed analysis is referred to as a Water Supply
Assessment ("WSA").
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Water supply for the proposed project would be provided by the Coachella Valley Water District
(CVWD). (DEIR, at 4.9-19.) Coachella Valley relies on groundwater for its primary supply sources.
(DEIR, at 4.9-19.) The proposed project is expected to consume approximately 958.63 -acre feet per
year (AFY), which equates to an alarming 312,163,558 gallons of water per year. (DEIR, at 4.9-19.) The
DEIR vaguely states without any details that the groundwater basin can meet the water demands of
the Coachella Valley for extended normal and drought periods. (DEIR, at 4.9-28.) However, the WSA
admits repeatedly that the Coachella Valley relies on groundwater for its primary supply source, and
that "the amount of water in the acquifer has decreased over the years due to heavy pumping to
serve urban, rural and agricultural development in the Coachella Valley, which has withdrawn water
from the aquifer at a rate faster than its natural rate of recharge." (WSA, p. 30.) The solution has been
to import the majority of the water supply, primarily from the Colorado River. This is not a sustainable
model as Californians have acutely learned over the last decade of drought -like conditions.
Response 83-1:
Please see the topical response concerning water use in Section 2.2.3 of this Final EIR for additional
discussion regarding the adequacy of the analysis in the Water Supply Assessment approved by the
CVWD and why the water demand estimated for the project, including the proposed Wave Basin, will
not result in adverse impacts to groundwater conditions in the Indio Subbasin. Contrary to the
commenter's assertions, the CVWD's long term planning includes multiple water sources, and
includes potential shortfalls in water allocations from outside sources. Furthermore, CVWD's analysis
shows that it has a long term management plan in place to assure a balanced supply of water under
drought conditions. Since 2009, groundwater storage volume in the Indio Subbasin actually increased
by approximately 840,000 acre-feet due to CVWD's groundwater management efforts.
As acknowledged in this comment, a Water Supply Assessment/Water Supply Verification
(WSA/WSV) was prepared for the project and approved by the Coachella Valley Water District
(CVWD), which concluded that the project is expected to consume a total of 958.63 acre-feet per year
(AFY) for all indoor and outdoor water uses, and concluded that there are sufficient water supplies
during normal, single -dry, and multiple -dry years over the required 20 -year assessment period for the
project and all other existing and planned future water demand.
As set forth in CVWD's Indio Subbasin Water Management Plan Update (the "Indio SGMA Update")
for the period 2020 through 2045, total water demand for the subbasin is expected to increase by a
total of approximately 61,262 AFY, from approximately 583,348 AFY to 644,610 AFY. The estimated
958.62 AFY required for the project is included in these estimates, and accounts for approximately
1.5% of this projected increase in total demand for the subbasin.
Also as explained in the Indio SGMA Update, CVWD relies on a combination of local groundwater,
Colorado River water, SWP exchange water, surface water, and recycled water to meet water
demands, and through its groundwater management efforts, CVWD projects that it can meet the
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projected water demand without depleting groundwater in the subbasin or creating an overdraft
condition. (See, e.g., Indio SGMA Update, pp. ES -7 — ES -12).
Comment 83-m:
Coachella Valley's water conservation plans rely on source substitution with the Colorado River, but
the Colorado River is also experiencing historically low levels and drought conditions. Countless other
communities also rely on the Colorado River as a water source, so this practice is not sustainable in
the long term. In fact, the WSA only analyzes and accounts for the water supply for the next 20 years,
which is relatively soon. (DEIR, at 4.9-28.) With exponential population growth expected, and the
continuing effects of climate change, this analysis needs to account for a much longer period.
Recent climatic developments, and the increasing impact of drought in the State and in the Western
state, especially an historic drought in the Colorado River basin of 20 years, demand that the City not
review water usage with "business as usual" calculations. See, e.g., California water regulators took
unprecedented action this week, passing an emergency regulation that will bar thousands of
Californians from diverting stream and river water as the drought worsens.
(https://www.latimes.com/california/story/2021-08-04/california-drought-water-restrictions-
howbad-is-it ). Elsewhere, in the Colorado River basin, water levels in the water reserves held by Lake
Powell and Lake Mead, two of the US's largest reservoirs that both sit along the Colorado River relied
upon more than 40 million (including the Coachella Valley) are at record lows.
https://www.popsci.com/science/lake-mead-lake-powell-drought/
As set forth above, the Wave Festival Project (even with water conservation measures) would have a
total water demand of 958.63 acre-feet per year (AFY). It is important to note that the DEIR fails to
equate the AFY by gallons of water per year. This was done purposefully. It does not want the public
to know just how many gallons of water this project will use on a yearly basis. Projects that allow for
312,163,558 gallons of wasted resources should not be permitted to put pressure on already declining
aquifers. This is especially true when the climate crisis is creating an uncertain future where
sustainability and demand on aquifers are getting harder and harder to predict.
Response 83-m:
Please see the Topical Response on Water Resources in Section 2.2.3. The WSA/WSV correctly
analyzed project impacts as required by State law, over a 20 year horizon. Both the WSA/WSV and
CVWD's Indio SMGA Update consider the potential for extended drought conditions. In addition, the
Indio SMGA Update specifically considers the impact of climate change and examines multiple
scenarios for its effect on the subbasin groundwater levels for the 50 -year period 2020 — 2070, taking
into account both cumulative water demand and CVWD's groundwater management efforts. Several
alternative scenarios are addressed in the SGMA Update that account for all projected growth,
expanded agricultural water use, and climate change/drought effects. CVWD projects a substantial
increase in the subbasin groundwater storage, not an overdraft condition, due to its ongoing
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groundwater management efforts and future planned CVWD projects that will reduce the net
demands on the Subbasin. (See, e.g., Indio SMGA Update, pp. ES -9 — ES -12, and p. 7-89).
As it relates to the use of acre feet per year (AFY) rather than gallons, the commenter's assertion that
gallons were purposefully omitted is false. The CVWD, and indeed the industry as a whole, calculate
aquifer use on the basis of AFY, and the WSA/WSV followed CVWD's required methodology.
Comment 83-n:
C. Noise Has Not Been Adequately Analyzed or Mitigated.
Noise pollution, like air pollution, has significant health implications. In analyzing the Wave Festival
Project, Applicant has utilized its existing wave facility in Lemoore, California as a barometer of certain
issues including noise. (See, DEIR at p. 4.11-45.) For example, Applicant states as follows:
Additionally, the noise expert stated that agricultural fields and desert floors are considered soft
surfaces for the purposes of sound propagation. Additionally, the noise expert stated that Coral
Mountain is likely to absorb, rather than reflect noise back towards sensitive receiver locations.
Only hard surfaces, such as pavement, would change the sound attenuation characteristics of the
project. In addition, the worst-case reference noise level conditions were taken during peak wave
noise events at 12 feet, as stated above, whereas Coral Mountain is located approximately 650
feet from the Wave Basin. The reference noise level measurements themselves do not include
any sound attenuation for the agricultural fields. Therefore, although the proposed project is
located on the desert floor and adjacent to Coral Mountain, the noise measurements from the
Lemoore site provide an accurate comparison of noise levels to occur at the project site. Id.
The absurdity of the suggestion that conditions of the Lemoore facility could be likened to the
proposed site of the Wave Festival Project can be seen clearly in an aerial photograph of that facility:
The Lemoore facility is in a rural, agricultural area that is devoid of nearby residential development.
The Wave Festival Project is proposed to be built next to adjoining large and well-developed
residential communities. The concerns that arise in an agricultural area are not the same as they are
in a residential up -scale area like the one that will surround the Wave Festival Project. The
comparison, for analysis purposes, of data from the Lemoore facility is therefore faulty since it is akin
to comparing "apples to oranges."
Moreover, the assertion that Coral Mountain is "likely to absorb, rather than reflect noise back
towards sensitive receiver locations" was never tested or analyzed and is contrary to common sense
and the experience of residents of the City. They know well that noise is AMPLIFIED off the hard
surfaces of the surrounding mountains that are largely devoid of vegetation that might absorb sound
as it does in an agricultural setting like Lemoore, California.
Response 83-n:
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The commenter's opinions are noted, but he does not provide substantial evidence that the
measurement of noise at the Lemoore facility, and the consideration of soft surfaces in the noise
analysis are incorrect. To clarify, measurements of noise levels from the Wave Basin in Lemoore were
taken at eight different locations at and around the Wave Basin, including at the lifeguard tower, the
cable roller system, and a variety of locations around the Wave Basin. (See Noise Impact Analysis,
Appendix K.1 of the DEIR, at pp. 73-74). These noise measurements were undertaken to accurately
characterize the noise created by the equipment and activity at the Wave Basin, including the
machinery that creates the waves. That analysis was appropriate, since the noise source is unique,
and data on noise levels at wave pools are not generally available. Noise levels ranged from 75.7 dBA
near the cable roller system to 62.6 dBA at the end of the Wave Basin. To analyze the "worst-case
scenario" for noise generated by the Wave Basin, the highest noise level of 75.7 dBA was input into
the CadnaA noise model, a three dimensional noise model used to estimate projected noise levels at
various distances from the noise sources, taking into account ground absorption, distance, and
building/barrier noise attenuation factors. Accordingly, the projected noise levels at the receiver
locations set forth in the Draft EIR are based on actual operational measurements input into
established computer modeling protocols, not noise levels in Lemoore at the same distances. The
only noise measurements taken from Lemoore were at the source of the noise itself, and therefore,
the difference between agricultural uses near the Lemoore facility and the proposed project site are
not relevant to the noise level projections set forth in the DEIR.
On the specific question of whether significant noise levels will be amplified by bouncing off Coral
Mountain, Urban Crossroads explained in a supplemental memo that based on Federal Highway
Administration studies and guidance, if all noise striking a hard surface were reflected back to a given
receiving point, the maximum increase in noise would be limited to 3 dBA. However, not all acoustical
energy is reflected back to the same point, and accordingly, FHWA measurements show that
reflective noise increases do not exceed 1-2 dBA, which is not perceptible to the average human ear.
(See Urban Crossroads Memo dated 4/20/21, attached as Appendix K.2 to the DEIR).
Comment 83-o:
Construction and traffic noise are some of the largest producers of noise pollution. Prolonged
exposure to noise pollution can lead to hypertension and heart disease, hearing loss and
consequential sleep disturbances. Wave Basin/Wave machine activity, outdoor pool/spa activity,
outdoor activity, and neighborhood commercial land use activities will run from 7:00 a.m. to 10:00
p.m. (DEIR, at 4.11-44.)
Response 83-o:
The comment asserts health impacts are associated with noise generally, but provides no substantial
evidence that the proposed project will cause any such health impacts. As analyzed in Chapter 4.11
of the Draft EIR, the project will generate construction noise, but will not exceed the FTA acceptable
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level of 85 dBA at any on-site or off-site location and will comply with the City's Municipal Code
restriction on hours of construction (see pp. 4.11-32 — 4.11-35). As stated in the DEIR, although the
project will not cause any significant construction noise impacts, the DEIR identifies four mitigation
measures (NOI-1 through NOI-4) which will further reduce construction noise. Traffic noise was also
analyzed in the DEIR, and the project will not cause any significant traffic noise impacts in the short
term or long term (see pp. 4.11-35 through 4.11-42).
Comment 83-p:
Finally, and most importantly, the Wave Festival Project is also projected to host Special Events as
pointed out above. The Applicant must also properly analyze and mitigate significant impacts from
noise from the Wave Festival Project considering these Special Events. Special consideration as to
when they will be scheduled must also be analyzed. Moreover, special consideration must be given
to the fact that all the proposed residential development will be in the nature of short-term rentals
which are known to create additional noise and havoc in a community. Indeed, the City knows these
problems exist with respect to short-term rentals. (See,
https://www.desertsun.com/story/news/local/la-quinta/2021/07/21/la-quinta-considers-
noisemonitor-mandate-str-properties/8033933002/.) The DEIR has not analyzed these impacts from
the short-term rentals that will be pervasive as the Wave Festival Project. This impact allowing these
rentals is significant since there are no nearby short-term rentals since most are prohibited in nearby
communities.
Response 83-p:
Potential traffic noise from special events was modeled and analyzed in the noise study, and as
discussed at pp. 4.11-40 and 4.11-41 of the DEIR, the special events will not cause any significant noise
impacts. The operational noise from the project was modeled by evaluating noise at the existing
Wave Basin in Lemoore, California, as well as noise at a pool at a local resort, a neighborhood park,
and a neighborhood commercial center operating simultaneously. Operational noise levels were not
projected to exceed 65 dBA at any off-site locations, and as a result, the project will not have any
significant operational noise impact on the existing residential communities in the project vicinity.
As it relates to the commenter's assumptions relating to short term rentals as a source of excessive
noise, without substantial evidence, short-term rentals will be subject to the City's noise ordinance
and Municipal Code provisions on short-term vacation rentals to ensure no significant noise impacts
to other communities in the project vicinity. As explained in the Desert Sun article cited in this
comment, the City completed a pilot program to determine whether mandatory noise monitors at
short term vacation rental locations would increase property owner attentiveness to neighbor
complaints and reduce such complaints. To the extent the City adopts a noise monitoring
requirement for short-term rentals, any short-term rentals within the project would be subject to that
requirement. The City's noise standards apply to all areas of the City, and will apply to the proposed
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project. Should noise from a short term rental be in violation of the City's noise ordinance, it will be
enforced in the same manner at the project site than it would be anywhere in the City.
Comment 83-q:
The former project, where the Wave Festival Project is proposed, envisioned a quiet golf -based
community with little noise emanating from that project. The City generally enjoys a quiet noise
environment, with existing community noise being dominated by highway and local traffic,
intermittent aircraft flyovers, and commercial operations. The City enjoys an enviable quiet
environment that must be considered and not compromised in the manner sought by Applicant. Low
noise levels are a major economic asset of the City's resort and residential atmosphere and it is
precisely that reason that residents have relocated to the City. The Wave Festival Project, however,
anticipates that the Applicant will conduct Special Events including concerts and hosting large-scale
surfing venues with music. These issues have not been properly addressed or analyzed in the DEIR.
All these elements will contribute heavily to noise pollution in the area. Noise pollution does not only
adversely affect human lives. Wildlife, especially birds, are heavily impacted by increased noise
pollution. Communication, mating behavior, hunting and survival instincts of animals are altered by
excessive noise. As such, the City should carefully review proposals such as the Wave Festival Project
which we believe to be incompatible with the quiet environment present in the City.
Response 83-q:
Please see the Topical Response on Noise in Section 2.2.4, as it relates to noise levels and the City's
noise standards. The comment incorrectly states that the project proposes concerts and large-scale
surfing events with music, as part of future special events. This is not accurate, as neither concerts
nor large-scale surfing events are proposed. Any special events would remain subject to the same
Wave Basin capacity limits, which include a maximum of 30 surfers at any one time, as well as
maximum total limitation of 2,500 special event attendees. By comparison, the large-scale music
festivals in Indio can have in excess of 100,000 guests daily.
Further, the number of these special events would be limited to no more than 4 per year and each
would only be authorized through review and approval of a temporary use permit from the City,
which includes demonstrating that the event will not violate the City's Municipal Code or cause
significant noise, traffic or other impacts. As it relates to noise levels and biological resources, please
see Response 14-q. In addition, Mitigation Measures TRA -9 through TRA -14, and BIO -4 and BIO -7,
will ensure that special event traffic will not cause any significant traffic impacts, and that Wave Basin
lighting and noise levels do not impact wildlife using Coral Mountain, respectively. Please also see
Responses 13-q and 13-r.
Comment 83-r:
D. Air Quality Has Not Been Adequately Analyzed or Mitigated.
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The Wave Festival Project will also result in significantly compromised air quality in the area
throughout the construction process, and potentially once the development is completed. Removal
of stabilized soils and biological soil crust creates a destructive cycle of airborne particulates and
erosion. As more stabilized soils are removed, blowing particulates from recently eroded areas act as
abrasive catalysts that erode the remaining crusts thus resulting in more airborne particulates.
The Coachella Valley is in the Salton Sea Air Basin ("SSAB") under South Coast Air Quality Management
District jurisdiction. (DEIR, at 4.1-2.) The regional climate, as well as the temperature, wind, humidity,
precipitation, and amount of sunshine significantly influence the air quality in the SSAB. Currently,
state and federal air quality standards are exceeded in most parts of the SSAB. (DEIR, at 4.1-16.)
Construction activities associated with the Wave Festival Project will result in emissions of VOCs, NOX,
SOX, CO, PM10, and PM2.5, which includes site preparation, grading, building construction paving,
and architectural coating. (DEIR, at 4.1-18.) A development with this effect on emissions is
unacceptable amidst the current state of our climate crisis.
Response 83-r:
The Draft EIR thoroughly analyzed the project's construction related emissions using universally
accepted modeling techniques, and determined that, with implementation of the specified mitigation
measures and project design features (PDFs), the project will not exceed criteria pollutant thresholds
established by SCAQMD or have any significant adverse effects (see DEIR pp. 4.1-15 — 4.1-23 and 4.1-
31— 4.1-40). SCAQMD is the expert agency entrusted with and responsible for air quality monitoring
and permitting in the air basin, and its thresholds of significance, as described on page 4.1-12 of the
Draft EIR, are the appropriate benchmark on which to base air quality analysis for the project As
explained in the DEIR, compliance with the applicable SCAQMD Rules and the City of La Quinta's
fugitive dust control ordinance limit the generation of PM10 and other fugitive dust during
construction activities to levels that are below the SCAQMD thresholds.
Comment 83-s:
The Wave Festival Project could result in significant impacts health effects from air quality emissions
as well considering the significant nature of the Special Events as has been outlined above. In Sierra
Club v. County of Fresno (Friant Ranch, L.P.) (2018) 6 Ca1.5th 502, the Court held that air quality analysis
must make a reasonable effort to substantively connect a project's air quality impacts to likely health
consequences. Any consideration of air quality must address the health effects to nearby sensitive
receptors from the large quantity of idling vehicles consistent with a development of the type sought
by Applicant. As pointed out above, because of the transient nature of the visitors to the Wave
Festival Project because of short-term rental and the significant impact of the Special Events, there
will likely be many idling vehicles. The analysis of the DEIR, to actually demonstrate that there are no
significant impacts to air quality, is required to "connect" adverse human health effects to the levels
of pollutants that would be emitted by the Wave Festival Project. The DEIR fails to do so.
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Response 83-s:
Despite the commenter's assertion, the comment does not provide substantial evidence that a "large
quantity of idling vehicles" will result from the proposed project. To the contrary, the DEIR specifically
evaluates vehicle emissions and other potential air quality emissions during special events at the
project (see pages 4.1-29 — 4.1-31 of the Draft EIR), and determined that with implementation of
applicable PDFs, including pedestrian connectivity and a complimentary mix of land uses, as well
Mitigation Measure AQ -3, daily emissions during special events, with a maximum of 2,500 guests,
will not exceed any SCAQMD thresholds of significance. The DEIR also discusses the health impacts
that would result from the exceedance of these thresholds of significance, but with implementation
of the specified PDFs and mitigation measures, these adverse health effects will be avoided, as
concluded on page 4.3-44 (also see Appendix A, at pp. 47-59).
Comment 83-t:
E. Greenhouse Gas Emissions Have Not Been Adequately Analyzed or Mitigated.
The DEIR needs to go further in addressing the spike in greenhouse gas emissions during the
potentially multiple year construction and because of the Special Events and short-term rentals.
The Wave Festival Project will be constructed in three phases and will take approximately six (6) years
to complete. (DEIR, at 4.1-19.) Due to the use of heavy construction equipment, unsafe levels of air
pollutants would have an impact on the surrounding community and wildlife during that time. The
presence of toxic air contaminants during construction is discussed in relation with the sensitive
human receptors but ignores construction pollutant impact on wildlife and the ecosystem. For
example, alpine and subalpine ecosystems could decline by as much as 60 to 80% by the end of the
century because of increasing temperatures. (DEIR, Appendix I [GHG Report], p. 20.] The City may not
hide behind a self-serving threshold to avoid this significant impact.
Response 83-t:
The project's potential impacts relating to GHG emissions are analyzed in Section 4.7 of the DEIR and
in the Coral Mountain Specific Plan Greenhouse Gas Analysis (GHGA) included in Appendix 1 to the
DEIR. The DEIR analysis also references and relies upon a number of public regulatory and reference
documents regarding the effects of GHG emissions and the measures taken by the State of California
and its agencies to substantially reduce GHG emissions. To meet California's adopted standards for
the reduction of GHG emissions, SCAQMD has provided guidance for public agencies to use to
establish project -level screening thresholds of significance under CEQA. Based on this guidance, and
the City's own Greenhouse Gas Reduction Plan, the City established a threshold of 3.65 metric tons
of CO2 emissions per service population annually as the analysis threshold for the project. This
threshold is consistent with SCAQMD guidance, including taking into account the most recent target
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of reducing emissions to a level of 40% below 2020 levels by 2030, as discussed in Section 14.7 and in
the project -specific GHG Analysis (Appendix 1).
As explained in the DEIR, the GHGA quantified the construction and operational GHG emissions that
will be generated by the project, including those from special events, and determined that with
incorporation of the specified PDFs and mitigation measures, the project would generate a total of
3.62 MTCO2e per service population, which is below the established threshold of significance (page
4.7-20). However, as this calculation depends, in part, on the purchase of carbon credits under
Mitigation Measure GHG-1, and because the purchase of carbon credits has not been widely adopted
in the Coachella Valley for residential and resort communities, the Draft EIR conservatively concluded
that the project's GHG emissions should be considered significant and unavoidable. Contrary to the
author's comment, the City is not "hiding behind a self-serving threshold," but instead, thoroughly
quantified and analyzed the project's construction and operational generation of GHG emissions,
identified ways to substantially reduce those emissions to the greatest extent feasible, and then
conservatively disclosed the worst-case scenario, specifically, that the project could cause significant
and unavoidable levels of GHG emissions if the purchase of carbon credits is not a feasible or
successful mitigation measure in the Coachella Valley. As allowed under CEQA Guidelines Section
15043, the City has identified a potentially significant and unavoidable impact, and fully disclosed it
to the public and decision makers. The City will, also as allowed under CEQA, consider whether this
potentially significant impact is outweighed by defined project benefits, and whether the EIR should
be certified through the hearing process, and the adoption of findings.
Comment 83-u:
F. Cumulative Impacts Have Not Been Adequately Analyzed or Mitigated.
As written, the DEIR also glosses over the aggregate environmental impacts of the Wave Festival
Project and misleads the reader through words such as "may" and "potentially." This Project cannot
be viewed independently from other planned developments in the region. The EIR needs to address
the cumulative effects of the Wave Festival Project in relation to other nearby projects and planned
developments.
The cumulative impact from several projects is the change in the environment which results from
the incremental impact of the project when added to other closely related past, present, and
reasonably foreseeable probable future projects. Cumulative impacts can result from individually
minor but collectively significant projects taking place over a period of time.
(14 Cal. Code Regs. § 15355(b).) Traffic, water demands, greenhouse gas emissions, noise and air
pollution are aggregate and have cumulative effects. It would be disastrous oversight for the City to
allow the Wave Festival Project to move forward without fully analyzing this Project impact in relation
to the overall impact of other projects in the region that are currently in development or in the
planning stages. This is especially true given the fact that the DEIR did not consider the scheduling of
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Special Events (not defined or discussed in the DEIR), and their otherwise enormous impact vis-a-vis
other festivals in adjoining communities such as Coachella and Stagecoach and the impact of the
short-term rentals (again, not addressed in the DEIR.)
Response 83-u:
This comment is not correct, as each chapter in the DEIR specifically addresses cumulative impacts
for the topic covered in that Chapter (i.e., traffic, hydrology, noise, GHG emissions, etc.), and
evaluates the potential cumulative impacts consistent with the requirements of CEQA Guidelines
section 15130. As specified in Guideline 15130, the cumulative impact analysis can be based upon a
summary of projections contained in an adopted plan, including a General Plan, which is how the
cumulative impact analysis was conducted in the DEIR. Cumulative impacts for the topics identified
in this comment are addressed in the Draft EIR on the following pages: traffic at pages 4.13-57 — 4.13-
61; water supplies at pages 4.15-34 — 4.15-35; noise at 4.11-51 — 4.11-54; GHG emissions at pages
4.7-25 — 4.7-26; and air quality at pages 4.2-41— 4.2-42.
As to other special events in the region that are outside the jurisdiction of the City, no separate
analysis is required because the commenter's assertion that special events will occur at the same time
as other, much larger events elsewhere in the valley is entirely speculative. As provided in CEQA
Guideline 15145, speculation is not appropriate in an EIR, and the City did not engage in speculation
in analyzing the impacts of the project. Furthermore, special events outside the jurisdiction of the City
of La Quinta are sufficiently removed geographically that, when considered in conjunction with the
limited size (2,500 guest maximum) of any project special events, would not have combined
environmental effects. Given this geographic distance and the limited size of the project's proposed
special events, such special events would not cause cumulatively considerable contributions to the
traffic, noise or other impacts of the 100,000+ person music festivals referenced in this comment,
that occur in the neighboring city of Indio. In addition, the mitigation measures identified in the DEIR,
such as TRA -9 — TRA -14, regarding the need for a traffic management and parking plans prior to
approval of any special use permits for special events at the project, will further ensure that the
project will not cause any cumulatively considerable contributions to the impacts caused by major
festivals in the region.
Finally, as described extensively in responses to multiple issue areas above, the impacts of special
events have been fully disclosed in the EIR, and the assertion that they are "not defined or discussed
in the EIR" is false. The comment references short-term rentals as a potential source of significant
cumulative effects but fails to provide any substantial evidence showing any such effects would occur.
As each topic area analyzes the operational impacts of the project with all residences occupied,
including traffic and noise, no further cumulative impacts from short-term rentals of such residences
are anticipated. Please also se Response 52-g.
Comment 83-v:
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IV. THE DEIR IS INCONSISTENT WITH GENERAL PLAN PROGRAMS AND LAND USE POLICIES.
CEQA requires that environmental impact reports analyze the consistency of a project with applicable
local plans, including General Plans. (See Napa Citizens for Honest Govt. v. Napa County Bd. of
Supervisors (2001) 91 Cal.App.4th 342, 386-87; 14 Cal. Code Regs. Appendix G, § IX(b).)
Inconsistencies with a General Plan or other local plan goals and policies that were enacted to protect
the environment are significant impacts in themselves and can also be evidence of other significant
impacts. (See id.; Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903, 929.)
"The general plan is more than the legal underpinning for land use decisions; it is a vision about how
a community will grow, reflecting community priorities and values while shaping the future." (See,
General Plan Guidelines; Published by the Governor's Office of Planning and Research
(https://opr.ca.gov/docs/OPR_COMPLETE_7.31.17.pdf )).
The City must abide by its general plan since it is, in essence the "Constitution" of the City:
"[T]he general plan [is] a ' "constitution" for future development' [citation] located at the top of
'the hierarchy of local government law regulating land use' [citation].
The general plan consists of a 'statement of development policies ... setting forth objectives,
principles, standards, and plan proposals.' [Citation.] The plan must include seven elements—land
use, circulation, conservation, housing, noise, safety and open space—and address each of these
elements in whatever level of detail local conditions require [citation]. General plans are also
required to be 'comprehensive [and] long[]term' [citation] as well as 'internally consistent.'
[Citation.] The planning law thus compels cities and counties to undergo the discipline of drafting
a master plan to guide future local land use decisions." (DeVita v. County of Napa (1995) 9 Ca1.4th
763, 772-773 [38 Cal. Rptr. 2d 699, 889 P.2d 1019], fn. omitted.)
Since it is essentially the Constitution of the City, a general plan cannot be lightly amended. Much
thought and deliberation go into the formation of the general plan and any amendment thereto. The
City is well of aware of this fact and its last update its general plan took place over a period of years.
(See, https://www.laquintaca.gov/business/Ig2035-general-plan/documents) Key to any such
updates is community participation which is integral to the update process. The City's general plan is
the 2035 La Quinta General Plan (General Plan).
Here, Applicant seeks an extraordinary request from the City in connection with the Wave Festival
Project, i.e., an amendment to the City's General Plan. This request skirts and short circuits the normal
procedure that the City undertakes when it amends its General Plan which involves years of
deliberations and community input. Moreover, such a request short circuits the expectations of
residents of the City who invest their life savings in the City in purchasing residences based on their
belief that the values of the General Plan will hold true for the foreseeable future. It is for that reason
the City must tread lightly and consider the request of the Applicant with great concern. Here, the
Applicant requests a dramatic change to the City's General Plan. The General Plan Amendment (GPA
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2019-0002) will amend the current General Plan land use designations from General Commercial, Low
Density Residential, and Open Space – Recreation to Neighborhood Commercial, Low Density
Residential, Tourist Commercial, and Open Space. (DEIR, at 3.5.2.) The Wave Festival Project bears
NO relationship to the development that had been originally entitled for that area. The request of the
Applicant is for a wholesale change in the character of the land where they propose to build. The DEIR
briefly states, "The project site is surrounded by developed residential communities..." A serious
examination of the area shows The Quarry, Santerra, Coral Mountain Estates, Andalusia, and Trilogy
residential communities surround the proposed location. Additionally, new home developments
immediately south of the proposed location have been approved or are in review including the 57
residential Estate Collection at Coral Mountain and the 1,200 residential Travertine community—a
fact omitted from the EIR. Clearly, the Wave Festival Project is a "horse of a different color" entirely
and is primarily a commercial enterprise where low-density housing is slated to be built.
Response 83-v:
While it is true that a General Plan is "at the top of the hierarchy of local government law regulating
land use," as cited in the comment, that does not mean that General Plans are not routinely amended.
If fact, Section 65358 (a) of the California Government Code states that a legislative body may amend
all or part of an adopted general plan. The only limitation on amending an adopted general plan in
Section 65358 (b) is that no mandatory element of a general plan can be amended more frequently
than four times during any calendar year for a general law city. La Quinta, as a charter city, has no
such limitation. Contrary to the commenter's assertion, and as provided in the City's Municipal Code,
Section 9.230.010, a General Plan Amendment may be made at any time, as determined by the
legislative body. Each amendment may include more than one change to the general plan.
Consistent with state law, both the City's 2035 General Plan and the Municipal Code provide that any
property owner or citizen may initiate a General Plan Amendment (See 2035 General Plan at pp. 1-7
– 1-8; and LQMC Chapt. 9.230). On page 1-7 of the General Plan itself, under the heading "Amending
the General Plan," it provides that "[t]he General Plan is a multi -faceted document, which defines and
addresses the changing needs of the City. It is also based on an ongoing assessment and
understanding of existing and projected needs." Several of the other projects on the City Planning
Department list of current projects also include proposed or approved General Plan Amendments,
including Centre at La Quinta, Codorniz, and Travertine.
This comment also states that the DEIR omits discussion of two new residential communities in the
project vicinity, the Estate Collection at Coral Mountain and Travertine. It is not clear whether the
commenter raises this issue to bolster his argument that the project is not compatible with these
residential neighborhoods, or to assert some error in the project's cumulative impact analysis. If the
latter, the cumulative impact analysis is properly based on General Plan buildout, which includes the
additional residential units proposed in those communities (see 2035 General Plan, General Plan Land
Use Plan and Table 11-3 [Land Use Summary] at pp. 11-8 through 11-12). If the former point, the DEIR
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addresses land use compatibility with regard to all surrounding land uses, and with respect to specific
impacts in the Draft EIR discussion of each environmental impact as appropriate.
The commenter characterizes the proposed General Plan Amendment as a "wholesale change in the
character of the land" proposed for development by the project, but in fact, the project retains the
low density, neighborhood commercial and open space land uses on most of the project site, including
the entire perimeter of the site. Less than one-third of the site is proposed for development under
the City's Tourist Commercial land use designation, and this area is buffered from the surrounding
communities by more than two hundred acres of low-density residential development, as well as
perimeter walls and landscaping that are fully consistent with the surrounding communities.
Comment 83-w:
The DEIR's analysis of the Wave Festival Project's consistency with the General Plan is fundamentally
flawed. The DEIR takes the position that because amendments and minor adjustments to the General
Plan are proposed, the Wave Festival Project would be consistent with both documents, and,
therefore, any conflicts with plans would be less than significant. (DEIR, at 4.10-1.) To evaluate the
accuracy of this statement and the Wave Festival Project's consistency with the General Plan, the
DEIR must identify the "minor adjustments" to the plan's policies. Unfortunately, the DEIR fails to
provide this critical information.
Response 83-w:
The Draft EIR states in both Chapter 3.0, Project Description (p. 3-9), and Section 4.10, Land Use and
Planning (pp. 4.10-2 — 4.10-4), that the proposed General Plan Amendment will amend the current
General Plan land use designations from General Commercial, Low Density Residential, and Open
Space — Recreation, to Neighborhood Commercial, Low Density Residential, Tourist Commercial, and
Open Space — Recreation. This comment also cites Draft EIR p. 4.10-1 for a statement about General
Plan consistency and minor adjustments that is not accurate and does not appear on that page of the
Draft EIR.
Comment 83-x:
Moreover, in its analysis, the DEIR glosses over numerous, glaring inconsistencies to reach the
contrived conclusion that the Wave Festival Project is somehow consistent with the General Plan. In
addition to misinforming decision -makers and the public about the Wave Festival Project's
consistency with the General Plan, this analysis underestimates the actual impacts of the Wave
Festival Project and ignores some of the Wave Festival Project's most significant impacts. The DEIR
must be revised and recirculated to provide a comprehensive and accurate analysis of all General Plan
inconsistencies.
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Numerous goals and policies within the City are relevant to the Wave Festival Project. Many of these
goals and policies are directly at odds with the Wave Festival Project. Some of the most egregious
violations are discussed below.
Response 83-x:
This comment asserts that the Draft EIR misinforms decision -makers and the public regarding the
project's alleged inconsistencies with the General Plan. However, the comment provides no specific
examples of any such alleged inconsistencies, and instead, serves as an introduction to the comments
that follow. As described in more detail in the following responses, the Draft EIR provides an analysis
of the project's consistency with the General Plan's applicable goals, policies and programs regarding
Land Use, Circulation, Livable Communities, Economic Development, Parks, Recreation and Trails,
Housing, Water Resources, Open Space and Conservation, Noise, Soils and Geology, Flooding and
Hydrology, Hazardous Materials, Emergency Services, and Water, Sewer and Other Utilities on pages
4.10-15 through 4.10-24. Moreover, the California courts have consistently held that an EIR does not
need to evaluate the project's consistency with every General Plan goal, policy and program. Rather,
"[b]ecause EIRs are required only to evaluate 'any inconsistencies' with plans, no analysis should be
required if the project is consistent with the relevant plans." Stop Syar Expansion v. County of Napa
(2021) 63 Cal.App.4th 444, 460 (quoting Pfeiffer v. City of Sunnyvale City Council (2011) 200
Cal.App..4th 1552, 1556; and see South of Market Community Action Network v. City and County of
San Francisco (2019) 33 Cal.App.5th 321, 352-354. As described above and in Response No. 79-1, the
Draft EIR thoroughly analyzes the project's consistency with the General Plan and other applicable
plans.
Comment 83-y:
A. The Wave Festival Project is Inconsistent with General Plan Policies Pertaining to Water Usages.
The General Plan embodies values and principles that recognize the importance of the water
resources in the area, including maintaining water availability to provide domestic water to existing
developments in the City. Despite these important principles, the DEIR fails to provide any General
Plan consistency analysis for water. The following goal is indisputably linked to protecting the
environment through avoiding impacts on water resources:
GOAL -WR -1
GOAL -WR -1 states: "The efficient use and conservation of the City's water resources." The General
Plan acknowledges that continued growth in the City and the region has resulted in an increased
demand for domestic water. As a result, CVWD extracts more water from the lower thermal subarea
than is naturally recharged into it every year — a condition known as overdraft. (General Plan, p. III -
58.) It further states that increased development will contribute to greater demand for water
resources and the potential for continued overdraft. (Id.)
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This Project is enormous and will require significant amount of the City's valuable water resources.
At project buildout, the Wave Festival Project could accommodate approximately 7.77 acres of
Neighborhood and Wave Farm Commercial uses; 232.07 acres of Low Density Residential; 117.70
acres of Hotel/Resort uses comprised of the hotel, the Wave Lagoon, attached residential uses and
various resort related amenities; and 27.01 acres of Open Space. The low-density residential land use
will include 496 units of detached residential. The hotel resort land use proposes 150 hotel keys, 104
attached resort residential units and 55,000 square feet of commercial uses.
The 16 -acre surf Wave Basin and lagoon will serve as the focal point of the development. The
estimated total domestic water demand for indoor and outdoor use is approximately 941.03 acre-
feet per year (AFY), or 2.45 acre-feet per acre. The residential indoor demand estimate is 97.22 AFY,
the non-residential indoor use estimate is 42.34 AFY, and the outdoor estimate is 801.47 AFY. (WSA,
p. 20.) The majority of the water use is the outdoor water demand, which equates to an outrageous
260,986,749.15 gallons of water per year. With precious water resources, a huge surf lagoon in the
middle of the desert clearly does not comply with General Plan GOAL -WR -1 as an efficient use of
water. The Wave Festival Project's inconsistency with this General Plan Goal constitutes a significant
impact.
Response 83-y:
This comment quotes the General Plan Goal WR -1 ("The efficient use and conservation of the City's
water resources") and asserts that the Project does not comply with the goal of efficient water use.
However, the comment does not identify any particular General Plan policies or programs that are
inconsistent with or prohibit any of the project's proposed uses of water. The General Plan does not
identify any specific limits on the amount of water that should be used by any particular project or
use, and instead, establishes policies to support CVWD's efforts to supply adequate domestic water
to residents and businesses by continuing to implement the City's landscape ordinance and building
codes (see Policy WR -1.1 and Program WR -1.1a).
Here, the project fully complies with the City's landscape ordinance and CVWD's limit on outdoor
water use. As set forth in the DEIR and the WSA/WSV, the Maximum Applied Water Allowance
(MAWA) for outdoor water use for the project site is 962 AFY. The project, including the Wave Basin,
is projected to use 801.47 AFY for outdoor uses, or approximately 83.3% of what is allowed under
CVWD's and the City's landscape ordinances. (See, e.g., DEIR at p. 4.15-31.) Accordingly, the project
not only complies with both City and CVWD water use standards, but in fact uses materially less
outdoor water than the maximum amount of water consistent with the efficient use of water.
Specifically, the project will reduce outdoor water use from 921.02 AFY, for the currently permitted
land uses, to 801.47 AFY, as set forth in the Draft EIR at pp. 4.15-15 — 4.15-16 and 4.15-34. This is
entirely consistent with Goal WR -1.
Comment 83-z:
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B. The Wave Festival Project is Inconsistent with General Plan's Policies Pertaining to Aesthetics and
Light Pollution.
It is undisputable that the Wave Festival Project — given the height, bulk, and scale of its proposed
structures — would irreparably alter the community's character and views of the surrounding
mountains. By the DEIR's own admission, the Wave Festival Project's impacts on scenic vistas, the
visual character or quality of the site, scenic resources, and light and glare would be significant and
unavoidable. (DEIR at 1-15.) The DEIR's conclusion that the Wave Festival Project would not conflict
with the General Plan policies pertaining to aesthetics would be laughable if the implications were
not so ominous. Certain of the most egregious violations include:
Guiding Principle:
One of the guiding principles of the General Plan is to reduce light pollution. (General Plan, p. 1-3.)
The Wave Festival Project is blatantly inconsistent with this principle. The Wave Festival Project
proposes 80 -foot -high light fixtures. The 80 -foot light fixtures proposed for the project would be
located around the Wave Basin to illuminate the recreational facility during the evenings. (DEIR, at
4.1-56.) The Wave Festival Project proposes seventeen (17) 80 -foot lights, separated approximately
20 feet from each other. The light poles lie within the line of sight for motorists and pedestrians, and
visible to the properties south of the Wave Festival Project. (DEIR, at 4.1-39, 4.1-41.) Even worse, the
lights will operate from dust to 10 PM. (Id.)
As opined by Minagar & Associates in their comment letter of August 2, 2021 (see, Exhibit 3), the
analysis contained in the DEIR is defective in several respects:
Providing the right lighting solution for an exterior application should take into consideration
glare, along with the specific site requirements for spacing, efficiency, and visual comfort. Current
means of measuring glare in exterior applications are not fully defined or comprehensive. Ways
to is by the following: Shielding, diffusion, selection of warm CCTs, and reducing contrast of the
Effective Luminous Area. Reducing glare may reduce the efficiency of the luminaire and the
spacing, height which were not addressed in this DEIR report nor in Appendix B due to cost and
potential redesign of the project. We have to bear in mind that, the level of glare that an individual
experiences is highly subjective. Therefore, the designers should install mock-ups in order to
confirm adequate performance and visual comfort of the concerned parties affected by such
installation. Shielding and Diffusion in LED Luminaires has not been explored in the DEIR report
nor in Appendix B. There is no alternative solution/ study provided for the intensity from the
luminaire, the number of luminaires, the size of the luminaire, and the height or the angle of the
luminaire. The proposed lighting plan does not provide any gradients. It immediately changes
between dark and bright. For older residents/visitors in the surrounding area of the proposed
project site, it will inevitably create a lot of discomforts especially bothering some individual's
eyes.
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Response 83-z:
To be clear, the Draft EIR did not determine that impacts associated with light and glare would be
significant. As described on page 4.1.60 through 4.1-70, impacts associated with light and glare were
found to be less than significant. Please also see the Topical Response on Light and Glare in Section
2.2.1.
As explained in the Draft EIR, the lighting for the Wave Basin includes shielded, directional energy
efficient LED light fixtures that will prevent light spillage outside of the Wave Basin planning area (see
Draft EIR pp. 4.1-60 — 4.1-63). While this comment fails to identify any specific General Plan goals or
policies that the Wave Bain could possibly violate, the Wave Basin lighting does comply with the
applicable provisions of the La Quinta Municipal Code, as explained on the Draft EIR pages cited
above. Specifically, the shielded and directional lights proposed will not emit light onto adjacent
properties and will comply with the allowed hours of operation for recreational lighting (10:00 p.m.
cutoff). Please also see Section 2.2.1 above for a thorough response to comments concerning the
project's potential light and glare impacts.
The Minagar & Associates letter quoted in the comment regarding the impacts of LED lighting are
speculative and do not provide substantial evidence that changes may occur in the design of the
lighting. The concerns relating to shielding certainly do not apply to the TLC lighting proposed for the
Wave Basin component of the project. The Musco memo (Appendix B.1) explains the details of how
the specific height of the proposed light fixtures, the shielding from the fixture visor, and the ability
to directionally aim the lighting will allow the system to light the Wave Basin without creating any up
lighting or unwanted light spillage, thus ensuring dark skies compliant lighting. It is important to note
that the Wave Basin light system was optimized to avoid light spillage, and if the light fixture heights
were reduced, the light cut off angle would need to be increased to cast light across the water surface,
which would result in more light and glare. Consequently, as described in the EIR, the height of the
light poles is optimal for lighting the project while at the same time minimizing any appreciable light
and glare impacts to Coral Mountain and adjacent properties. The analysis has further been
supported by the demonstration conducted on November 17, which included the installation of
"mock-ups" suggested by Minagar & Associates (see Appendix B.2 of this Final EIR).
Comment 83 -aa:
Nor does the DEIR address concerns that are specific to the City and desert conditions. The City is
regularly buffeted by high winds. As a result, there is silica particulate blown about in the area of the
proposed project. That particulate is highly reflective. Nowhere in the DEIR does the Applicant
address this important issue.
The DEIR did not, then, properly analyze the light and glare emanating from the enormous 80 -foot
towers that will be constructed. There are no actual mockups of the proposed towers that would
provide real and credible analysis of their impacts, for example.
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Response 83 -aa:
While the comment does not provide any evidence or other information showing how winds would
affect the lighting analysis in Appendix B of the Draft EIR, the lighting analysis in Appendix B and the
further information in the supplemental Musco memo, plainly demonstrate that the proposed
lighting system has been optimized to reduce light and glare and avoid any significant light or glare
related impacts to adjacent properties or the public. Also see Response 83-z as it relates to "mock-
ups.
II
Comment 83 -bb:
Moreover, the analysis of the DEIR did not consider the darkened skies of the surrounding
environment in the Coachella Valley. It is a much -hallowed quality that municipalities and
homeowner's associations go to great lengths to make certain that ambient light is dampened or
eliminated, e.g., some communities prohibit or limit light posts. This darkened atmosphere opens the
night skies to the beauty of illuminating stars. These darkened skies then are a particularly bad
backdrop from the glare that will most assuredly emanate from the 80 -foot light towers that Applicant
proposes especially when windstorm lift reflective particulate into the air. The light and glare
generated from the fixtures would result in significant impacts and is in direct contrast to the City's
principle to reduce light pollution..
Response 83 -bb:
First, the commenter is correct that La Quinta limits lighting in order to assure dark skies. As described
in the EIR (see page 4.1-60 and 4.1-61), the analysis is based on the City's lighting standards, which
require that lighting plans demonstrate that light not extend beyond property lines. That standard
was correctly analyzed in the EIR. As explained above and in the DEIR, the Wave Basin lighting system
is fully dark sky compliant and uses TLC for LED technology to effectively light the Wave Basin while
generating a fraction of the light and glare typically visible at parks and other recreational facilities
that use older generations of lighting technology or standard LED lighting (see pages 1-2 of Appendix
B.1). As explained in the Musco memo, the lighting at the Bagdouma Sports Park in Coachella consists
of "a combination of light fixtures from Musco, including the 2005 lights and 1989 unshielded lights,
with respective candela ratings of 11,858 and 21,400," as compared to the 7 candela generated by
the proposed TLC lights proposed for the project (see Musco memo, Appendix B.1 of this Final EIR, at
p.2). Accordingly, the EIR demonstrates that the Wave Basin lighting will generate far less light and
glare than the existing lighting in the community and will avoid any significant impact on the area's
dark skies.
Comment 83 -cc:
GOAL OS -3:
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Goal OS -3 states the importance of the preservation of scenic resources as vital contributors to the
city's economic health and overall quality of life. (General Plan, at 11-30.) The Wave Festival Project
causes a significant change in the visual character of the area from a singlestory residential and golf
environment to a hotel and Wave Basin facility. As determined in the line -of -sight analyses and visual
simulations, the project site will result in the partial obstruction of views of Coral Mountain and the
Santa Rosa Mountains, depending on location and viewpoint. Therefore, development of the project
property would result in obstructed and partially obstructed views of these scenic resources. (DEIR,
at 4.1-44.) The Wave Festival Project's clear inconsistency with this General Plan Goal constitutes a
significant impact.
Response 83 -cc:
The comment does not mention the three policies in the General Plan supporting this goal all make
clear that the City's policies to meet this goal involve avoiding development in designated open space
areas within hillside and visually prominent areas. Furthermore, to the extent development of
designated open space is allowed, grading and structures should be visually subordinate and
compatible with surrounding landscape features (see 2035 General Plan 111-73 and 111-74). The
project does not propose any development in such designated open space areas, and instead,
proposes development of a site that has been planned for residential and golf course development
since the time the property was annexed into the City of La Quinta in or about 2002. Accordingly, the
project is consistent with General Plan Goal OS -3.
In addition, and unrelated to the Open Space goal cited in the comment, the Draft EIR thoroughly
analyzes the project's impacts on scenic vistas and the visual character of the site and surrounding
area (see DEIR pp. 4.1-22 — 4.1-60). This analysis includes line -of -sight and visual simulations of the
project from 5 different locations surrounding the project (see Exhibits 4.1-4 — 4.1-13). Based on this
evidence, the DEIR concluded that the Wave Basin lighting and buildings in the Tourist Commercial
area (Planning Area III) will not have a significant impact on existing views of scenic vistas due to their
location far into the interior of the project, and their distance from off-site viewing locations (see DEIR
p. 4.1-40).
The DEIR further concluded that development of the project will result in the obstruction of existing
views of Coral Mountain from certain locations along the perimeter roads surrounding the project
due to construction of the walls, landscaping, and homes along the perimeter of the site. The DEIR
notes that these improvements are consistent with the perimeter walls, landscaping and homes in
the surrounding communities, and their impact on existing views of scenic resources would result
from any development of the project site (see DEIR pp. 4.1-44 — 4.1-45).
Even though this impact is mitigated to the maximum extent feasible through implementation of
Mitigation Measures AES -1 and AES -2 (setting back the perimeter walls and residential structures
further from the perimeter roads than required under the City's Municipal Code), the change in
existing views is identified as a significant and unavoidable impact of the project, even though the
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impact would be consistent with the visual character of the surrounding developments. While this
constitutes a significant aesthetic impact, as disclosed in the DEIR, it does not reflect any inconsistency
with applicable policies in the 2035 General Plan.
Comment 83-dd:
Policy LU -2.3:
Policy LU -2.3 states that the City's outdoor lighting ordinance will be maintained. The La Quinta
Municipal Code ("LQMC") Section 9.100.150, Outdoor Lighting, is intended to provide standards for
outdoor lighting which allow adequate energy efficient lighting for public safety while minimizing
adverse effect of lighting, such as lighting which has a detrimental effect on astronomical
observations; inefficiently utilizes scarce electrical energy; and/or creates a public nuisance or safety
hazard. As set forth above, the Wave Festival Project site, which is currently undeveloped and vacant,
provides largely unobstructed views of Coral Mountain and the Santa Rosa Mountains from public
rights -of -ways. (DEIR, at 4.1-72.) However, because of the enormous light poles around the Wave
Basin, it will create an unsafe glaring off the roads where cars travel. The Wave Basin lights will be
projected until 10 p.m. at night. The bright lights at the Wave Basin in the evening hours will clearly
conflict with the City's policy for public safety under the LQMC outdoor lighting ordinance.
Response 83-dd:
As described in the DEIR, the project lighting fully complies with the City's outdoor lighting ordinance,
which is set forth in Section 9.100.150, including shielding requirements and hours of operation for
recreational lights (see DEIR pp. 4.1-60 — 4.1-63). The pole lights will be located 1,274 feet from the
public viewing point on Avenue 60, 2,745 feet from Madison Street, and 4,002 feet from Avenue 58
(see Exhibits 4.1-6, 4.1-10, and 4.1-12 in Draft EIR). The lights will have no impact on public streets.
Please also see the detailed description of the proposed Wave Basin lighting in Response No. 83-z
above. The project is therefore not in conflict with Policy LU -2.3.
Comment 83-ee:
C. The Wave Festival Project is Inconsistent with General Plan Policies Pertaining to Noise Pollution.
Notwithstanding the fact that the Wave Festival Project would result in significant noise pollution, the
DEIR identifies it as "less than significant." Moreover, it never bothers to analyze the Wave Festival
Project's consistency with the following General Plan policies:
Guiding Principle:
One of the guiding principles of the General Plan is to reduce noise pollution. (General Plan, p. 1-3.)
The City's ongoing efforts to preserve the quality of life for all its residents, present and future, must
include the protection of a quiet noise environment. The Wave Festival Project is clearly inconsistent
with this principle.
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There are both operational and construction noise impacts associated with this Project. For example,
the Wave Basin and associated machinery/facilities will cause operational noise impacts. Prior to each
wave, the control tower announces the event over the public address system. (DEIR, Appendix K.1
[Noise Study], at p. 73.) This is followed by the noise generated from the movement of the sled and
an increase in noise levels from the mechanical equipment buildings. As the sled moves through the
lagoon, noise from the cable and metal rollers is clearly audible. (Id.) During peak wave events, the
Wave Basin generates noise levels ranging from 62.6 dBA Leq at end of the lagoon, 73.8 dBA Leq in
the lifeguard tower and 75.7 dBA Leq near the cable roller system. (Id.) There are also serious noise
levels concerns associated with outdoor hotel pool and spa activity. These noise activities include the
waterfall, people talking, and children and adults swimming and playing in a pool. The measured
reference noise level at 50 feet is 57.8 dBA Leq. (Id. at p. 75.)
In addition, there is noise level impacts associated with the Wave Festival Project's outdoor or beach
club activities, including parents speaking on cell phones, kids playing, and background youth soccer
games, with coaches shouting instructions and people cheering and clapping. The special events will
also contribute to additional noise. The Noise Study estimated the playground activity noise level to
be 43.4 dBA Leq. (Id.)
Finally, there is noise level impacts associated the proposed neighborhood commercial center. The
noise level measurements collected show a peak hourly noise level of 54.8 dBA Leq when measured
at 50 feet. (Id.) All the operational noise impacts exceed 219.3 dBA Leq.
There are also construction -related impacts associated with the Wave Festival Project, which includes
combination of trucks, power tools, concrete mixers, and portable generators that when combined
can reach high levels. Noise levels generated by heavy construction equipment can range from
approximately 68 dBA to more than 80 dBA when measured at 50 feet. (Id. at p. 81.) Construction
activity can result in varying degrees of ground vibration, depending on the equipment and methods
used, distance to the affected structures and soil type. The Wave Festival Project is inconsistent with
this general principle of reducing noise pollution. As discussed above, the operational and
construction noise impacts would affect human lives, as well as wildlife. The DEIR cannot simply
ignore this very real threat to public safety.
Response 83-ee:
Please see the Topical Response on Noise in Section 2.2.4. As described in that response and as set
forth in the DEIR (pp. 4.11-32 — 4.11-50), the project's potential construction and operational noise
impacts were carefully evaluated, and with implementation of Mitigation Measure NOI-1 through
NOI-6, all such impacts would be less than significant. The comment cites noise levels that are clearly
below the City's standards for single family homes, as described in the EIR. Furthermore, the
comment's conclusion that the noise levels at the site will cumulatively equal 219.3 dBA Leq is false.
Noise levels are not additive, as suggested in this comment. Rather, as described on page 4.11-47 of
the Draft EIR, the project will generate noise levels ranging from 39.8 to 53.3 dBA Leq at the off-site
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sensitive receptor locations analyzed in the Noise Study, taking into account all operational noise
sources.
The EIR analysis included an evaluation of noise from the wave machine, the wave itself, and the
loudspeaker announcements, as well as outdoor pool activity noise, outdoor park activities, and
neighborhood commercial noise (see DEIR at p.p. 4.11-45-4.11-48). Also see Response Nos. 83-n to
83-p above regarding the project's potential to generate increased noise at any off-site locations, and
the evidence supporting the DEIR conclusion that the Wave Basin and other project operations will
not cause noise levels that exceed the City's established standard of 65 dBA.
Comment 83-ff:
GOAL N-1
GOAL N-1 states as follows: "A helpful noise environment which complements the City's residential
and resort character." The primary source of noise in the City is traffic. (General Plan, p. IV -4.) Traffic
generated by the operation of the Wave Festival Project will influence the traffic noise levels in
surrounding off-site areas. (DEIR, Appendix K.1 [Noise Study], at p. 1.) The DEIR acknowledges that
the Wave Festival Project -related noise level increases are considered "potentially significant" for
Avenue 58 and Madison Street. (Id.) In addition to the resort itself, there will be increased traffic from
construction and special events. The Wave Festival Project's inconsistency with these General Plan
principles and goals constitutes a significant impact.
Response 83-ff:
The project's potential impacts on roadway noise levels are analyzed in detail on pages 4.11-35
through 4.11-42. As described on those pages, traffic noise increases from the project were
calculated at 28 roadway segments surrounding the project site at three different stages of project
buildout (completion of Phase 1, Phase 2 and full buildout), and at all times, the project -related
increases in roadway noise fall below the City's established thresholds of significance (See DEIR Tables
4.11-17, 4.11-18 and 4.11-19).
The General Plan Noise element also identifies several specific policies and programs to promote the
goal of a "healthful noise environment" (see 2035 General Plan pp. IV -15 through IV -16). These
include limiting outdoor noise levels to 65 dBA for sensitive receptors, including residences, and
requiring that development projects provide a noise impact analysis of construction and operations
showing compliance with the City's noise standards. This is exactly what is provided in Section 4.11
and Appendix K.1 and K.2 of the DEIR.
Although the project will fully comply with the City's noise standards, including during special events,
it is worth noting that in support of Goal N-1, the General Plan includes Program N -1.3.a, which states
as follows: "Provide accommodation for special events in the public interest, such as concerts and
festivals, which may temporarily exceed the maximum allowable decibel level." This program reflects
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the balance the 2035 General Plan seeks to strike between promoting the residential and resort
character of the community and promoting opportunities to strengthen the City's economic base and
the City of La Quinta as a world-class "resort and recreation destination" (See 2035 General Plan at
pp. 1-2 and 1-3).
Comment 83-gg:
D. The Wave Festival Project is Inconsistent with General Plan Policies Pertaining to Transportation.
If implemented, the Wave Festival Project would be directly at odds with the General Plan's
fundamental principles that development only be allowed in areas where the circulation and
transportation system capacity can accommodate such development. One of the guiding principles in
the General Plan is to "[p]romote and encourage a broad range of transportation opportunities,
especially those that reduce the impact to our environment, as well as effectively moving people and
goods. Continue to work closely with neighboring communities and regional agencies to address
regional transportation issues." (General Plan, at p. 1-3.) The General Plan includes numerous guiding
policies centered on these themes, including, but not limited to:
Response 83-gg:
Contrary to the commenter's assertion, and as set forth in Section 4.13 of the Draft EIR, with
implementation of Mitigation Measures TRA -1 through TRA -15, the project will not have any
significant impacts on the intersections and roadways in the vicinity of the project. The roadways
surrounding the project site are all designated in the General Plan to carry substantially more vehicles
than they currently do, as evidenced by the Existing Conditions Table 4.13-8, which demonstrates that
current roadway capacity is at LOS's ranging from A to C. As such, the circulation system can
accommodate the vehicle trips that will be generated by the project. In addition, Mitigation
Measures TRA -1 and TRA -2 require the project to pay the City's development impact fees to fund
circulation system improvements within the City and the regional TUMF to fund regional
improvements to the transportation system. Accordingly, the project will support the General Plan
guiding principle quoted above.
Comment 83-hh:
Policy CIR-1.12
Policy CIR-1-1.12 states as follows: "As a means of reducing the vehicular traffic on major roadways
and to reduce vehicle miles traveled by traffic originating in the City, the City shall pursue
development of a land use pattern that maximizes interactions between adjacent or nearby land
uses." (General Plan, at p. 11-126.) In direct violation of Policy CIR-1.12, if the Wave Festival Project is
approved, the City would be allowing significant and unavoidable traffic impacts on local and regional
highways. The Wave Festival Project is inconsistent with this General Plan Policy which also
constitutes a significant impact.
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Response 83-hh:
This comment is incorrect. As analyzed and disclosed in the DEIR, the project will not have any
significant and unavoidable traffic impacts. (See DEIR pp. 4.13-17 – 4.13-42). Moreover, the project
proposes a complimentary mix of uses and design features that will reduce vehicle miles traveled by
maximizing the internal connections between adjacent land uses. As explained on pages 4.13-54 and
4.13-55, the project includes residential, resort and neighborhood serving retail development that
will allow residents and guests to meet some of their retail and recreational needs without traveling
outside of the project site. The project also includes improved design elements to enhance walkability
and connectivity within the project and between uses so that residents and guests can travel within
the project without using their vehicles.
The neighborhood commercial uses proposed at the corner of Madison St. and 58th Avenue will also
help meet the retail needs of nearby residents, which will reduce their existing trips further into La
Quinta and Indio for such needs, such as coffee and groceries. Accordingly, the project complies with
and promotes General Plan Policy CIR-1.12. In fact, the project's mix of complimentary land uses and
design features described above implement General Plan Programs CIR-1.12.a through CIR-1.12.c,
which implement Policy CIR-1.12 (see 2035 General Plan at p. 11-126).
Comment 83-11:
Policy CIR-2.1
Policy CIR-2.1 states as follows: "Encourage and cooperate with SunLine Transit Agency on the
expansion of routes, facilities, services and ridership especially in congested areas and those with
high levels of employment and commercial services and encourage the use of most energy
efficient and least polluting transportation technologies." (General Plan, at p. 11-128 — 11-129.)
Within this Policy are several program goals, including:
Program CIR-2.1.a: Consult and coordinate with the SunLine Transit Agency on immediate and
long-term transit issues and assure pro active representation on the Agency Board and its decision
making process.
Program CIR-2.1.c: When reviewing development proposals, consult and coordinate with SunLine
and solicit comments and suggestions on how bus stops and other public transit facilities and
design concepts, including enhanced handicapped access, should be integrated into project
designs.
Program CIR-2.1.d: When reviewing large-scale development proposals, consult and coordinate
with SunLine to encourage the development of rideshare and other alternative, high occupancy
transit programs for employers with sufficient numbers of employees. (Id. at 11-129.)
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The DEIR simply states that "bus facilities are not located within the project study area." (DEIR, at
4.13-8.) It makes no mention of consulting with the SunLine Transit Agency or evaluating on ways that
transit services could be incorporated into the Wave Festival Project. In fact, the DEIR provides no
indication that the Wave Festival Project would result in an increase in transit mode share. Based on
the Coral Mountain Vehicle Miles Traveled (VMT) Analysis (Appendix L.2), the Wave Festival Project
has an estimated service population (SP) of 1,698 residents, 434 employees associated with the hotel
use, 240 employees associated with the retail use, and approximately 300 hotel occupants for a total
service population of 2,672. (DEIR, at 4.7-9.) With this type of large-scale project, it is imperative that
transit programs are evaluated in more detail.
Response 83 -ii:
Unfortunately, as described on page 4.13-8 of the DEIR, Sunline Transit Agency's facilities and services
are not located with the project's study area. Sunline Transit Agency reviews and updates its service
areas periodically, and as described in General Plan Program CIR-2.1.a, the City consults and
coordinates with Sunline Transit Agency on such long-term transit issues. However, at this time, there
is nothing more that the City or project can do to extend Sunline's transit service to the project,
because SunLine is an independent agency whose business plan the City cannot control. Instead, the
project supports General Plan Goal CIR-2 ("A circulation system that promotes and enhances transit,
alternative vehicle, bicycle and pedestrian networks") through the project design features described
above in Response No. 83-hh and in the DEIR at pp. 4.13-54 and 4.13-55.
Comment 83-jj:
Policy CIR-2.2
Policy CIR-2.2 states as follows: "Encourage reduction of greenhouse gas emissions (GHG) by reducing
vehicle miles traveled and vehicle hours of delay by increasing or encouraging the use of alternative
modes and transportation technologies, and implement and manage a hierarchy of Complete Street
multimodal transportation infrastructure and programs to deliver improved mobility and reduce GHG
emissions." (General Plan, at p. 11-129.)
As set forth above, the DEIR is inadequate in its evaluation of alternative modes of transportation.
The DEIR states that the Wave Festival Project includes Project Design Features (PDFs) that effectively
reduce air quality and GHG emissions. (DEIR, at 7-6.) It goes on to list a few programs, such as
employer-sponsored shuttles, and commute trip reduction program. (Id.) However, the DEIR provides
very little detail on how these programs would be implemented. Without providing any details, it is
unclear whether it complies with Policy CIR-2.2 of the General Plan.
The Wave Festival Project is in clear violation of these General Plan Policies. The DEIR provides no
indication that the Wave Festival Project would result in an increase in transit mode share. Rather
than meeting recreational demand with transit service, the Wave Festival Project would likely be
completely auto -based. In addition, the Wave Festival Project would result in a significant impact on
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local transit service providers for which the DEIR does not identify adequate mitigation. The Wave
Festival Project is inconsistent with this General Plan Policy which also constitutes a significant impact.
Response 83-jj:
As explained in Response No. 83-hh above, the project complies with this Policy by incorporating
improved design elements to enhance walkability and connectivity within the project and between
uses, so that residents and guests can travel within the project without using their vehicles. In fact,
such efforts to improve interconnectivity between adjacent uses is specified in General Plan Program
CIR-2.2.c as one of the ways to help achieve Policy CIR-2.2. The project also reduces GHG emissions
by including a complimentary mix of uses that will help reduce vehicle trips from project residents
and guests, as well as existing residents in the community, who would otherwise need to travel
several miles for any neighborhood serving commercial uses. Finally, the project is required to make
improvements to adjacent public streets, as described on pages 4.13-29 and 4.13-37 — 4.13-38 of the
EIR, to include sidewalks, multi -modal trails and bike lanes, in full compliance with the City's Complete
Streets program. Accordingly, the project is consistent with Policy CIR-2.2 by reducing GHG emissions.
Comment 83-kk:
CONCLUSION
We are concerned on several fronts that a project of the magnitude and impact of the Wave Festival
Project is being considered without sufficient consideration being given to its significant
environmental impact to the City and its residents. Moreover, we are concerned that the City is
running afoul of its requirements to conduct a thorough and meaningful analysis of the Wave Festival
Project as required by California law and by its own General Plan. Before the Wave Festival Project
can even be considered, then, there must be a credible analysis of its environmental impact. That
critical analysis has not been performed.
Response 83-kk:
The commenter's concerns are noted. As described in Responses 83-a through 83-kk, the City has
undertaken a complete and comprehensive analysis of the project's environmental impacts. As this
comment does not identify a specific question or concern regarding the adequacy of the Draft EIR in
identifying and analyzing potential environmental impacts, no further response to this comment is
provided.
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Comment Letter No. 84: Alena Callimanis 1
Date: August 6, 2021
Affiliation: Area Resident
Comment 84-a:
Comments regarding DEIR Section 4.15 Utilities and Service Systems.
In the CVWD Water Assessment, Coral Mountain surf pool replenishment is listed at 39 million gallons
yearly. CVWD does not have knowledge of coefficients to account for evaporation due to Wave Action
at the time of their Water Assessment. In addition, the increasing number of days of wind action in
the Coachella Valley will cause additional evaporation. (If required, Alena Callimanis can provide
additional information on the number of high wind days in Coachella Valley). Water evaporation
calculations by CVWD are based on a standard factor of 1.2 for moving water and pan evaporation
numbers from 2005. In 2005, when these calculations concluded, we only had 99 days over 100
degrees.
Response 84-a:
Please see Response 65-d regarding the validity and accuracy of the water demand and evaporation
calculations for the project as stated in the WSA/WSV approved by CVWD.
Comment 84-b:
Therefore, in order to determine the amount of water required, the DEIR must look at the following
information:
1) The World Surf League, which purchased Kelly Slater wave technology, wrote that on very hot days
at Lemoore Surf Ranch, the pool lost 250,000 gallons a day. It is valid to accept this as a minimum
number to be used for La Quinta, because Lemoore is in Kings County where the evapoTranspiration
rate is lower than our area. Since the La Quinta evapoTranspiration Rate would dictate a higher rate
of evaporation than Lemoore, we are actually looking at higher than 250,000 gallons per day of
evaporation.
Lemoore had 27 days over 100 degrees in 2020 with hottest temperature of 107 degrees. La Quinta
had 143 days over 100 degrees in 2020. The first part of a new calculation can use 250,000 gallons a
day times 143 hot days. This equals 36 million gallons lost to evaporation in 143 days. This does not
account for an additional 222 days of the year. But considering we had 56 days over 110 degrees in
2020, it should be reasonable to expect that on the days over 110 degrees, evaporation should be
higher than 250,000 gallons. Should we calculate that at 300,000 gallons?
Especially considering our Eto is higher than Lemoore. What about the rest of the 222 days of the
year? We had 51 days over 90 degrees as part of that 222 days.
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The DEIR must use numbers that reflect actual wave pool evaporations and not outdated evaporation
methods. It must include calculations based on known evaporations from wave pools.
2) The DEIR must account for the additional windy days which add to evaporation. Many sites on line
provide ways to account for actual wind evaporation. This must be included.
Response 84-b:
Please see Response 65-d.
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Comment Letter No. 85: Alena Callimanis 2
Date: August 6, 2021
Affiliation: Area Resident
Comment 85-a:
We have been told that there will be no "light pollution". However, this picture was taken from 58th
Street and shows the light impact from Bagdouma Park in Coachella, over five miles from the Coral
Mountain site. Due to the nature of fine sand particles in the air in the Desert, light will always appear
like this. And since the residents are significantly closer to Coral Mountain than Bagdouma Park we
will have significant light pollution from the seventeen 80 feet light poles. By the way, the poles at
the Park are only 60 feet height. So the light impact will be significant to the surrounding
developments.
Response 85-a:
Please see the Light and Glare Topical Response in Section 2.2.1 of this Chapter. Please also see
Response 51-c, which provides a detailed explanation of how the proposed TLC for LED lighting system
is substantially different from the older metal halide lights installed at Bagdouma Park. Please also
see Appendix B.1 for a discussion of the LCD for LED lighting system features that provide effective
illumination of the Wave Basin while preventing light spillage outside of the Wave Basin area, and
Appendix B.2 for the results of the on-site lighting lest conducted on November 17, 2021 and the
resulting light contour exhibit that shows the contour line where light levels will be 0.01 foot candles
or less (which is on-site and within the immediate vicinity of the Wave Basin).
Comment 85-b:
In addition, please also provide information on wind tunnel tests that have been performed on the
lights to ensure that during our wind events, the poles will not snap or bend and cause injuries.
Lisa Castro, the resident adjacent to the surf basin, has stated for the record to the City Council that
Coral Mountain causes a wind tunnel effect in this area. She has recorded significant wind events and
can provide that information if requested.
Response 85-b:
The light poles and fixtures will be constructed in full compliance with the California Building Code
wind load design requirements. The California Building Code has been adopted by the City of La
Quinta with minor revisions to account for the specific climate in the Coachella Valley, including high
wind events. Also see City of La Quinta Building Department, Building Code page
(https://www.laquintaca.gov/business/design-and-development/building-division/building-codes),
which identifies additional design criteria for buildings and other structures constructed in the City,
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including "Basic Wind Speed: 110 mph for Risk Category II Buildings and other structures (usually
results in 85 mph for Allowable Stress Design); Exposure "C".
Comment 85-c:
This comment displays the pictures Callimanis refers to in Comment 85-a.
Response 85-c:
Please see Response 85-a.
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Comment Letter No. 86: Alena Callimanis 3
Date: August 6, 2021
Affiliation: Area Resident
Comment 86-a:
A full study must be completed on this site due to the fact that the surf lagoon has a still water level
that is as much as 9 ft (2.75 m) deep in the center. 9 ft of water weighs 562 pounds per square foot
(psf), which is a very heavy load (a uniform freeway load is only 250 psf, as comparison). The load will
fluctuate with the wave and will cause a dynamic loading. A geotechnical engineer needs to provide
an analysis to determine the potential impact of this loading on the soil at this site.
Response 86-a:
As stated on page 4.6-17 of the Draft EIR, all on-site water bodies will be lined, and slopes and shores
will be stabilized to state and local standards and under the supervision of a structural engineer, to
ensure liquefaction or infiltration will not occur at the Wave and water bodies onsite.
As discussed in Response 86-b, a Geotechnical Investigation was prepared for the project by Sladden
Engineering to explore the subsurface conditions at the site to provide recommendations for
foundation design and site preparation relative to the development of all the facilities and structures
proposed as part of the project. Sladden conducted a field exploration program, laboratory testing,
and engineering analyses to determine the potential for impacts relating to existing geology and soils
conditions on the site and recommendations to avoid these potential impacts.
Additionally, as also explained on page 4.6-17 of the Draft EIR, the Wave Basin will incorporate the
necessary structural concrete design features to address the pressure and drainage associated with
the wave generation. In addition, Mitigation Measure GEO-1 requires the Wave Basin designs to be
prepared by a qualified engineer in compliance with all seismic requirements and to incorporate all
recommendations of a qualified soils engineer. Finally, the proposed Wave Basin will be constructed
to meet all engineering standards of the California Building Code in force at the time that building
permits are secured. These measures will ensure that the loading of the soil at the site of the Wave
Basin will not create any significant geotechnical effects.
Comment 86-b:
The site is located in relatively close proximity of potentially active seismic faults and pressures due
to seismic forces. The geotechnical engineer needs to address equivalent fluid pressure for lateral
seismic forces at this site, and to be added to the geology and soils discussion.
Meriwether has discussed that they recorded the Kelly Slater wave pool in Lemoore for seismic
information and found no impact. This is not what is required here at the Wave Basin site in La Quinta.
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An independent geotechnical engineer, who has not worked with Meriwether in the past and has
been vetted by us, must provide the information requested above that is required to be included in
the EIR due to this location, not Lemoore.
Response 86-b:
A Geotechnical Investigation was prepared for the project by Sladden Engineering, in February 2019.
The purpose of the Geotechnical Investigation is to explore the subsurface conditions at the site to
provide recommendations for foundation design and site preparation relative to the development of
the project. Sladden conducted a field exploration program, laboratory testing, and engineering
analyses. Specifically, the site characterizations consisted of the following tasks:
• Site reconnaissance to assess the existing surface conditions on and adjacent to the site.
• Drilling ten (10) exploratory boreholes to depths between approximately 21 and 51 feet bgs
in order to characterize the subsurface soil conditions. Representative samples of the soil were
classified in the field and retained for laboratory testing and engineering analyses.
• Digging five exploratory trenches to depths of approximately five feet bgs in order to evaluate
the subsurface conditions along previously identified vegetation linaments.
• The performance of laboratory testing on selected samples to evaluate their engineering
characteristics.
• The review of available geologic literature and the discussion of potential geologic hazards.
• The review of various geotechnical reports previously prepared for the project site.
• The performance of engineering analyses to develop recommendations for foundation design
and site preparation.
With respect to the proximity of potentially active seismic faults, the results of Sladden Engineering's
analysis are stated on pages 4-5 of the Geotechnical Report included as Appendix G to the Draft EIR.
Sladden determined that while the southwestern United States "is a tectonically active" region, the
project site is not located within any State of California or County of Riverside designated fault zone,
and the nearest known potentially active fault is San Andreas — Coachella fault located approximately
13.9 Km from the project site.
Consistent with the request in this comment, the Sladden report discusses the appropriate equivalent
fluid weight to use in retaining wall design, and notes that seismic pressures must be considered in
the design of retaining walls in excess of 6 feet (once wall heights and configurations are finalized and
designed). See Geotechnical Report at p. 11.
The Geotechnical Report was prepared by an experienced and independent engineering firm that
conducted a project -site specific evaluation as described above, not based on data from the Lemoore
wave basin. Sladden Engineering provided their professional expertise to determine best practices
compliant with engineering standards and procedures to be implemented at the project site.
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Based on the site-specific investigation and analysis performed by Sladden Engineering, the
Geotechnical Report and Draft EIR determined that with implementation of Mitigation Measures
GEO-1 through GEO-3, impacts associated with strong seismic ground shaking, seismic -related ground
failure, ground subsidence, collapsible soils, and corrosive soils would be less than significant (see
Draft EIR, at pp. 4.6-26 - 4.6-28).
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Comment Letter No. 87: Alena Callimanis 4
Date: August 6, 2021
Affiliation: Area Resident
Comment 87-a:
Section 4.5 states that the project would be .19 percent of IID's total estimated demand in 2031. We
are not interested in the demand in 2031. We are interested in the demand when the Wave Park is
operating 7AM to 10pm, 365 days a year, in 2023. Please provide information from IID that states
that power will be available at that rate required for the wave machinery in 2023. In addition, with
IID's aggressive peak demand energy efficiency programs, we would like to see incorporated into the
EIR that IID understands that the Wave Park's peak hours of energy demand will be 6pm to 10pm,
especially in the summer during our extreme heat and how IID and the Coral Mountain project plans
to address that.
Response 87-a:
As discussed on pages 4.5-25 — 4.5-28 of the Draft EIR, the project will be required to add a
transformer to IID's existing substation on Avenue 58, which according to IID's comment letter on the
NOP (See Draft EIR Appendix A), will need to be completed prior to the first electrical in-service date
for the project. With this additional infrastructure, IID will have adequate capacity to meet the
project's demand along with all other existing and planned future development. As it is doing with
this project, IID requires all new projects to submit detailed loading calculations, panel sizes, and
related information so that IID can complete the necessary studies and engineering work to
determine each project's infrastructure requirements that will need to be constructed before that
project receives electrical service. In that way, IID is able to ensure that it is able to meet all existing
and future electricity demands.
Comment 87-b:
In addition, section 4.7 Greenhouse Gas Emissions, references greenhouse gas credits but bypasses
the actual discussion of the significant amount of greenhouse gas emissions as the result of the huge
amount of electricity that is required to be produced to generate waves by the Wave Pool machinery,
from 7AM to 10PM, 365 days per year. We want a full accounting in the EIR of the greenhouse gas
emissions, both from electrical power creation, and from the cement production required for the 16.7
acres Wave Basin.
Response 87-b:
The operational energy source GHG emissions disclosed in Section 4.7 of the Draft EIR, tables 3-4
through 3-9 and in the underlying GHG Analysis Study include the factor of electricity use from Wave
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Basin operations. As shown in Table 4.7-4, GHG emissions relating to energy used by the project
during operations, including the Wave Basin, are projected to by 3,923.79 total MTCO2e per year (by
comparison, mobile sources are projected to generate 6,602.23 MTCO2e per year). Phase 1 of the
project construction, which includes the Wave Basin, is estimated to generate 2,171.3 total metric
tons of CO2e over a 2 -year period (total project buildout is estimated at 12,438.51 total metric tons
of CO2e over an 8 year period). The GHG Analysis is provided as Appendix! in the Draft EIR, and the
appendices to the GHG Analysis contain the results of the GHG computer modeling for the different
construction and operational components of the project's total estimated GHG emissions.
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Comment Letter No. 88: Alena Callimanis 5
Date: August 6, 2021
Affiliation: Area Resident
Comment 88-a:
With regards to the project noise levels, Section 4.11, we demand a noise evaluation to be conducted
on the Coral Mountain site, in order to determine the actual noise impact of the project. There has
been a significant amount of La Quinta City Council Public Hearing Comments on noise that is
propagated currently throughout the communities that are around Coral Mountain, including hikers
conversations, shooting noises from the Lake Cahuilla Police Shooting range, car noises, and
numerous other examples. The Urban Crossroads Noise Memo, dated April 20, 2020, states that Coral
Mountain is likely to absorb, rather than reflect noise. This is an Environmental Impact Report. A
speculative comment like that has no place in the EIR.
The new noise evaluation must be made directly on site so that the noise impact can be properly
evaluated, both during the day and during the hours of 8pm to 10pm. There must be an independent
sound advisor available during the study so that we are comfortable with the results.
The importance of this cannot be brushed aside by an evaluation that is determined by computer
simulations. Even though sensors were placed around the Coral Mountain site to record pre-existing
sound conditions, that cannot be used to predict the actual noise levels on site.
Please inform me when this is scheduled so that we make sure an independent noise consultant will
be able to join the analysis.
Response 88-a:
Project -related operational noise was thoroughly analyzed in Section 4.11, Noise, of the Draft EIR,
based on technical studies provided by Urban Crossroads, Inc. As described in Responses 52-h, 59-e,
and 62-f, the noise impacts of all components of the project were analyzed in the Draft EIR at pages
4.11-44 through 4.11-49. As the comment relates to increases in noise versus the City's noise
standards, please see the Topical Response on Noise in Section 2.2.4 above, as well as Table 4.11-26
in the Draft EIR, which shows that the project will not significantly increase ambient noise levels at
any of the ten sensitive receptor locations in the immediate project area. As described in the Draft
EIR, noise measurements were taken at ten off-site locations, and identified current noise levels
ranging from 43.8 dBA (at location L8/R8 at the existing homes on Avenue 60 approx. 38 feet from
the project site) to 62.5 dBA (at location L2/R2 at the existing homes on the north side of Avenue 58).
The analysis then goes on to apply all of the noise made by all of the land uses proposed for the
project, and found, as shown in Table 4.11-26, that noise levels will increase in those sensitive
locations by between 0.0 and 4.9 dBA, and in no location does the addition of project noise increase
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noise levels above the City limit of 65.0 dBA or increase ambient noise levels by a significant amount.
This method of analysis was completed by Urban Crossroads, a recognized expert traffic and noise
engineering firm, using established noise modeling software consistent with protocols and used in
analyzing noise impacts throughout California. Therefore, the noise analysis, and the Draft EIR
correctly analyzed impacts on the project site, not in a hypothetical environment.
The comment's characterization of the Noise Memo is incorrect. On the issue of whether significant
noise levels will be amplified by bouncing off Coral Mountain, the noise expert explained that based
on Federal Highway Administration studies and guidance, if all noise striking a hard surface were
reflected back to a given receiving point, the maximum increase in noise would be limited to 3dBA.
However, not all acoustical energy is reflected back to the same point, and accordingly, FHWA
measurements show that reflective noise increases do not exceed 1-2 dBA, which is not perceptible
to the human ear (see Urban Crossroads Memo dated 4/20/21, attached as Appendix K.2 to the DEIR).
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Comment Letter No. 89: Alena Callimanis 6
Date: August 6, 2021
Affiliation: Area Resident
Comment 89-a:
I have significant concerns about the undercalculation of the use of chlorine at the Wave Basin. With
our excessively high temperatures, the risk of warmer water means more chlorine demand. Both
living and non -living contaminants are more prevalent in warmer water. Algae, bacteria and brain -
eating amoebas, for instance, are living contaminants that chlorine must kill. Warmer water means
those microorganisms can reproduce more rapidly, therefore problems like algae and bacteria are
more prevalent in the summertime. To kill any living organism, chlorine needs a certain amount of
contact time (CT). Hotter days mean more non -living organics in the water, like sunscreen and body
oils. Between these organics and the living contaminants like algae and bacteria, warm water has a
higher chlorine demand than cold water.
For example, dosing at 5ppm/day, chlorine consumption could be 1,1001bs/day of 68% briquettes.
This is a significant amount of chlorine that needs to be kept on site. What are the precautions that
are being taken to safely house this significant amount of chlorine? To keep it cool?
I am concerned that the filtration systems will not be able to circulate the water an adequate amount.
In our excessive high temperatures, if full pool circulation through the filtering system takes
significantly longer than once per day, there is a high risk of not properly removing all contaminants.
This poses a danger to the health and safety of surfers and people in the pool.
I would like to understand more fully in the EIR how the developer will address the chlorine and
filtration required at the excessively hot water temperatures found here (pool temperatures have
been between 93 and 97 degrees, with no cooling relief overnight). This is a big risk to the health and
safety of all surfers/people in the water, that must be addressed.
Response 89-a:
Please see Responses 52 -land 65-c for a detailed response to these concerns regarding the project's
disinfectant treatment of the water in the Wave Basin, the safe storage and use of the necessary
chemicals, and the project's compliance with the State and County health and safety requirements.
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Comment Letter No. 90: Anast Demitt
Date: August 6, 2021
Affiliation: Area Resident
Comment 90-a:
Following please find my response to the Draft EIR (the "DEIR") for the Coral Mountain Resort (the
"Project"). I anticipate that a number of other concerned residents will prepare responses
commenting upon zoning, aesthetics, noise, and lighting so I will focus my response to two issues
where analytic review can provide support to my comments.
In general, my concerns lie in three areas that will be detailed further in my report. A short summation
of these issues follows:
MSA Consulting Inc. failed to disclose what I believe to be a conflict of interest in their
engagement as prime consultant in the preparation of the DEIR which results in bias in the
conclusions contained within the Draft EIR.
The calculated water consumption determined by MSA Consulting Inc. did not take into
consideration the City of La Quinta's Maximum Applied Water Allowance for this project.
The calculated outdoor water consumption is at 99.98% of the City of La Quinta's legislated
maximum consumption for this site leaving no additional capacity for emergency or
maintenance use.
The increased vehicular traffic loads will result in significant reductions in levels of service
necessitating roadway and signalization upgrades for which the Project developer will only
pay a small percentage of the associated costs.
Response 90-a:
This introductory comment is noted. Please see the responses to Comments 90-b through 90-d below.
Comment 90-b:
1. MSA Consulting Inc's Engagements
I would like to commence this response by commenting on the DEIR prepared by MSA Consulting Inc.
("MSA"). During my reading of the Notice of Proposal in March of 2021, I reviewed a number of
grading and site layout drawings for the project which had MSA's logo on them leading me to
understand that they had been prepared by MSA. Clearly MSA had been retained to act in the role of
a civil engineering consultant by the developer several years ago and was engaged to act as the prime
consultant in the preparation of the EIR. In my view, this is a serious conflict of interest which results
the calling into question the credibility of the entire DEIR and any of the conclusions presented in the
DEIR by MSA.
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The National Society of Professional Engineers ("NSPE") has issued a Code of Ethics that all practicing
Professional Engineers are expected to understand and follow. MSA, in my opinion, has contravened
the Code of Ethics by not addressing their retainer as the design engineer in the DEIR. Without this
disclosure, readers of the report are given the impression that MSA is acting as a neutral independent
party in preparing the DEIR for the lead Agency, The City of La Quinta.
Following is Cannon 5 taken from the NSPE's Code of Ethics and it states:
5. Engineers shall not be influenced in their professional duties by conflicting interests.
MSA is not a neutral party in the preparation of the DEIR as MSA has and may continue to receive
financial gain as the civil engineering consultant for the Project in the event the Project receives
regulatory approval. Without clear disclosure, the average reader of the DEIR will assume that MSA,
acting in their professional capacity, is entirely neutral and that the conclusions they present are
statements of fact and are not influenced by past or future financial gain. This undisclosed Conflict of
Interest causes any conclusions made in the report to be called into question. Even the perception of
a possible conflict of interest should be sufficient reason for MSA to include in the DEIR their prior
engagement as the design engineer by the developer to ensure full disclosure is provided to all
readers of the DEIR which is a public document issued through the city of La Quinta.
Response 90-b:
The City of La Quinta is the Lead Agency for preparation of CEQA analysis and documentation. Lead
Agency means the public agency which has the principal responsibility for carrying out or approving
a project. The Lead Agency will decide whether an EIR or Negative Declaration/Mitigated Negative
Declaration will be required for the project and will cause the document to be prepared (Guidelines
Section 15367).
MSA Consultants, Inc. provides CEQA support for the City as an "On Call Consultant," for the City. This
list is available at the City of La Quinta. The City, consistent with many other cities in California, allows
the preparation of environmental documents, subject to City peer review and approval. In this case,
the City has reviewed, extensively commented upon, and eventually approved all of the technical
studies prepared for the project, the Notice of Preparation, the Draft EIR, and this Final EIR.
Furthermore, as stated in Eureka Citizens for Responsible Government v. City of Eureka (2007) 147
Cal.App.4t" 357, 369, "When an EIR is required, the lead agency is responsible for preparing it, but
rather than preparing it using its own staff, the agency may enlist the initial drafting and analytical
skills of the applicant's consultant (Pub. Resources Code §§ 21082.1(a), 21100(a); [CEQA] Guidelines
15084(d)(3)), so long as the agency applies its 'independent review and judgment to the work product
before adopting and utilizing it ... This methodology is common in California and the Guidelines
affirmatively endorse [this approach]."
Comment 90-c:
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2. Water Consumption and the Water Serving Agreement
Appendix M to the DEIR is the Water Serving Agreement ("WSA") between the Coachella Valley Water
District ("CVWD") and the developer of the project. The updated water demand was prepared by MSA
and submitted to the CVWD in a letter dated September 28, 2020. The updated WSA indicates that
the Project's calculated outdoor water demand is 810.47 acre feet.
I have reviewed the City of La Quinta's Municipal Code with respect to the annual Maximum Applied
Water Allowance ("MAWA") for new developments. The Municipal Code defines MAWA as follows:
"Maximum applied water allowance" means for design purposes, the upper limit of annual
applied water for the established landscaped area, as specified in Division 2, Title 23, California
Code of Regulations, Chapter 7, Section 492. It is based upon the area's reference
evapotranspiration, the ET adjustment factor, and size of the landscaped area. The estimated
applied water use shall not exceed the maximum applied water allowance.
In the following comments, I refer to Article 8.13 of the La Quinta Municipal Code and specifically,
section 8.13.030. It is my understanding that MAWA applies to aggregate annual amount of water
which is available for use by a project outside of the buildings. This procedure is consistent within the
MAWA cacluations provided by CVWD in the WSA.
The City of La Quinta's MAWA calculation equation from section 8.13.030 of the Municipal Code is
reproduced following:
MAWA = (ETo X 0.45 X LA X 0.62) / 748
Inserting an Eto (reference evapotranspiration) of 75 inches per year which is specified by the City of
La Quinta in Section 8.13.030 and an outdoor landscaped area of 12,656,401.56 square feet (taken
from table 2.0-3 of the WSA) into the referenced equation results in a MAWA for this site of
354,057.76 hundred cubic feet or 812.81 acre feet of water. The estimated outdoor consumption
calculated my MSA of 810.47 acre feet is therefore 810.47/812.81 or 99.8% of MAWA. The total
estimate consumption as determined by CVWD is for evapotranspiration only and does not include
for extraordinary irrigation or for filling or refilling of the wave pool, swimming pools or the lakes and
ponds located within the project.
If the wave pool evaporation calculated by MSA is even marginally greater than what has been
estimated, or, if maintenance requires the emptying and refilling of any of the ponds, pools, or
surf/Wave Basin, then the project's water consumption will exceed the legislated MAWA for the site.
It is my understanding that a development cannot consume more water than that determined using
the MAWA equation in the City of La Quinta Municipal Code specified MAWA.
The NSPE Code of Ethics addresses the honesty of an engineer's work as follows:
3. Engineers shall avoid all conduct or practice that deceives the public.
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a. Engineers shall avoid the use of statements containing a material misrepresentation of fact or
omitting a material fact.
The important material fact that was not included in the MSA Report was that the estimated water
consumption on this site is essentially already at MAWA without the demand for additional water in
the event that evaporation or maintenance demands are higher than what was allowed for by MSA
in their estimates.
Response 90-c:
Please see the Topical Response on Water Resources in Section 2.2.3 of this Chapter for information
on the MAWA estimate for the project.
The MAWA reflects the maximum amount of outdoor water use that a proposed project may use
under the CVWD and City of La Quinta Landscape Ordinances. This also ensures compliance with
applicable state law restrictions on outdoor water use. As stated on page 23 of the WSA, project
"landscaping may need to me modified to ensure that the entirety of the project is meeting the
MAWA established in CVWD's Landscape Ordinance or other applicable regulations." Since the Wave
Basin is being constructed in Phase 1 of the project, that means that if the Wave Basin uses more
water than was allocated, landscape areas in other portions of the project will need to modify their
landscaping to use less water so the project remains compliant with the Landscape Ordinance. Please
note, however, that the WSA/WSV conservatively used the entire footprint of the Wave Basin to
estimate water demand (815,443 square feet), rather than the actual water surface area (544,500
square feet), Which means the Wave Basin should actually use less water than estimated, not more
as suggested in the comment.
Please also see Response 65-d.
Comment 90-d:
3. Traffic Changes caused by the Project
Once the Tourist Commercial aspect of the Project is "up and running" there will be resulting traffic
loads that will significantly impact our day to day lives as we know them. In my opinion, the traffic
study included in the DEIR is flawed as it was conducted during COVID when many seasonal residents
chose not to return to the valley. The base traffic volumes used in the analysis are therefore likely an
underestimation of the actual volumes. The study shows that levels of service in some of the affected
areas will be reduced to level F. The DEIR recommends that changes be implemented to reduce the
impacts on the Level of service. The developer has stated that they will pay for "their proportional
share". The citizens of La Quinta are then stuck with the remainder of the costs, a very unreasonable
expectation for citizens of La Quinta.
Response 90-d:
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This comment is incorrect in its characterization of the analysis conducted during the COVID-19
pandemic. As stated on page 29 of the Traffic Impact Analysis as well as Section 4.13, Transportation,
in the Draft EIR, "the intersection LOS analysis is based on the traffic volumes observed during the
peak hour conditions using traffic count data collected on August 15th, 2017, April 9th, 2019, May
7th, 2019, and September 10, 2019.
To ensure that these traffic counts reflect high -season traffic levels, a 20% increase is applied to
counts taken in August, 5% increase is applied to counts taken in April, and 10% increase is applied to
counts taken in May, as required under City of La Quinta's Traffic Study requirements (EB#06-13).
The average AM/PM peak hour intersection growth between 2017 and 2019 counts data at selected
study area and nearby intersections is approximately 2.66%. The additional 2.66% growth rate was
applied to the study area intersections with 2017 counts to reflect 2019 conditions."
Therefore, traffic counts were taken prior to COVID, and baseline numbers were properly adjusted to
reflect peak season traffic conditions.
As it relates to the concern that the roadway improvements will not be constructed in time to meet
the cumulative demands of project traffic plus other cumulative traffic growth, this concern is
unfounded. As stated on page 4.13-29 through 4.13-34 of the Draft EIR, all intersections impacted by
Phase 1 and Phase 2 traffic will need signals or other improvements installed to operate at an
acceptable level of service, with or without the project, and are funded by the City's Capital
Improvement Plan (CIP). Accordingly, these improvements are fully funded by the CIP and will be
installed as warranted. Please note that Phase 1 and Phase 2 traffic contributes a fair -share of
between 0.4% and 3% to these intersection improvements. The project's payment of the City's
development impact fees covers its share of these intersection improvements and helps fund the
City's CIP.
As described on pages 4.13-37 — 4.13-42, at buildout, the project will be required to install a signal at
the intersection of Madison Street and Avenue 58 (project contributes 23% of traffic), and will
contribute to the need for signals or other improvements at four additional intersections which are
included in the City's CIP and will be constructed by the City. The project's fair share of the
improvement costs at the affected intersections range from 2% to 11% and are fully funded through
payment of the City's development impact fees.
Comment 90-e:
Additionally, the study finds that the so called "special events" will further increase the anticipated
traffic loads on the existing transportation infrastructure. Once again, the burden for these traffic
loads will be borne by the citizens of La Quinta with increased travel times, delays in commutes
resulting in significant greenhouse gas emissions. The report does not address these environmental
impacts on the quality of life for residents in the adjoining neighborhoods.
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Response 90-e:
A maximum of four special events per year are proposed as part of the project description. As
described in Draft EIR Section 4.13, Transportation, events will be restricted to 4 days duration with
peak trips anticipated on Saturdays (up to 4 events per year). Staggered arrivals and departures will
result in fewer trips on the three other days. Therefore, Saturdays were selected to illustrate the
worst-case traffic scenario.
Improvement recommendations identified for weekend special event conditions are consistent with
the improvements identified for Phase 3 weekday typical operations. Therefore, any event occurring
prior to the build out of the project, and concurrent improvements, including traffic signal
installations, would result in a significant impact on traffic operations. If project special events are
held prior to the construction of Phase 3 improvements the following mitigation measures are
included in the EIR to reduce the impacts to the regional traffic system (as provided in Mitigation
Measures TRA -9 and TRA -10):
• Traffic improvements will be completed or the applicant shall provide a focused traffic analysis
with the Temporary Use Permit that identifies any improvements that are not necessary to
maintain acceptable levels of service at study intersections. If the analysis does not
demonstrate acceptable operations, the TUP will be denied.
• A special event traffic and parking plan will be submitted with each Temporary Use Permit to
ensure that special events will not cause any significant traffic or parking impacts. If the
analysis does not demonstrate acceptable operations, the TUP will be denied.
As required by Mitigation Measures TRA -12 through TRA -14 for large special event venues, traffic
control typically includes special event flaggers, law enforcement personnel, online or transmitted
event information (suggested routes, parking, etc.,) and portable changeable message signs (CMS) (or
moveable mechanical electronic message boards.) CMS will be located at critical locations identified
by the La Quinta Police Department (LQPD) and in place 5 days ahead of the event and 2 days after.
Therefore, the Draft EIR correctly analyzed the traffic impacts associated with special events, found
those impacts significant based on the City's thresholds of significance (LOS D) for intersection
operations, and provided feasible mitigation measures that will reduce these impacts to less that
significant levels.
Contrary to the comment's assertion, GHG emissions associated with special events were disclosed
and analyzed. As explained on pages 4.7-19 and 4.7-19 of Section 4.7 Greenhouse Gases, in order to
ensure a worst-case analysis of total GHG emissions for the project, total annual emissions for the
project were calculated separately (as shown in Table 4.7-3), and then total GHG emissions from the
maximum 16 days of special events were calculated (see Table 4.7-5), and the two totals were added
together for the maximum annual GHG emissions for the project (See Tables 4.7-7 and 4.7-8).
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The annual GHG emissions associated with the operation of the proposed Project, is shown on Table
4.7-8, after implementation of all feasible emission reduction measures as enforceable PDFs and
Mitigation Measure GHG-1. As shown in that Table, project -related GHG emissions are reduced to
3.62 MTCO2e per service population (SP) per year which is less than the applicable threshold of 3.65
MTCO2e per SP per year. The Draft EIR correctly found that feasible mitigation may not be possible,
and identified GHG emission impacts as potentially significant and unavoidable. Mitigation Measure
GHG-1, which requires the developer to purchase a minimum of 72,000 MTCO2e of carbon credits
from a CARB-approved carbon registry, prior to any occupancy of the site, would offset the GHG
emissions generated by the project. However, the purchase of these carbon credits would not change
the actual GHG emissions levels of the project itself. Moreover, as the use of carbon credits as
mitigation for GHG emissions has not been widely adopted in the Coachella Valley area for residential
and resort community projects. Therefore, the Draft EIR considers impacts associated with GHG
emissions to be a significant and unavoidable impact of the project to ensure disclosure of the worst-
case scenario.
Comment 90-f:
In closing, the DEIR for the Project appears to have been prepared by a consultant who is conflicted
in their professional capacity without adequate disclosure of the conflict to readers of the report.
Furthermore, the DEIR contains language that is repetitive, subjective and attempts to obfuscate the
facts. Engineers are to prepare reports based on facts and not to include overly descriptive language
or superlatives in an attempt to sway readers to a proponent's proposal. This DEIR is short on
objective facts and burdened with opinion and superlatives.
In my view, the DEIR is in need of significant rewriting bearing in mind the obligations that Professional
Engineers are required to adhere to in work that will be relied upon by City Officials and members of
the public. Any conclusions presented in the current DEIR are therefore called into questions
regarding their objectivity given the MSA's prior engagement with the Project's developer on this
matter.
I may be contacted at the number below with any questions that you may have.
Response 90-f:
Please see Response 90-b regarding the appropriateness of consulting environmental services; and
Section 2.2.7 of the Topical Responses regarding the content of the EIR. As described in response to
these comments and throughout this Final EIR, the analysis of impacts of the proposed project has
been thoroughly conducted, all impacts have been identified, and all feasible mitigation measures
applied.
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Comment Letter No. 91: Mary Greening
Date: August 6, 2021
Affiliation: Area Resident
Comment 91-a:
Thank you for the opportunity to provide commentary on the EIR for the Coral Mountain Wave
Project. As 15 year homeowners at Andalusia CC, we have enjoyed the serenity of this part of La
Quinta, and believe the proposed waterpark development is not in sync with other developments in
the area.
We support the following alternative considered for evaluation, in order of preference:
- Alternative 2 — No Project/Existing Entitlements
- Alternative 4 — The Golf/Resort Hotel
- Alternative 5 — The Lake Amenity/No Hotel
- Alternative 3 — Reduced Density
If the project continues, we would like to voice the following issues/concerns:
Response 91-a:
The commenter's opinion is noted. Responses to individual issues are provided below. With respect
to the land use compatibility concerns raised, please see Responses 41-c and 52-f.
Comment 91-b:
Visibility/Lighting:
We are very concerned about the lights that will be visible from the top viewing levels of the hotel. A
4 -story structure is significantly above the predominantly single level only housing in the area, and
the top of the building and its lights would be visible from adjacent neighborhoods.
We are even more concerned about the 80' proposed lights over the wave park. These towers would
not only be visible from a distance, even unlight, but would also impact views of the mountain and
the night sky.
Response 91-b:
Please see the Topical Response on Light and Glare in Section 2.2.1 of this Chapter for a summary of
the analysis in the Draft EIR regarding the potential for significant light and glare impacts from the
proposed pole lighting. In addition, please see the line -of -sight analysis contained on pages 4.1-23 —
4.1-45, including Exhibits 4.1-4, 4.1-6, 4.1-8, 4.1-10, and 4.1-12, which show that the hotel will not be
visible from the off-site viewing locations due to topographical conditions and intervening perimeter
walls, landscaping and low-density residences.
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Comment 91-c:
Noise
This neighborhood is very quiet. We can hear the cars from the Thermal Club, which is much further
away than the proposed project. Our concerns are:
- Traffic noise on Madison
- Noise from the filtering and heating system for the wave park (which we couldn't find addressed in
the EIR). The waterpark will need to be heated much of the year, and filtering will be constant
- Noise from the announcers
- Noise from spectators
- Noise from special events
Response 91-c:
Section 4.11, Noise, of the Draft EIR includes analysis of the sources of noise identified in this
comment. Traffic noise is addressed in Section 4.11 (see Tables 4.11-19 and 4.11-20, which show that
the project will not cause a significant increase in traffic noise at any of the study area roadway
segments). Noise from each of the operational noise sources listed in this comment are addressed
on pages 4.11-44-4.11-4.11-50 (see Tables 4.11-25 and 4.11-26, which show that all such operational
noise sources, taken together, will not exceed the City's 65 dBA noise standard at any off-site location
or cause a significant increase in ambient noise levels). Please also see Responses 52-h, 59-e and 62-
f.
Comment 91-d:
Traffic
We believe there should be 2 main entrances into the development — one as proposed, which would
serve only residents, and a second, which would be off Madison in the south end of Sec. II, which
would serve the hotel, wave park, tourists.
We are very concerned about the increased traffic levels, particularly during special events.
We also do not want traffic light(s), now or in the future, on Madison at 58th, 60th, or in-between
Response 91-d:
Section 4.13, Transportation, in the Draft EIR includes analysis of the traffic that would be generated
during the proposed special events (pages 4.13-42 — 4.13-47). As it relates to the commenter's
preference to not have traffic signals installed, the comment is noted. However, as described in the
Draft EIR, a significant impact would occur at the intersections of Madison St./Avenue 58 and Madison
St./Project entrance if traffic signals are not installed, and accordingly, the project will be required to
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install those signals when warranted. Only a stop sign controlled stop is required at Madison
St./Avenue 60.
With respect to project access, the commenter's preferences are noted. Please see the circulation
plan on Exhibit 3.9 for a full depiction of the project access points.
Comment 91-e:
Hours of Operation
The hours of operation should be reduced. We would propose an opening no earlier than 8 am, with
a closure from October through February no later than 7 pm, and from March through September of
8 pm. With lights doused at the wavepark and on the viewing area of the hotel at these hours, there
would be much less impact of lights on nearby communities.
Response 91-e:
The commenter's opinions are noted.
Comment 91-f:
Special Events
We would prefer no special events, but if they are to be allowed, we would propose that they never
be held during any concert, art, or other main event at the polo grounds, and not during athletic
events like the bike tour, triathlons, etc.
Response 91-f:
The commenter's opinion is noted.
Comment 91-g:
Operations during Wind Events
Cancel operations if winds are > 20 mph or gusts > 25 mph. We have high gust rates in this area even
when winds are in the 20's due to the currents coming down the mountain.
Response 91-g:
The commenter's opinion is noted. However, the comment does not provide substantial evidence
that wind events would impact the project site or project operations.
Comment 91-h:
Border Wall and Landscaping
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A wall higher than normal would help reduce noise. Planting of large trees such as palms, tipuanas,
etc. on the exterior and interior would reduce visibility of the hotel, lights, etc.
Response 91-h:
The project proposes a 6 -foot perimeter wall surrounding the property, consistent with the Noise
Study's determination that it is required to mitigate on-site noise levels from traffic on the perimeter
arterial roadways (Mitigation Measure NOI-5). Perimeter trees are also proposed along the northern
and eastern property boundaries in areas adjacent to Avenue 58 and Madison Street. On the western
project boundary, an 8 -foot high fence is proposed to serve as a barrier to ensure that bighorn sheep
cannot access the project site.
Comment 91-1:
Thank you. We look forward to receiving updates on the review and approval process. Please add us
to your mailing list.
Response 91-i:
This comment is noted. The City has added the commenter to the mailing list for all notices related
to this proposed project.
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Comment Letter No. 92: Carol Jensen
Date: August 6, 2021
Affiliation: Area Resident
Comment 92-a:
It is with great dismay I begin this letter in response to the DEIR on the proposed Coral Mountain
Resort.
I really don't know where to begin. The DEIR is way too long for the La Quinta average citizen to read
which I believe is by design.
There are so very many things wrong about this project but when speaking specifically about the DEIR,
I am seeing way too many statements of the impact in any given category being unknown or only
being projected based on years old data.
Response 92-a:
The commenter's opinions are noted. Please see the Topical Response on the Length of the Draft EIR
in Section 2.2.6 of this Chapter.
Comment 92-b:
The drought situation alone should be enough to stop this project.
Farmers will not have enough water to grow food in CA. This translates to hunger, unemployment,
and a tanked economy. Why approve a project that will leave a hole in the ground when there is no
water to be had? Will LQ residents need to conserve and thirst, not bathe, so we can have a
recreational wave park?
Response 92-b:
Please see the Topical Response on Water Resources in Section 2.2.3 of this Chapter for information
on the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies.
Comment 92-c:
Everything is wrong about this proposed project, everything. From water waste to increased noise to
a horrendous number of STVRs, which are already a huge problem for La Quinta, this project cannot
go forward.
What about the 2035 La Quinta report, written and approved by the Mayor and Council, that states
good use of valuable resources as a prime goal? This project would not comply with any good use of
resources, especially water.
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Response 92-c:
The commenter's opinion is noted. Please see Response 52-g as it relates to STVRs; and Responses
41-c, 52-f, and 83-w through 83-hh as it relates to the project's consistency with the General Plan.
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Comment Letter No. 93: Suzanne Kahn
Date: August 6, 2021
Affiliation: Area Resident
Comment 93-a:
Please do not approve the Wave Park development. Increased use of water, increased traffic resulting
in increased emissions will simply increase the stress on an environment that is already growing drier
and hotter.
Please plan for being responsible and sustainable in the long term.
Response 93-a:
The commenter's opinion is noted. This comment presents an opinion, however, and not substantial
evidence that the project will result in substantially greater impacts than identified in the Draft EIR.
The Draft EIR discusses and analyzed project -related water use in Section 4.9, Hydrology and Water
Quality, and Section 4.15, Utilities and Service Systems, and traffic in Section 4.13, Transportation.
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Comment Letter No. 94: Francine Roy
Date: August 6, 2021
Affiliation: Area Resident
Comment 94-a:
I am making a correction to my letter. I erroneously referenced the IID... I meant the Coachella Valley
Water District.
Response 94-a:
The correction is noted.
Comment 94-b:
I am writing this letter to you because I am in a state of shock....
Why would you even CONSIDER changing the current zoning to allow a project that goes against ALL
COMMON SENSE? The residents who purchased homes near this project site BELIEVED that the
"worst case scenario" they would ever have to deal with was what the current zoning allows: "LOW-
DENSITY residential use, as well as a golf course and some commercial use." The proposed change to
allow "tourist commercial" zoning violates the 2035 general plan for La Quinta.
So, tell me, what was the point of spending all of the time, money and effort to come up with the
2035 general plan if you were going to be tempted to go against that plan when a project came along
that dangled a couple of million dollars of tax revenue in front of you that doesn't make any sense on
MANY levels! We all choose to live here because we enjoy the night sky, the quiet, the nature, the
landscape, the small amount of traffic we have, etc.
Response 94-b:
Please see Responses 15-d and 17-a as they relate to the Change of Zone and processing of the
project.
Comment 94-c:
But, the reality of climate change is that we are all very concerned about how long we will have
drinking water available to us. The IID has asked us all to conserve water and I know I am doing my
share to USE LESS than their recommended amount. This wave park will require 18,000,000 gallons
of DRINKING WATER JUST TO FILL IT UP. This does not include "topping it off" every day because of
evaporation loss. This does not sound like "conserving water" to me.
Response 94-c:
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Please see the Topical Response on Water Resources in Section 2.2.3 of this Chapter for information
on the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies, including during drought conditions. Please
see Response 65-d as it relates to evaporation rates.
Comment 94-d:
Since I moved here, I have been reading about the issues with Short Term Rentals. This project is
planning on making all 600 homes available as Short Term Rentals!!!! How can you justify allowing
this? At the very least, 600 homes does not sound like "low density" to me!
Response 94-d:
Please see Response 52-g regarding STVRs. As the 600 homes are spread over approximately 353
acres in Planning Areas II and III, the density is approximately 1.7 units per acre, well below the
maximum range allowed in the Low Density Residential land use designation.
Comment 94-e:
What this beautiful parcel of land needs is a developer who wants to put in some beautiful energy
efficient homes, some hiking and biking trails that we can all enjoy, maybe a beautiful park with
drought tolerant natural landscaping (no golf course.... there are already too many golf courses that
are using up water resources) and a small commercial area where there could be a market, a cafe, a
restaurant, etc. for the residents that live in that part of La Quinta since it's a drive just to get
groceries.
Response 94-e:
The commenter's opinion is noted.
Comment 94-f:
Please, please realize that this developer is "slick." He seems to have an answer for everything. The
project doesn't make sense for our community nor do I think it even makes sense for him but that's
a different discussion ...
Last but not least, I'm very confident that the City of La Quinta would be "featured" on the CBS Evening
News if this project is approved. I can hear it now ... "City of La Quinta approves a private wave park
project in the midst of a historical drought and climate change!" Do we really need that kind of
negative publicity??? I'd rather we be admired for spearheading energy-efficient projects and
protecting our decreasing natural resources.
This is not the right place nor the right time for this project.
Response 94-f:
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This comment is noted.
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Comment Letter No. 95: Carolyn Winnor
Date: August 6, 2021
Affiliation: Area Resident
Comment 95-a:
My name is Carolyn Winnor and my husband and I have lived in Trilogy La Quinta, for 16 years. Moved
to La Quinta after we retired to get away from the congestion of Los Angeles County, having lived in
Santa Clarita for 24 years.
I am strongly Opposed to the rezoning of Coral Mountain from low density residential to
Tourist/Commercial. I have read portions of the DEIR and I believe the City needs to do additional
research regarding the Lighting, Noise and Water Usage that a project of this magnitude requires.
I am sure you are aware of the La Quinta General Plan 2035. Below are some excerpts from the plan
and you may consider my opinions as NIMBY; not sure how they couldn't be, when the developer
wants to have the property rezoned to Tourist/Commercial in the middle of a Low Density Residential
area. I understand the need for the City to look for additional tax dollars, but I think consideration is
required on how this will affect your constituents and even you, if you lived in or near South East La
Quinta.
Response 95-a:
The commenter's opinion is noted. Please see Responses 15-d and 17-a as they relate to the Zone
Change and processing of the project. Please also see Responses 41-c, 52-f, and 83-w through 83-hh
regarding consistency with the City's 2035 General Plan.
Comment 95-b:
The DEIR considers the items below: Significant and Unavoidable (Executive Summary Page 1-15)
Table 1-3. These are admitted faults that cannot be addressed or mitigated.
4.1 Aesthetics
1. Adverse effect on scenic vistas
2. degradation to the visual character or quality of the site.
3. Light and Glare
Response 95-b:
The summary provided in this comment is incorrect. Section 4.1, Aesthetics, addresses the project's
impacts on aesthetic resources. Within this Section, the project would result in significant and
unavoidable impact to scenic vistas (i.e., Coral Mountain and Santa Rosa Mountains) when viewed
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from a public viewshed (CEQA threshold of significance a.). The Draft EIR concluded that the proposed
project's perimeter walls, landscaping and structures would result in significant impacts to these
scenic vistas when viewed from public rights -of -ways. This is clearly stated at pages 4.1-44 and 4.1-
45. Section 4.1 of the Draft EIR also concluded the project's impact to light and glare, visual character,
and scenic resources would be less than significant with the incorporation of mitigation measures.
Comment 95-c:
La Quinta General Plan 2035 Land Use Zoning Consistency To assure consistency and compatibility
between the General Plan and the Zoning Ordinance Table 11-2 shows the Zoning districts that
correspond to each land use designation.
Tourist Commercial This land use designation is specifically geared to tourism- related land uses, such
as resort hotels, hotels and motels, and resort commercial development, such as conference centers,
restaurants, resort -supporting retail and services (including day spas and similar personal services).
Time share, fractional ownership or similar projects may also be appropriate in this designation, with
the approval of a Conditional Use Permit.
For this project to be built on the land purchased by Meriwether it will need to be rezoned to Tourist
Commercial. The developments surrounding this land are zoned Low Density Residential. Based on
LQ 2035 Land Use, there is no consistency or compatibility between T/C & Low Density Residential.
Response 95-c:
The commenter's opinion is noted. Please see Responses 15-d and 17-a as they relate to the Zone
Change and processing of the project. Please see Responses 41-c, 52-f and 83-h concerning
consistency with the City's 2035 General Plan.
Comment 95-d:
The lighting for this project is consistent with commercial property located on Highway 111. Lights
left on during nighttime hours, height, in the Resort 25', Wave Club 25', Farm 40' and Back of House
40'. The only lights currently addressed that will be on until 10 pm, are the 80' Wave lights. The LQ
Municipal Code for Lighting, pole height 8'. Is this consistent or compatible with Low Density
Residential Property? NO. The DEIR considers, this is significant and unavoidable.
Response 95-d:
Please also see the Light and Glare Topical Response in Section 2.2.1 of this Chapter. The proposed
lighting will comply with Section 9.100.150 of the La Quinta Municipal Code (Outdoor Lighting), and
no significant impacts will occur to the surrounding residential communities (see Draft EIR at pp. 4.1-
60 — 4.1-61).
Comment 95-e:
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The Resort 4 stories at 40', Wave platform 4 stories at 45', Wave Club 3 stories at 40' E &.W Resort
Residential 3 stories at 30', Farm 3 stories at 40' and Back of House 2 stories at 30'. The LQ Municipal
Code 2 stories at 28'. Is this consistent or compatible with Low Density Residential Property? NO. The
DEIR considers, this is significant and unavoidable.
Response 95-e:
The commenter's opinions regarding land use compatibility of the proposed tourist commercial uses
are noted. Please see Responses 41-c, 52-f, and 83-w through 83-hh regarding these compatibility
concerns. Section 4.1, Aesthetics, of the Draft EIR provides analysis of the consistency of the project
with the existing visual character of the area on pages 4.1-53 through 4.1-57, and concludes that the
proposed building heights, pole heights, and lot coverage proposed for the Tourist Commercial
planning area are not fully consistent with the City's established Municipal Code development
standards. However, "the building and lighting height standards allowed under the proposed Specific
Plan are located at the center of the site, and will neither be visible from outside the project, nor
impact the viewsheds surrounding the project." The building heights proposed exceed the maximum
building heights established in the La Quinta Municipal Code for Low Density Residential zones.
However, the submittal of the project Specific Plan establishes new developmental standards for the
project site. If approved, the Specific Plan acts as the guide for the project site. Please also see the
land use consistency analysis on pages 4.10-24 through 4.10-29. Based on this thorough analysis of
land use compatibility issues, impacts were determined to be less than significant.
Comment 95-f:
Noise —The DEIR used the dBA recorded at the Kelly Slater Le Moore Wave Pool, not on the proposed
property, next to Coral Mountain. The DEIR states the surface of Coral Mountain is soft and sound
will not travel (totally erroneous). I live in Trilogy, La Quinta and I can hear gun shots from the shooting
range near Lake Cahuilla. On Sunday mornings I can hear the cars on the track at the Thermal Race
Track. Sound carries in the desert and especially during the evenings and at night. I believe the City
needs to address how the sound will carry near Coral Mountain. Not just the sounds that make the
Wave, but record the dBa of jet skis, music at the volume they plan on using, any announcements
from loud speakers, etc. I have watched many videos of Wave Pools and they put music on the videos,
or voice overs, people making commentaries but NEVER do you hear the actual sounds at the Wave
Pool and its surroundings. Why?
Appendix K.2 Noise Memo Report Urban Crossroads See Page 76
Table 10-1 Reference Noise Level Measurements.
Please read where and when these noise levels were measured. Why hasn't the noise levels been
measured on the proposed site?
Noise Level Chart:
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4/13/2020 Surf Ranch Lemoore, Ca
3/16/2005 Westin Hotel Rancho Mirage, CA
10/8/2014 Founder's Park in County of Orange
4/18/2018 Ramon Commercial Center
See Page. 93-94 9.100.210 La Quinta Municipal Code Non Residential Noise Regulations
The quiet low density residential neighborhoods, will now have to live with NON Residential Noise
standards?
Response 95-f:
Please see the Noise Topical Response in Section 2.2.4 of this Chapter as it relates to the City's noise
standards. Also see Responses 52-h, 59-e, and 62-f as it relates to the analysis methodology used for
the site-specific noise modeling, including the uses and machinery factored into the analysis.
Comment 95-g:
Water Usage - I believe the evaporation of water needs to be addressed by the City, so we will actually
know the water consumption of the Wave. The developer claims Los Angeles is only 2 hours from La
Quinta, who then will be coming to La Quinta during the summer months where the temperature
ranges from 110-120 degrees and the lows are between 85-95 degrees at night? Individuals can go
surfing at the beach with water and air temperatures between 65-70, actually closer than 2 hours
from Los Angeles.
Response 95-g:
Please see the Water Resources Topical Response in Section 2.2.3 of this Chapter for information on
the water demand estimate for the project, and CVWD's groundwater management plan, including
projections for long-term water demand and supplies. Also see Response 65-d as it related to summer
temperatures and water use.
Comment 95-h:
What happens if the fad of the Wave is over in 3 to 5 years or financially without summer usage the
Wave fails? What is La Quinta and the residents of South East La Quinta left with? Who will be
responsible to rehab the land? If this project goes forward, it will forever change South La Quinta from
a quiet residential area to a bustling Tourist area, with lights 25' to 80' tall, unnecessary water usage,
additional traffic, 600 STVR, 150 Hotel Rooms, noise (Jet skis, music, loudspeakers and alarms)
24/7/365 days a year, not to minion a minimum of 4 Special Events, did I say additional traffic?
Response 95-h:
The commenter's opinions are noted.
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Comment 95-i:
Please listen to the Residents that will be forced to live in this constant festival like environment and
say NO to rezoning the property to Tourist/Commercial.
Response 95-i:
This comment is noted.
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Comment Letter No. 96: Brian and Gale Levy
Date: August 5, 2021
Affiliation: Area Resident
Comment 96-a:
This email is from Brian and Gail Levy - we live in Trilogy at Avenue 60 & Madison. We retired to live
here in 2014 to enjoy the beautiful, quiet, and peaceful La Quinta neighborhood in and about Trilogy.
We previously spent many years as part-time Palm Springs vacationers, and have owned property
there since 1979. Having spent decades vacationing in and about Palm Springs, we decided to retire
to live in our beautiful and quiet La Quinta neighborhood. We are vehemently opposed to the
proposed wave park for a number of reasons, which are summarized below:
Response 96-a:
The commenter's opinion is noted.
Comment 96-b:
1: We are living in a critical drought situation while experiencing increasing wildfires. Water for
firefighting and sustaining life is in an increasingly short supply. We believe that building a wave park
during an increasing water shortage while experiencing increasing wildfires is irresponsible and self-
serving to the financial interests of a few, rather than the greater good of the La Quinta community;
Response 96-b:
As described in the Water Resources Topical Response in Section 2.2.3, CVWD, the water provider for
the City and the project site, has thoroughly and comprehensively researched and documented
projected long-term water demand and supply, including the effects of drought and climate change,
in its Urban Water Management Plan and Indio Subbasin Water Management Plan. As described
above, CVWD's documentation shows that both short-term and long-term impacts of drought and
climate change have been assessed, and that the management techniques, water supplementation
measures and other strategies implemented by CVWD and its sister agencies within the Subbasin will
assure a balanced and positive long term water supply.
In addition, CVWD approved a project -specific Water Supply Assessment/Water Supply Verification
(WSA/WSV), which disclosed that the project is expected to consume approximately 958.63 -acre feet
per year (AFY) based on the residential indoor demand, non-residential indoor demand, and outdoor
demands of the project at buildout. Taking into account the project water demands and the available
sources of water, as well as the required water conserving measures described on page 4.15-16 of
the Draft EIR, CVWD determined that there are adequate water supplies available for the project and
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all other existing and planned future uses, including during single -dry and multiple -dry years. See
Appendix M to the Draft EIR.
The project's water use is not expected to have any effects on the ability to fight wildfires locally,
regionally, or elsewhere in the State of California, because (1) CVWD has confirmed that it has
adequate water supplies for the project and all other current and planned future uses, including for
local firefighting purposes (which is one aspect of water system demands evaluated by CVWD), and
(2) because groundwater from the Indio Subbasin is not a significant source of water for fighting
wildfires in California.
Comment 96-c:
2: We believe that the additional noise and added traffic will negatively impact our residential
neighborhood forever. Can our neighborhood tolerate more traffic and noise? Maybe. Is additional
traffic and noise from a commercial resort within our residential community a good idea? NO.
Residents frequently walk and bike ride on Madison between Avenue 60 and the fire department.
More traffic from the proposed commercial wave park is not a good idea for this residential
neighborhood. Further, the proposed size of this wave park in this specific mountain location is unlike
any other in existence, and as a result, reliable and predictable noise patterns hypothecated in the
pending DEIR are extremely speculative and therefore unreliable. The DEIR in and of itself was not
well written, and the assumptions utilized were not clearly spelled out;
Response 96-c:
The commenter's opinions regarding additional noise and traffic, are noted, but not supported by
substantial evidence. The project's potential impacts relating to increased noise were thoroughly
analyzed in the project -specific noise study attached as Appendices K.1 and K.2 to the Draft EIR, which
was prepared by a professional noise engineer using established state and local methodologies to
evaluate whether project would cause any significant effects relating to construction noise, traffic
noise, or project operational noise. As explained in the Noise Study and Section 4.11 of the Draft EIR,
the noise study took into account both the surrounding geography of the project site and the actual
noise levels that will be generated by the proposed Wave Basin. With implementation of Mitigation
Measures NOI-1 through NOI-6, the project will not create any significant increases in noise. Please
also see the Topical Response on Noise in Section 2.2.4 above, and Responses 52-h, 59-e, and 62-f in
this Final EIR.
Regarding traffic, Section 4.13, Transportation, of the Draft EIR fully analyzes project -related traffic
impacts of the proposed project and provides mitigation measures that will reduce impacts to less
than significant levels. These findings were generated based on technical studies performed by
professional traffic engineers, which are included as Appendix L.1 and L.2 in the Draft EIR. Please also
refer to the Topical Response on Traffic at Section 2.2.5 above.
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With respect to pedestrian and bicycle safety on Madison Street, north of Avenue 60, the project will
be required to install a perimeter trail and landscaping that will significantly enhance pedestrian
safety along that segment of Madison Street. In addition, the project will be required to install
roadway improvements to City standards along this portion of the project frontage, which will
enhance bicycle safety.
Comment 96-d:
3: What if the developers are wrong, and the wave park is not a financial success? What if the project
cannot be financially sustained long term, and the wave park shuts down? What then? What will be
left behind will be a blight on our community, and a regretful legacy for this city who valued proposed
additional revenue over quality of life for its residents;
4: When we purchased our home in Trilogy, we intended to spend our retirement living in this
community and enjoying the many benefits that our La Quinta neighborhood has to offer. The
approval of the commercial wave park project will be a permanent change to our residential
neighborhood and signal to us that we should no longer continue to live in La Quinta because La
Quinta no longer values the quality of our lives and this neighborhood. It is our belief that the only
good that can come from the commercial wave park will be the potential financial gain for the
developers and investors. This may be a good commercial project for the investors, but this residential
neighborhood is the wrong location for a commercial development such as this wave park.
Response 96-d:
The commenter's opinions regarding the project's potential economic benefits are noted.
This comment addresses the economic characteristics of the project and does not address any
potential impacts of the project on the environment. Section 15131 (a) of the CEQA Guidelines
precludes the analysis of economic effects unless that economic effect would have a physical impact
on the environment. This comment does not provide any information or evidence on how the long-
term economic viability of the proposed Wave Basin could result in physical changes that would
constitute significant environmental impacts.
Additionally, the project promotes the quality of life for all residents of the City by providing needed
sales and transient occupancy tax revenues to the City to fund police, fire and other public facilities,
which is particularly important in this portion of the City because the City will not receive property
tax revenue from the land in this area until 2035, as further described in Response 52-e above.
Comment 96-e:
Given the variables, the misuse of our precious water resources, and the high financial risks associated
with putting this commercial development in our residential neighborhood, when you consider this
proposal, please ask yourselves the following questions:
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What is the legacy that I want to leave for this community?
What is the downside to the community if the project is approved, goes forward, and then fails to
pan out financially?
Does this project represent a wise use and conservation of our dwindling water resources?
Is the high risk associated with this venture worth taking for the city and for the La Quinta residents
affected by this proposed commercial project in a residential neighborhood?
Thank you for your consideration.
Response 96-e:
The commenter's questions are noted, but do not address environmental issues. As it relates to the
processing of the project applications and the City Council's consideration of policy issues, please see
responses 15-d and 17-a above.
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Comment Letter No. 97: Nancy Bruce
Date: August 6, 2021
Affiliation: Area Resident
Comment 97-a:
I am writing in response to the Draft EIR for the Coral Mountain Resort development. I have owned a
home in La Quinta for 20 years. When my husband and I first built a home in La Quinta I loved that
the city motto was "Gem of the Desert" and "Growth with Charm". You don't see the "Growth with
Charm" anymore and this development certainly flies in the face of that motto! I have many concerns
about the development but I think it must be said that this DEIR was so long, convoluted and hard to
understand it was almost unreadable.
Response 97-a:
The commenter's opinion is noted. Regarding the commenter's opinion on the DEIR being long,
convoluted and hard to understand, please see Topical Responses on Length of Draft EIR and Ability
to Comprehend the Draft EIR in Sections 2.2.6 and 2.2.7 above.
Comment 97-b:
The fact that the entire report was hired and paid for by the developer also presents huge concerns
to its validity.
Response 97-b:
Regarding the report's validity, the City of LA Quinta is the lead agency who is responsible for
exercising its independent judgment in determining the adequacy of the EIR and in deciding whether
to approve a proposed project. Prior to public release, both the Draft EIR and this Final EIR were
thoroughly reviewed, extensively commented upon, and ultimately approved by the City. As expressly
permitted in the CEQA Guidelines, the Draft EIR was prepared by MSA Consultants, Inc., who are on
the City's list of approved CEQA consultants. Please also see Response No. 90-b.
Comment 97-c:
Another concern is that most of the study was completed during COVID which certainly affects the
traffic study and noise to some degree. Here are my concerns:
Response 97-c:
As stated on page 29 of the Traffic Impact Analysis included as Appendix L.1 in the Draft EIR, the
supplemental memo from Urban Crossroads included as Appendix L.3 in this Final EIR, and page 4.13-
10 in Section 4.13, Transportation, in the Draft EIR, "the intersection LOS analysis is based on the
traffic volumes observed during the peak hour conditions using traffic count data collected on August
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2-439 February 2022
2.0 RESPONSES TO COMMENTS
15th, 2017, April 9th, 2019, May 7th, 2019, and September 10, 2019 (which were all collected before
the effects of the COVID-19 pandemic). Moreover, these counts were adjusted upward in accordance
with the City's Engineering Bulletin # 06-13 to reflect peak season conditions."
Therefore, traffic counts were taken prior to COVID, and baseline numbers reflect peak season levels.
Additionally, as stated on page 4.11-2 of Section 4.11, Noise, noise measurements were taken by the
noise technical expert on October 16th, 2019. Thus, noise measurements were taken prior to COVID,
and the noise analysis reflects peak season levels.
Comment 97-d:
Lighting — Seventeen 80 foot tall lights surrounding the wave pool will certainly have an effect on
everyone living around this development. Most homes in the neighborhood with mountain views look
towards Coral mountain. What they will see in the future is light poles during the day and light glow
at night. What happened to the Dark Sky ordinance? Well, the City Council voted to remove the Dark
Skies ordinance from the Municipal Code in May, 2021. How convenient! Yet the people living here
say that the night skies are precious part of their community. Ads on the internet extolling La Quinta's
many virtues talk about the Dark Sky ordinance. So much for all the people who live here and visitors
too!
Response 97-d:
Please see Topical Responses on Light and Glare in Section 2.2.1 above, as well as Appendices B.1 and
B.2 of this Final EIR for a summary of the analysis in the EIR regarding the potential for significant light
and glare impacts from the proposed Wave Basin lighting, including how the proposed lighting system
fully complies with all applicable dark sky requirements. Please also see Responses 13-r and 52-i in
this Final EIR.
Comment 97-e:
Noise — The noise study found no issues with noise whether it be construction or the operation of the
Wave pool. They studied the noise of traffic (during COVID) and did theoretical studies of other
aspects of the operation. One of their conclusions was that sound would be absorbed by rock. Really?
Since when does rock absorb sound? And if it did, why can I hear hikers near Coral Mountain when
I'm standing on the corner of 58th and Madison? Theoretical studies don't replicate reality and this
area needs real world study.
Response 97-e:
The commenter's opinions regarding noise are noted, but not supported by substantial evidence. The
Noise Memo provided by Urban Crossroads, Inc. (Appendix K.2 of the Draft EIR) addressed the
concern regarding noise of the project echoing off of Coral Mountain. The noise engineer explained
that based on Federal Highway Administration guidance and studies, noise bouncing off a hard
Coral Mountain Resort Final EIR
2-440 February 2022
2.0 RESPONSES TO COMMENTS
surface can cause noise increases of no more than 1-2 dBA, which is not perceptible to the human
ear. Further, given the distance between the Wave Basin and Coral Mountain (approximately 650
feet), the soft surfaces over that distance that absorb sound, and the maximum, worst-case noise
levels generated at the Wave Basin (75.7 dBA), the Wave Basin will not cause significant noise levels
or noise impacts at Coral Mountain or in the surrounding communities. Again, as explained in Topical
Response 2.2.4 and Section 4.?, Noise of the Draft EIR, the noise levels will not exceed the City's
standards, and impacts were correctly determined to be less than significant. Please also see
Responses 52-h, 59-e and 62-f of this Final EIR.
See Response 97-c to address the commenter's concern about the timing of the reports and COVID.
Comment 97-f:
Traffic — As mentioned before the studies were done during COVID. In my development (Puerta Azul)
none of the Canadians made it to La Quinta in the winter of 2020 which is a significant number of
owners. The rate of COVID in early winter was also very high keeping some homeowners from coming
as well as visitors. I heard a presentation from the developer admitting that the study may not reflect
non COVID traffic amounts but if there are stop lights needed they would help pay for them. For a
light at 58th and Madison, which I can't see NOT having, they would contribute 10%. If that is correct
then the homeowners living around this PRIVATE development end up paying for a light that wouldn't
have been needed. How in the world is that fair?! This development is in a land locked area with very
few roads to get people to it.
Response 97-f:
See Response 97-c to address the commenter's concern about the timing of the reports and COVID.
As it relates to the concern of roadway improvements and the implementation of traffic signals, this
concern is unfounded. As described on pages 4.13-37 — 4.13-42 of the Draft EIR, at buildout, the
project will be required to install a signal at the intersection of Madison Street and Avenue 58 (the
project contributes 23% of the traffic). Existing residents will not be asked to provide any funding for
this traffic signal. As stated on page 4.13-41, the funding will come from the Developer, who will be
required to install the traffic signal, with the potential to receive credit against the Developer's
payment of impact fees for the costs that exceed the Developer's fair share obligation.
Moreover, as stated on page 4.13-29 through 4.13-34 of the Draft EIR, all intersections impacted by
Phase 1 and Phase 2 traffic will need signals or other improvements installed to operate at an
acceptable level of service, with or without the project, and are funded by the City's Capital
Improvement Plan (CIP). Accordingly, these improvements are fully funded by the CIP and will be
installed as warranted. Please note that Phase 1 and Phase 2 traffic contributes a fair -share of
between 0.4% and 3% to these intersection improvements. At buildout, the Project will also
contribute to the need for signals or other improvements at four additional intersections, which are
Coral Mountain Resort Final EIR
2-441 February 2022
2.0 RESPONSES TO COMMENTS
also included in the City's CIP and will be constructed by the City. The project's fair share of the
improvement costs at the affected intersections range from 2% to 11%. The project's payment of the
City's development impact fees covers its share of these intersection improvements and helps fund
the City's CIP.
Please also see the Topical Response on Traffic at Section 2.2.5 and Response 22-j above.
Comment 97-g:
Someone needs to really look at what will happen with traffic especially with planned events of 2500
people. I can think of the traffic jams from the PGA concerts a couple of years ago as perfect examples
of what happens when thousands of people try to squeeze into an area with few roads. If this were
to happen on Madison thousands of people would be unable to leave their developments. Any
emergency vehicle would have trouble reaching any destination on that route. This needs serious
attention.
Response 97-g:
A maximum of four special events per year are proposed for the project, with a maximum attendance
of 2,500 per event. By way of comparison, it is estimated that approximately 25,000 people attended
the Stevie Nicks concert during the American Express Golf Tournament at PGA West in 2020 (See New
Traffic Patterns, More Exits Part of Plan to Fix American Express Concert Traffic, The Desert Sun, by
Larry Bohannan, published January 11, 2022). As described in Draft EIR Section 4.13, Transportation,
events will be restricted to 4 days duration with peak trips anticipated on Saturdays (up to 4 events
per year).
Improvement recommendations identified for weekend special event conditions are consistent with
the improvements identified for Phase 3 weekday typical operations. However, any event occurring
prior to the build out of the project, and its concurrent traffic improvement requirements, would
result in a significant impact on traffic operations. Therefore, if project special events are held prior
to the construction of Phase 3 improvements, the following mitigation measures identified in the EIR
are required to reduce the impacts to the regional traffic system (as provided in Mitigation Measures
TRA -9 and TRA -10):
• Traffic improvements will be completed or the applicant shall provide a focused traffic analysis
with the Temporary Use Permit that identifies any improvements that are not necessary to
maintain acceptable levels of service at study intersections. If the analysis does not
demonstrate acceptable operations, the TUP will be denied.
• A special event traffic and parking plan will be submitted with each Temporary Use Permit to
ensure that special events will not cause any significant traffic or parking impacts. If the
analysis does not demonstrate acceptable operations, the TUP will be denied.
Coral Mountain Resort Final EIR
2-442 February 2022
2.0 RESPONSES TO COMMENTS
As required by Mitigation Measures TRA -12 through TRA -14 for special events, traffic control
typically includes special event flaggers, law enforcement personnel, online or transmitted event
information (suggested routes, parking, etc.,) and portable changeable message signs (CMS) (or
moveable mechanical electronic message boards.) CMS will be located at critical locations identified
by the La Quinta Police Department (LQPD) and in place 5 days ahead of the event and 2 days after.
Therefore, the Draft EIR correctly analyzed the traffic impacts associated with special events, found
those impacts significant based on the City's thresholds of significance (LOS D) for intersection
operations, and provided feasible mitigation measures that will reduce these impacts to less that
significant levels.
The Draft EIR analyzes project -related impacts to traffic in compliance with CEQA. This topic is
discussed in Section 4.13, Transportation, in the Draft EIR. Please also see the Topical Response on
Traffic at Section 2.2.5, above, and Response 52--n.
Comment 97-h:
Water — We are in a serious drought. The entire west coast and beyond is suffering in ways no one
anticipated happening for many years because of Global Warming. The water numbers in the DEIR
are calculated using information from the Lemoore surf park. The climate there is different from La
Quinta, we have many more and hotter days, the proposed pool is bigger than Lemoore (more area
to evaporate) yet no one attempted to extrapolate what that would mean for water consumption. I
heard an engineer at the City Council this week say that the development was at 99% of their total
water allotment. That's not much of a cushion! What happens if they need more water? And let's be
clear: this is drinking water! Someone needs to look at this carefully.
Response 97-h:
As described in the Water Resources Topical Response in Section 2.2.3, CVWD, the water provider for
the City and the project site, has thoroughly and comprehensively researched and documented
projected long-term water demand and supply, including the effects of drought and climate change,
in its Urban Water Management Plan and Indio Subbasin Water Management Plan. As described
above, CVWD's documentation shows that both short-term and long-term impacts of drought and
climate change have been assessed, and that the management techniques, water supplementation
measures and other strategies implemented by CVWD and its sister agencies within the Subbasin will
assure a balanced and positive long term water supply.
In addition, CVWD approved a project -specific Water Supply Assessment/Water Supply Verification
(WSA/WSV), which disclosed that the project is expected to consume approximately 958.63 -acre feet
per year (AFY) based on the residential indoor demand, non-residential indoor demand, and outdoor
demands of the project at buildout. Taking into account the project water demands and the available
sources of water, as well as the required water conserving measures described on page 4.15-16 of
the Draft EIR, CVWD determined that there are adequate water supplies available for the project and
Coral Mountain Resort Final EIR
2-443 February 2022
2.0 RESPONSES TO COMMENTS
all other existing and planned future uses, including during single -dry and multiple -dry years. See
Appendix M to the Draft EIR. CVWD enforces these water limits when it reviews the landscaping plans
for each portion of the project, and CVWD will only approve plans that are consistent with the water
use limits set forth in Landscape Ordinance No. 1302.4.
With respect to the source of water for the project, the Wave Basin is projected to use approximately
119.58 AFY, or approximately 12.5 % of the project's total demand, and is expected to use private
well water or other non -potable water, rather than water from CVWD's potable system as stated in
the comment. Moreover, the project landscaping and other outdoor water use, which constitutes
approximately 681.89 AFY of the project's total 958.63 AFY (71%), is expected to use non -potable
water from the nearby canal or from private wells, not from CVWD's potable water system. These
are the same water sources used for the golf courses and outdoor landscaping at the other
developments in the area. The project will also be required to determine the feasibility of using
recycled water for these outdoor uses if it becomes available to the area in the future.
Finally, please see Response 65-d for a further response regarding the projected water use and
evaporation rates of the Wave Basin.
Comment 97-i:
Bats — No one mentions the bats when they talk about this project but the bat study in the DEIR says
that night time light is the biggest concern for the multiple bat species living on and near the proposed
development site. Light disrupts feeding, roosting, maternity and raising of the young. The study
recommends that all lighting be "dark sky compliant". Does La Quinta care about this anymore since
they removed Dark Sky from Municipal Code? And how compliant can the custom 80 foot lights be?
At that height they will disrupt any creature flying anywhere near the wave pool. What mitigation can
be made for bats, a protected species? Is there really any reason people need to surf at night? You
certainly can't do that at the beach, why should this be any different?
Response 97-i:
Please see Topical Responses on Light and Glare, in Section 2.2.1, and Biological Resources, in Section
2.2.2, above. As shown in the exhibit on page 2-10 of this Final EIR, the light levels from the Wave
Basin lighting system will drop to the imperceptible level of 0.01 foot candles within the immediate
vicinity of the Wave Basin itself, and will not cause any light spillage onto Coral Mountain. Please also
see Appendices B.1 and B.2 of this Final EIR, as well as Response 13-r, which discusses how Mitigation
Measure BIO -4 will avoid any impacts to bats by prohibiting any light trespass onto Coral Mountain,
which must be confirmed with a supplemental light study following installation of the Wave Basin
lighting system.
Comment 97-j:
Coral Mountain Resort Final EIR
2-444 February 2022
2.0 RESPONSES TO COMMENTS
Zoning — I realize that zoning isn't part of the DEIR but it must be addressed. What homeowner buys
a house where they're researched all things that could impact that important, expensive decision,
only to have something like this happen? How can a homeowner trust their Mayor and City council
to look out for their best interests when a developer comes along with a proposal to change a swath
of land located in the middle of a number of neighborhoods zoned low density, residential to
Commercial, tourist? I don't see another area in La Quinta that is as quiet and residential as this area.
It defies logic why this would be the place to build something like what is proposed and to allow a
zoning change along with it.
Response 97-j:
A General Plan Amendment and Change of Zone have been requested to allow the Wave Basin and
other tourist commercial uses on a portion of the project site because these uses are not presently
allowed on the project site. These are policy decisions for the City Council. As it relates to the
processing of the project applications, please see Responses 15-d and 17-a of this Final EIR. The
proposed General Plan Amendment and zone change are analyzed in Section 4.10, Land Use and
Planning of the Draft EIR, which concluded that the land use and zone changes proposed for the
project would result in less than significant impacts, in part because the proposed tourist commercial
uses are located in the interior of the project site, surrounded by low-density residential uses,
perimeter walls and landscaping, consistent with the surrounding communities.
Comment 97-k:
I appreciate the time you've taken to read my concerns. I hope that all parties involved in the decision
making will take the time to study the issues, be open minded and see that this development belongs
in another area.
Response 97-k:
This comment is noted.
Coral Mountain Resort Final EIR
2-445 February 2022
2.0 RESPONSES TO COMMENTS
Comment Letter No. 98: Dennis and Jackie Miller
Date: August 5, 2021
Affiliation: Area Resident
Comment 98-a:
We are 10 year homeowners at Andalusia at Coral Mountain. We enjoy the quiet environment the
southern La Quinta border provides. We are proponents of property rights but wonder if the wave
park is consistent with development of this area of La Quinta.
Alternative uses for the property are well defined in the EIR. We support alternatives (in descending
order of preference):
• Alternative #4 Golf/Resort Hotel
• Alternative #2 No project / Existing Entitlements
• Alternative #3 Reduced density
Additional areas of concern are:
Response 98-a:
The commenter's opinions and preferences concerning the project alternatives are noted. Responses
to individual issues are provided below.
Comment 98-b:
• Traffic — We are concerned event related traffic will overload the corridor resulting in gridlock.
The 4 way stop at Madison and 58th will be overwhelmed during events. The memory of
Ironman I's paralyzing of La Quinta streets is still fresh. Additional access to the property would
provide additional ingress/egress on alternatives to Madison alone.
Response 98-b:
The comment is noted. Please see Response 97-g above, which addresses the special events and the
associated traffic. As explained therein, the project is required to install a traffic signal at the
intersection of Madison Street and Avenue 58. Please also refer to Topical Response 2.2.5, Traffic,
and Response No. 52-n above.
Comment 98-c:
• Noise — The area is a quiet, serene neighborhood. We are concerned about noise from
equipment required to heat, treat the pool in addition to the wave making machinery.
Response 98-c:
Coral Mountain Resort Final EIR
2-446 February 2022
2.0 RESPONSES TO COMMENTS
The project's potential impacts relating to increased noise were thoroughly analyzed in the project -
specific noise study attached as Appendices K.1 and K.2 to the Draft EIR, which was prepared by a
professional noise engineer using established state and local methodologies to evaluate whether
project would cause any significant effects relating to construction noise, traffic noise, or project
operational noise. As explained in the Noise Study and Section 4.11 of the Draft EIR, the noise study
took into account the actual noise levels that will be generated by the proposed Wave Basin and the
equipment associated with it. With implementation of Mitigation Measures NOI-1 through NOI-6, the
project will not create any significant increases in noise. Please also see the Topical Response on
Noise in Section 2.2.4 above, and Responses 52-h, 59-e, and 62-f in this Final EIR.
Comment 98-d:
• Lighting —17 80' towers will create a "ball park" type of illumination immediately adjacent to
the beautiful mountains. We understand the desire for specific light angles but ask
consideration be given to lighting standards of 30' or less to reduce the lighting glare.
Response 98-d:
Please see Topical Responses on Light and Glare in Section 2.2.1 above, as well as Appendices B.1 and
B.2 of this Final EIR for a summary of the light and glare analysis in the EIR and the conclusion that
the project will not cause any significant light and glare impacts. Please also see Responses 51-c and
52-i in this Final EIR. The Musco Total Lighting Control (TLC) for LED technology lighting system
proposed for the Wave Basin is a state-of-the-art lighting system that effectively lights the Wave Basin
itself without creating light and glare impacts on surrounding properties. The TLC for LED system uses
optimized height, directional lighting, and full cut-off visors to minimize light overspill outside of the
Wave Basin area. As explained in Appendix B.1, at pp. 2-3, the 80 -foot height of the fixtures optimizes
the angle of the lighting and the cut-off visors, thus minimizing any light spillage outside of the area
intended to be illuminated (here the Weave Basin itself). In addition, the exhibit on page 2-7 of this
Final EIR illustrates the differences between the TLC for LED lighting and traditional stadium lighting.
Comment 98-e:
• Hours of operation — reduce end time to 8 pm.
Response 98-e:
The comment is noted. The Draft EIR analyzed the maximum hours of operation for the Wave Basin
allowed under the City's Municipal Code for a recreational facility to ensure that the worst-case
scenario for potential impacts like light, glare and noise was fully analyzed and disclosed. The
operating hours requested by the applicant will be a matter for consideration by the Planning
Commission and City Council in their review of the project. Please see Response 15-d and 17-a
regarding processing of the project.
Comment 98-f:
Coral Mountain Resort Final EIR
2-447 February 2022
2.0 RESPONSES TO COMMENTS
• Special events — 4 special events drawing attendees and traffic to La Quinta's southern edge
has the potential to create traffic gridlock.
Response 98-f:
The comment is noted. Please see Responses 52-n, 97-g and 98-b above, which address special events
and the associated traffic.
Coral Mountain Resort Final EIR
2-448 February 2022
Tuesday, June 22, 2021 at 07:39:09 Pacific Daylight Time
Subject: RE: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Date: Tuesday, June 22, 2021 at 6:30:50 AM Pacific Daylight Time
From: Rull, Paul
To: Consulting Planner
Attachments: image002.png
This project is outside of the airport influence area, and therefore ALUC has no comments at this time.
If you have any questions, please feel free to contact me.
Paul Rull
ALUC Director
Riverside County Airport Land Use Commission
4080 Leman Street_ 14" Flew
RruarsH:1$, Ca 92501
(951) 955-6893
{951) 955.5177 (tax)
PRULL iIVCO.ORG
www. rcal uc_oro
From: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Sent: Monday, June 21, 2021 4:42 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Subject: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Good Afternoon,
Attached please find the Notice of Availability of the Draft Environmental Impact Report for Coral
Mountain Resort in the City of La Quinta, California.
The Draft Environmental Impact Report (EIR) is available for a 45 -day public review period
beginning on June 22, 2021 and ending on August 6, 2021. The Draft EIR is available for
public review at City Hall, located at 78-495 Calle Tampico, La Quinta, CA 92253 and at the
City of La Quinta Public Library, located at 78-275 Calle Tampico, La Quinta, CA 92253. In
addition, the Draft EIR is available on the City's website at
http://www.laquintaca.go/thewave.
Please provide any comments in response to this notice (please note "Coral Mountain
Resort DEIR" in the subject line) in writing by August 6, 2021 to:
Page 1 of 2
Tuesday, June 22, 2021 at 13:07:03 Pacific Daylight Time
Subject: Re: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Date: Tuesday, June 22, 2021 at 12:18:48 PM Pacific Daylight Time
From: Zerda, Daniel
To: Consulting Planner
Hi Nicole,
Thank you for the transmittal. Please note that the project is not located within an Airport Influence
area, and as a result, ALUC review will not be required at this time. Please let me know if you have any
questions.
-Best Regards,
Daniel Zerda
Student Intern
Transportation and Land Management Agency
County of Riverside
(951)955-0982
From: Consulting Planner<ConsultingPlanner@laquintaca.gov>
Sent: Tuesday, June 22, 2021 10:42 AM
To: Consulting Planner<ConsultingPlanner@laquintaca.gov>
Subject: Re: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
CAUTION: This email originated externally from the Riverside County email system.
DO NOT click links or open attachments unless you recognize the sender and know the content is safe.
Good Morning,
Yesterday's email had a typographical error in the body of the email. The URL address has been
corrected below.
My apologies for any inconvenience.
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
From: Consulting Planner
Sent: Monday, June 21, 2021 4:41 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Subject: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Good Afternoon,
Attached please find the Notice of Availability of the Draft Environmental Impact Report for Coral
Mountain Resort in the City of La Quinta, California.
Page 1 of 2
Firefox https://outlook.office.com/mail/AAMkAGJiMWY1OTY1LTBhY2EtN...
RE: Coral Mountain Resort Notice of Availability - Draft Environmental Impact
Report
Hetrick, Kohl@CALFIRE <Kohl.Hetrick@fire.ca.gov>
Mon 6/28/2021 11:44 AM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Cc: Kimberly Cuza <kcuza@terranovaplanning.com>
** 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. **
Hi Nicole,
Yes, I should be routed for these reviews and will ensure that they are sent to the appropriate Fire
Strategic Planning Representative in our Riverside Office.
Which case in Trakit is being utilized for documenting this review?
Thank you,
KOHL HETRICK
Fire Safety Specialist / Office of the Fire Marshal
Cal Fire/Riverside County Fire Department
City of La Quinta
CAL FIRE/Riverside County Fire Department
Desk: 760-777-7074 I Mobile: 760-409-5109
Inspection Hotline: 760-777-7131
78495 Calle Tampico, La Quinta, CA 92253
kohl.hetrick@fire.ca.gov I www.rvcfire.org
Sch: Mon-Thurs
Leadership, Competence, Integrity, Safety, Customer Service
The Office of the County Fire Marshal is committed to facilitating fire and life safety solutions by
empowering its employees to serve our community through innovation and partnership.
From: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Sent: Wednesday, June 23, 2021 12:54 PM
To: Hetrick, Kohl@CALFIRE <Kohl.Hetrick@fire.ca.gov>
Cc: Kimberly Cuza <kcuza@terranovaplanning.com>
Subject: Fw: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Warning: this message is from an external user and should be treated with caution.
Good Afternoon Kohl,
We have Shawn Branaugh on our EIR list for Cal Fire, and he sent me the email below. Are
you reviewing EIRs for the City? If not, can you forward this to the right person?
Thanks!
Nicole
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
1 of 3 6/28/21, 1:41 PM
Firefox https://outlook.office.com/mail/AAMkAGJiMWY1OTY1LTBhY2EtN...
From: Branaugh, Shawn@CALFIRE <Shawn.Branaugh@fire.ca.gov>
Sent: Wednesday, June 23, 2021 11:18 AM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Subject: RE: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
** 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. **
Hi Nicole,
This email was sent to me by mistake, I have nothing to do with the City of La Quinta. The CAL
FIRE/Riverside County Fire Department contact person for La Quinta is Kohl Hetrick at
760-777-7074.
Shawn.
From: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Sent: Tuesday, June 22, 2021 10:43 AM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Subject: Re: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Warning: this message is from an external user and should be treated with caution.
Good Morning,
Yesterday's email had a typographical error in the body of the email. The URL address has
been corrected below.
My apologies for any inconvenience.
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
From: Consulting Planner
Sent: Monday, June 21, 2021 4:41 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Subject: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Good Afternoon,
Attached please find the Notice of Availability of the Draft Environmental Impact Report for
Coral Mountain Resort in the City of La Quinta, California.
The Draft Environmental Impact Report (EIR) is available for a 45 -day public
review period beginning on June 22, 2021 and ending on August 6, 2021. The
Draft EIR is available for public review at City Hall, located at 78-495 Calle
Tampico, La Quinta, CA 92253 and at the City of La Quinta Public Library, located
at 78-275 Calle Tampico, La Quinta, CA 92253. In addition, the Draft EIR is
available on the City's website at http://www.laquintaca.gov/thewave.
Please provide any comments in response to this notice (please note "Coral
Mountain Resort DEIR" in the subject line) in writing by August 6, 2021 to:
Nicole Sauviat Criste, Consulting Planner
City of La Quinta
2 of 3 6/28/21, 1:41 PM
Firefox https://outlook.office.com/mail/AAMkAGJiMWY1OTY1LTBhY2EtN...
78-495 Calle Tampico
La Quinta, CA 92253
or consultingplanner@laquintaca.gov
Please include your name, address, and other contact information in your
response. Further details of the proposed Project are available at
http://www.laquintaca.gov/thewave.
Kindest Regards,
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
3 of 3 6/28/21, 1:41 PM
Firefox https://outlook.office.com/mail/inbox/id/AAMkAGJiMWY1OTY1LTB...
RE: Coral Mountain Resort Notice of Availability - Draft Environmental Impact
Report
IGR — Intergovernmental Review <IGR@scag.ca.gov>
Tue 6/29/2021 2:11 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Cc: Anita Au <au@scag.ca.gov>
** 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. **
Hi Nicole,
Thank you for sending this NOA for the Coral Mountain Resort DEIR. I have a couple of follow-up
questions related to the incorporation of SCAG's comments on the NOP (starting page 66 in
Appendix A) and I'm wondering if we can chat over the phone in the coming weeks. I'm out of the
office next week, but my schedule is open this Friday, July 2nd and in the morning and afternoon on
Tuesday, July 13th. Let me know if any of these times work for you.
Thanks,
Annaleigh
Alm
goi5C
II OUTING FDR d SETTER TDYDRROW
Intergovernmental Review (IGR) Program
Annaleigh Ekman (she/her), Assistant Regional Planner
Tel: (213) 630-1427
IGR scag.ca.gov
SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
900 Wilshire Blvd., Ste. 1700, Los Angeles, CA 90017
f
From: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Sent: Tuesday, June 22, 2021 10:43 AM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Subject: Re: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Good Morning,
Yesterday's email had a typographical error in the body of the email. The URL address has
been corrected below.
My apologies for any inconvenience.
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
From: Consulting Planner
Sent: Monday, June 21, 2021 4:41 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Subject: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Good Afternoon,
Attached please find the Notice of Availability of the Draft Environmental Impact Report for
1 of 2 6/29/21, 3:00 PM
Firefox https://outlook.office.com/mail/inbox/id/AAMkAGJiMWY1OTY1LTB ...
Coral Mountain Resort in the City of La Quinta, California.
The Draft Environmental Impact Report (EIR) is available for a 45 -day public
review period beginning on June 22, 2021 and ending on August 6, 2021. The
Draft EIR is available for public review at City Hall, located at 78-495 Calle
Tampico, La Quinta, CA 92253 and at the City of La Quinta Public Library, located
at 78-275 Calle Tampico, La Quinta, CA 92253. In addition, the Draft EIR is
available on the City's website at http://www.laquintaca.gov/thewave.
Please provide any comments in response to this notice (please note "Coral
Mountain Resort DEIR" in the subject line) in writing by August 6, 2021 to:
Nicole Sauviat Criste, Consulting Planner
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
or consultingplanner@laquintaca.gov
Please include your name, address, and other contact information in your
response. Further details of the proposed Project are available at
http://www.laquintaca.gov/thewave.
Kindest Regards,
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
2 of 2 6/29/21, 3:00 PM
Wednesday, June 30, 2021 at 14:05:08 Pacific Daylight Time
Subject: Coral Mountain Resort Notice of Availability - Draft Environmental Impact Report
Date: Wednesday, June 30, 2021 at 2:00:58 PM Pacific Daylight Time
From: Hetrick, Kohl@CALFIRE <Kohl.Hetrick@fire.ca.gov>
To: Reinertson, Adria@CALFIRE <Adria.Reinertson@fire.ca.gov>, Williams, Traci@CALFIRE
<Traci.Williams@fire.ca.gov>
CC: Nicole Criste <ncriste@terranovaplanning.com>, Kimberly Cuza <kcuza@terranovaplanning.com>,
Cooley, Sonia@CALFIRE <Sonia.Cooley@fire.ca.gov>, White, Bryan@CALFIRE
<Bryan.White@fire.ca.gov>
Good Day Strategic Planning Team,
RE: La Quinta MP2019-0004
The Draft Environment Impact Report for the Coral Mountain Resort (The Wave Development, LLC) is now
available for review. The documents may be accessed at the following link: https://www.laquintaca.gov/our-
city/city-departments/design-and-development/planning-division/the-wave-at-coral-mountain
This Draft EIR is available for a 45 -day public review period beginning on June 22, 2021, and ending on August
6, 2021.
To provide comments in response to this notice (please include "Coral Mountain Resort DEIR" in the subject
line in writing, by August 6, 2021, to: Nicole Sauviat Criste, Consulting Planner, City of La Quinta, 78-495 Calle
Tampico, La Quinta, CA 92253, or consultingplanner@laquintaca.gov. Please include your name, address, and
other contact information in your response.
Please let me know if you have any questions.
Thank you,
KOHL HETRICK
Fire Safety Specialist / Office of the Fire Marshal
Cal Fire/Riverside County Fire Department
City of La Quinta
CAL FIRE/Riverside County Fire Department
Desk: 760-777-7074 1 Mobile: 760-409-5109
Inspection Hotline: 760-777-7131
78495 Calle Tampico, La Quinta, CA 92253
kohl.hetrick@fire.ca.gov 1 www.rvcfire.org
Sch: Mon-Thurs
Leadership, Competence, Integrity, Safety, Customer Service
The Office of the County Fire Marshal is committed to facilitating fire and life safety solutions by empowering
its employees to serve our community through innovation and partnership.
Page 1 of 1
JASON E. UHLEY
General Manager -Chief Engineer
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
RIVERSIDE COUNTY FLOOD CONTROL
AND WATER CONSERVATION DISTRICT
August 3, 2021
1995 MARKET STREET
RIVERSIDE, CA 92501
951.955.1200
951.788.9965 FAX
www.rcflood.org
239464
Attention: Nicole Sauviat Criste Re: Coral Mountain Resort, 2nd Submittal
The Riverside County Flood Control and Water Conservation District (District) does not normally
recommend conditions for land divisions or other land use cases in incorporated cities. The District
also does not plan check City land use cases or provide State Division of Real Estate letters or other
flood hazard reports for such cases. District comments/recommendations for such cases are normally
limited to items of specific interest to the District including District Master Drainage Plan facilities,
other regional flood control and drainage facilities which could be considered a logical component or
extension of a master plan system, and District Area Drainage Plan fees (development mitigation fees).
In addition, information of a general nature is provided.
The District's review is based on the above -referenced project transmittal, received June 23, 2021. The
District has not reviewed the proposed project in detail, and the following comments do not in any way
constitute or imply District approval or endorsement of the proposed project with respect to flood
hazard, public health and safety, or any other such issue:
▪ This project would not be impacted by District Master Drainage Plan facilities, nor are other
facilities of regional interest proposed.
❑ This project involves District proposed Master Drainage Plan facilities, namely,
The District will accept ownership of such facilities on written request of the City. Facilities
must be constructed to District standards, and District plan check and inspection will be
required for District acceptance. Plan check, inspection, and administrative fees will be
required.
❑ An encroachment permit shall be obtained for any construction related activities occurring
within District right of way or facilities, namely, . For further
information, contact the District's Encroachment Permit section at 951.955.1266.
▪ The Districts previous comments are still valid (see attached letter dated 03/09/21).
GENERAL INFORMATION
This project may require a National Pollutant Discharge Elimination System (NPDES) permit from the
State Water Resources Control Board. Clearance for grading, recordation, or other final approval
City of La Quinta - 2 - August 3, 2021
Re: Coral Mountain Resort, 2nd Submittal 239464
should not be given until the City has determined that the project has been granted a permit or is shown
to be exempt.
If this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then
the City should require the applicant to provide all studies, calculations, plans, and other information
required to meet FEMA requirements, and should further require that the applicant obtain a Conditional
Letter of Map Revision (CLOMR) prior to grading, recordation, or other final approval of the project
and a Letter of Map Revision (LOMR) prior to occupancy.
If a natural watercourse or mapped floodplain is impacted by this project, the City should require the
applicant to obtain a Section 1602 Agreement from the California Department of Fish and Wildlife and
a Clean Water Act Section 404 Permit from the U.S. Army Corps of Engineers, or written
correspondence from these agencies indicating the project is exempt from these requirements. A Clean
Water Act Section 401 Water Quality Certification may be required from the local California Regional
Water Quality Control Board prior to issuance of the Corps 404 permit.
Very truly yours,
h4f44 chi. ditAt.4$
DEBORAH DE CHAMBEAU
Engineering Project Manager
Attachment
ec: Riverside County Planning Department
Attn: Phayvanh Nanthavongdouangsy
SLJ:ju
JASON E. UHLEY
General Manager -Chief Engineer
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
RIVERSIDE COUNTY FLOOD CONTROL
AND WATER CONSERVATION DISTRICT
March 9, 2021
Attention: Nicole Sauviat Criste Re: Coral Mountain Resort
1995 MARKET STREET
RIVERSIDE, CA 92501
951.955.1200
FAX 951.788.9965
www.rcflood.org
237149
The Riverside County Flood Control and Water Conservation District (District) does not normally
recommend conditions for land divisions or other land use cases in incorporated cities. The District also
does not plan check City land use cases or provide State Division of Real Estate letters or other flood
hazard reports for such cases. District comments/recommendations for such cases are normally limited
to items of specific interest to the District including District Master Drainage Plan facilities, other
regional flood control and drainage facilities which could be considered a logical component or extension
of a master plan system, and District Area Drainage Plan fees (development mitigation fees). In addition,
information of a general nature is provided.
The District's review is based on the above -referenced project transmittal, received February 18, 2021.
The District has not reviewed the proposed project in detail, and the following comments do not in any
way constitute or imply District approval or endorsement of the proposed project with respect to flood
hazard, public health and safety, or any other such issue:
This project would not be impacted by District Master Drainage Plan facilities, nor are other
facilities of regional interest proposed.
0 This project involves District proposed Master Drainage Plan facilities, namely, , The
District will accept ownership of such facilities on written request of the City. Facilities must be
constructed to District standards, and District plan check and inspection will be required for
District acceptance. Plan check, inspection, and administrative fees will be required.
❑ An encroachment permit shall be obtained for any construction related activities occurring within
District right of way or facilities, namely, . For further information,
contact the District's Encroachment Permit section at 951.955.1266.
❑ The Districts previous comments are still valid.
City of La Quinta 2
Re: Coral Mountain Resort
March 9, 2021
237149
GENERAL INFORMATION
This project may require a National Pollutant Discharge Elimination System (NPDES) permit from the
State Water Resources Control Board. Clearance for grading, recordation, or other final approval should
not be given until the City has determined that the project has been granted a permit or is shown to be
exempt.
If this project involves a Federal Emergency Management Agency (FEMA) mapped floodplain, then the
City should require the applicant to provide all studies, calculations, plans, and other information
required to meet FEMA requirements, and should further require that the applicant obtain a Conditional
Letter of Map Revision (CLOMR) prior to grading, recordation, or other final approval of the project
and a Letter of Map Revision (LOMR) prior to occupancy.
If a natural watercourse or mapped floodplain is impacted by this project, the City should require the
applicant to obtain a Section 1602 Agreement from the California Department of Fish and Wildlife and
a Clean Water Act Section 404 Permit from the U.S. Army Corps of Engineers, or written
correspondence from these agencies indicating the project is exempt from these requirements. A Clean
Water Act Section 401 Water Quality Certification may be required from the local California Regional
Water Quality Control Board prior to issuance of the Corps 404 permit.
Very truly yours,
DEBORAH DE HAMBEAU
Engineering Project Manager
ec: Riverside County Planning Department
Attn: Phayvanh Nanthavongdouangsy
SLJ:bim
CORAL MOUNTAIN RESORT
NOTICE OF PREPARATION
1.0 INTRODUCTION
The City of La Quinta is located in the Coachella Valley, Riverside County. Exhibit 1, Regional
Location Map, shows the City's location within the larger Coachella Valley region. The project site
encompasses an area of approximately 929 acres in the southeastern portion of the City of La
Quinta. As shown in Exhibit 2, Vicinity Map, the local area is characterized as a developing area
with a number of golf course and residential communities to the north, west, east, and
southeast, the Santa Rosa Mountains to the west and south, and open space and the Coachella
Valley Water District (CVWD) percolation ponds to the south. Exhibit 3, Site Location Map,
displays an aerial view of the project site, outlining section lines, project boundary, adjacent
roadways and neighboring communities. In addition to the Santa Rosa Mountains to the west and
south, Coral Mountain is situated within the southwest portion of the project property.
The proposed project includes a General Plan Amendment, Change of Zone, Specific Plan
Amendment and new Specific Plan, as well as a Tentative Tract Map and Site Development
Permit(s) leading to the development of a mix of uses including residential, resort, commercial,
and recreational uses on 386 acres. The project proposes 496 low density residential units on
approximately 232.3 acres, a full-service resort hotel (up to 150 keys), 104 resort residential
units, and 57,000 square feet of resort commercial uses on approximately 120.8 acres, 60,000
square feet of neighborhood commercial uses on 7.7 acres, and open space recreational uses on
23.6 acres. Additionally, an artificial Wave basin is proposed on approximately 16.62 acres of the
site.
The site is currently included in a previously approved specific plan titled "Amendment IV of
Andalusia at Coral Mountain." Amendment IV's Specific Plan consists of approximately 929 acres
located south of Avenue 58, west of Monroe Street, north of Avenue 60, and both east and west
of Madison Street. Amendment IV was approved in 2017 and separated the project into two
distinct communities: Andalusia East (the area east of Madison Street) and Andalusia West (the
area west of Madison Street and the proposed project area). Andalusia East, under Amendment
IV, is currently under development, providing low density residential units, an 18 -hole golf
course, a clubhouse and associated amenities. Andalusia West, under Amendment IV, is currently
undeveloped, but proposed residential and golf course uses.
In order to achieve the land use goals of the properties east and west of Madison Street, the two
areas are to be separated and governed by two specific plans. Amendment V of SP 03-067
removes the area west of Madison Street and covers the area east of Madison Street. No changes
to the land uses, development standards or guidelines are proposed, and build out of SP 03-067
Coral Mountain Resort Specific Plan NOP 1 Febraury 2021
on the east side of Madison Street will proceed as currently planned. The approximately 386 -acre
area west of Madison Street will be governed by the Coral Mountain Resort Specific Plan, a new
Specific Plan that will address only the westerly area.
The Applicant is also requesting approval of a General Plan Amendment (GPA 2019-0002), a Zone
Change (ZC 2019-0004), a Specific Plan Amendment, a Specific Plan (SP 2019-0003), a Tentative
Tract Map (TTM 2019-0005), and a Site Development Permit (SDP). The GPA will amend the
current General Plan land use designations to reflect the land use designations required for
implementation of Specific Plan 2019-0003, and include General Commercial, Low Density
Residential, Open Space — Recreation, and Tourist Commercial. The ZC will revise the existing
zoning of the Specific Plan area to Neighborhood Commercial, Low Density Residential, Parks and
Recreation, and Tourist Commercial. The Specific Plan Amendment (SPA) will separate the west
386 acres from the existing Specific Plan (SP 03-067). The Coral Mountain Resort Specific Plan (SP
2019-0003) will be adopted as the master plan governing the allowable land uses, development
standards and design guidelines for the project. The proposed Tentative Tract Map will subdivide
the subject property into separate legal lots to facilitate development of the proposed uses, and
the proposed SDP will detail the site plan, architectural designs and landscape plans for the
artificial wave basin.
Coral Mountain Resort Specific Plan NOP 2 Febraury 2021
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MSA CONSULTING, INC
>
PLANNING CIVIL ENGINEERING LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760.320.9811 msaconsultinginc.com
REGIONAL LOCATION MAP
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
1
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Project Boundary
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MSA CONSULTING, INC.
>
PLANNING CIVIL ENGINEERING LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760.3209811 msaconsultinginc.com
VICINITY MAP
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
2
MSA CONSULTING, INC SITE LOCATION MAP
> PLANNING> CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760.320.9811 msaconsultinginc.com
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
3
1.1 Project Site Location
As shown in Exhibit 2, Vicinity Map, and Exhibit 3, Site Location Map, the approximately 386 -
acre portion of the project site to be developed under SP 2019-0003 is generally bounded by
vacant land and Avenue 58 on the north; Madison Street on the east; residential estates, vacant
land, and the Avenue 60 alignment on the south; and Coral Mountain, and vacant land to the
west. Further discussion of the land uses adjacent and in proximity to the project property is
included in the following section, Surrounding Land Uses. The project is located in portions of
Section 27 and 28, Township 6 South, Range 7 East, San Bernardino Base Line and Meridian;
and at Latitude 33° 37' 15" N, Longitude 116° 15' 21" W (approximate geographic center of the
site).
1.2 Surrounding Land Uses
Land uses surrounding the project site are as follows (see the aerial photograph in Exhibit 2):
Direction Description
North
East
South
West
• Avenue 58
• Vacant Land
• Developed and Undeveloped Single Family Residential
Communities
• Golf Course
• Madison Street
• Single Family Residences in Andalusia Country Club
• Golf Course in Andalusia
• Vacant lands
• Avenue 60
• Developed and Undeveloped Single Family Residences and
Communities
• Golf Course, including Trilogy
• Vacant Land
• CVWD Levee
• Coral Mountain
• Natural Open Space
Coral Mountain Resort Specific Plan NOP 6 Febraury 2021
2.0 Project Site History
The project property was originally included as part of the "Rancho La Quinta Specific Plan", first
approved in 1988 by Riverside County. The Specific Plan area was later annexed to the City of La
Quinta. The area south of Avenue 58 and north of Avenue 60 became known as the "Andalusia
at Coral Mountain Specific Plan 03-067" and included areas east and west of Madison Street.
Since then, the property has gone through various entitlement activities and four specific plan
amendments as part of the Andalusia at Coral Mountain Specific Plan (SP 03-067), summarized
in Table 1, below:
Table 1
Specific Plan Summary 1988-2017
Specific Plan Name
Year
Approved
Summary
Supporting Documents
Rancho La Quinta
Specific Plan 218
(County of Riverside)
1988
Original Specific Plan approved by Riverside County
Board of Supervisors; included a maximum
development of 4,262 dwelling units, 380 acres of
golf and 35 acres of commercial uses.
EIR Rancho La Quinta
SCH #1987071302
Coral Mountain
Specific Plan 218,
Amendment 1
(County of Riverside)
2000
Reduced development intensity by 762 dwelling
units and 25.8 acres of commercial uses to up to
3,500 dwelling units and 9.2 acres of commercial
uses.
TTM 2002-149 TTM
2002-12
Coral Mountain
Specific Plan
Amendment 11 (City
of La Quinta)
2003
Changed name to "Coral Mountain" Specific Plan;
split specific plan into two specific plans: Trilogy
(522 acres) and Andalusia (934 -acres); Supersedes
Coral Mountain Specific Plan 218 for Andalusia
area. Environmental Assessment 2003-483
approved
GPA 2003-093; CZ
2003-116; Specific Plan
2003-067; Site
Development Permit
2003-787; EA 2003-483
Amendment III of
Coral Mountain SP
2013
Relocated golf clubhouse and provided higher
density around golf course.
Amendment IV of
Andalusia at Coral
Mountain
2017
Revised development standards in Planning Area II
to allow for attached/detached residential villas of
up to 2 stories.
The eastern half of the previous iteration of the Specific Plan is being developed with the
Andalusia Country Club while the western half has remained vacant. Exhibit 4, Existing General
Plan Land Use Map, illustrates the project's existing General Plan land use designation. Approval
of the Coral Mountain Resort Specific Plan will establish a new master plan and development
standards for the property west of Madison Street to allow creation of a boutique resort and
master -planned community. Concurrently, Amendment V of Specific Plan 03-067 is being
processed to remove the western half such that only the Andalusia Country Club east of
Madison Street will remain. This will create two separate and distinct communities, "Coral
Mountain Resort", west of Madison Street, and "Andalusia Country Club", east of Madison
Street.
Coral Mountain Resort Specific Plan NOP 7 Febraury 2021
Legend:
Project si undary
• •
Low Density Residential
Medium/High Density Residential
General Commercial
Open Space - Natural
Open Space - Recreation
MSA CONSULTING, INC.
>
PLANNING CIVIL ENGINEERING LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
7603203811 msaconsultinginc.com
EXISTING GENERAL PLAN LAND USE
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
4
3.0 PROPOSED SPECIFIC PLAN
3.1 Project Objectives
The Coral Mountain Resort Specific Plan serves as an overall framework to conscientiously
guide development of the proposed project. To ensure the functional integrity, economic
viability, environmental sensitivity, and positive aesthetic impact of this Specific Plan,
planning and development goals for the project were established and supported through
an extensive analysis. This analysis includes an examination of project environmental
constraints, engineering feasibility, market acceptance, economic viability, City General Plan
goals, development phasing, and local community goals.
The Coral Mountain Resort Specific Plan has identified the following Project objectives:
• To implement a plan that recognizes and responds to the natural and aesthetic
character of the property.
• To create a private resort community with a variety of interrelated and mutually
supportive commercial and recreational land uses that will also generate transient
occupancy and sales tax revenues to enhance the City's economic base and long-term
financial stability.
• To promote walkability and non -motorized connectivity as an integral part of the
project design.
• To maintain the overall density count previously included for this property in the
Andalusia Specific Plan.
The following project objectives have been identified for the EIR:
• To contribute to the reduction of air emissions generated within the City.
• To contribute to the reduction of greenhouse gas emissions generated within the City.
• Provide a regulatory framework that facilitates and encourages energy and water
conservation through sustainable site planning, project design, and green
technologies and building materials.
• Assist in the protection and preservation of cultural resources.
• Contribute to the preservation, conservation and management of the City's open
space lands and scenic resources for enhanced recreation, environmental and
economic purposes.
• Provide protection of the health and safety, and welfare of the community from
flooding and hydrological hazards.
• Provide a healthful noise environment which complements the City's residential
and Resort/Spa character.
• Provide housing opportunities that meet the diverse needs of the City's existing
and projected population.
Coral Mountain Resort Specific Plan NOP 9 Febraury 2021
• Provide a circulation system that promotes and enhances alternative vehicle,
bicycle, and pedestrian systems.
• Provide domestic water, sewer and flood control infrastructure and services which
adequately serve the project development.
3.2 Project Description
As stated in Section 2.0, Project Site History, the project site is currently a part of the
"Andalusia at Coral Mountain Specific Plan 03-067", which includes the area south of Avenue
58 and east and west of Madison Street. The area east of Madison Street encompasses the
Andalusia Country Club property, and the area west of Madison Street is currently vacant.
Amendment V of Specific Plan 03-067 is being processed to remove the area west of Madison
Street from the Specific Plan area, thus, creating two separate and distinct communities,
"Coral Mountain Resort", west of Madison Street, and "Andalusia Country Club", east of
Madison Street. Approval of the Coral Mountain Resort Specific Plan will establish a new
master plan and development standards for the 386 -acre property west of Madison Street to
allow creation of a boutique resort and master -planned community.
The Coral Mountain Resort project ("project") will result in a variety of land uses, as shown in
Exhibit 5, Proposed General Plan Land Use Map. Low Density Residential land uses will occupy
approximately 232.3 acres and result in a maximum of 496 dwelling units. Tourist Commercial
land uses will result in 104 dwelling units, 150 hotel rooms, and 57,000 square feet of private
resort -serving commercial uses available to residents and hotel guests, on approximately 120.8
acres. General Commercial land uses will occupy approximately 7.7 acres with up to 60,000
square feet of retail commercial uses available to the general public. Open Space Recreation
land uses will occur on approximately 23.6 acres in the southwest portion of the site.
Table 2, Proposed Land Use Summary, shows the land use associated with each planning
area. Exhibit 7, Planning Area Land Use Plan, shows the location of each project planning
area.
Table 2
Proposed Land Use Summary
Planning Area
(PA)
Land Use
Category
Gross
Land Area
(Acres)
Non-
Residential
Building (SF)
Max.
Dwelling
Units (DU)
Max.
Hotel/Resort
Units (DU)
PA 1
GC
7.7
60,000'
PA II
LDR
232.3
496
PA 111
TC
120.8
57,000'
104
150
PA IV
OS -R
23.6
Right of Way
1.5
Total
385.9
117,000
600
150
Note: GC = General Commercia , LDR = Low Density Residential, TC = Tourist Commercial, OS -R =
Open Space Recreation
Coral Mountain Resort Specific Plan NOP 10
Febraury 2021
1. Consisting of retail commercial uses available to the general public.
2. Consisting of private resort -serving commercial uses available only to residents and hotel
guests.
In addition to the proposed onsite development, project implementation will also include the
installation of an off-site transformer bank at an existing IID substation, located at 81600
Avenue 58, as part of the proposed upgrades. Construction for the conduits and line extension
would occur in the existing right-of-way.
Project Construction
According to the Coral Mountain Specific Plan, project construction will occur in eight (8)
primary development areas with buildout anticipated to occur in three primary phases over
approximately 4- to 6 -years. Each primary development area may be broken into
subphases in response to market conditions and consumer demand. For example, the
hotel of up to 150 keys may be constructed in multiple subphases. Exhibit 6, Conceptual
Development Plan, reflects the anticipated construction sequence and may be non -sequential
and adjusted subject to market conditions (so long as necessary utilities and access are
provided). Phased development will be accompanied by the orderly extension of circulation
and parking facilities, public utilities, and infrastructure in accordance with the final conditions
of approval for the project. Phasing is conceptual and subject to refinement with final
engineering design and changes in sequence in response to market conditions.
The applicant proposes to commence construction of the Wave Basin first due to the longer
construction timelines associated with this component of the project, compared to the other
uses within the Specific Plan. Accordingly, a Site Development Permit (SDP) for the Wave Basin
is being processed concurrently with the initial entitlements, with one or more SDPs for other
Planning Areas within the Tourist Commercial and Low Density Residential land use
development areas (designated as Phase 2 on Exhibit 6) being filed prior to final approval of
the Wave Basin SDP. The Wave Basin SDP map is illustrated in Exhibit 7, Wave Basin SDP Map.
Following this entitlement and construction schedule, it is anticipated that the Wave Basin and
other Tourist Commercial and Residential land uses will be completed and ready for occupancy
at approximately the same time.
Project Components
The project components shall include:
• 600 Dwelling Units of varying types
o 496 single family attached and detached dwellings and affiliated amenities (Low
Density Residential land use)
o Low Density Residential product types may include estate compounds, single-family
Coral Mountain Resort Specific Plan NOP 11 Febraury 2021
detached/attached units, alley loaded homes, and clustered products
o 104 resort residential units (Tourist Commercial land use)
o Resort residential product types may include single family detached units,
townhomes, and stacked flats
• 60,000 square feet of publicly accessible neighborhood commercial building space
• 150 -key resort with customary resort amenities
o The Resort Hotel will provide a hospitality component, with amenities such as a
restaurant and bar, retail shop, meeting space, swimming pool, fitness center, spa
and lodging.
o Lodging options will provide a range of traditional hotel rooms, suites, and casitas.
• 57,000 square feet of resort -serving commercial and recreational building space
o Residents and guests of the property will have exclusive use of resort commercial.
• The Wave Basin
o 16.62 -acre artificial surf Wave basin
o Residents and guests of the property will have exclusive use of Wave basin
• 26.5 acres south of the Wave basin
o Providing permanent service and administrative facilities and unprogrammed
gathering and staging space for temporary equipment such as portable toilets, shade
structures, tenting for inclement weather, and catering equipment.
• Approximately 24 acres of natural open space for low -impact active and passive
recreation activities.
o Including hiking, biking, and ropes courses.
• Special events
o The project applicant anticipates the potential occurrence of special events involving
attendance of up to 2,500 guests per day for up to 4 days (up to 4 events per year).
Coral Mountain Resort Specific Plan NOP 12 Febraury 2021
Legend:
Project Boundary
General Commercial
Low Density Residential
Tourist Commercial
Open Space (Recreation)
AVENUE 58
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COMMERCIAL
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RESIDENTIAL
OPEN S
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N.T.S.
MSA CONSULTING, INC.
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
7603209811 msaconsultinginc.com
PROPOSED GENERAL PLAN LAND USE
Et
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
5
Legend:
Project Boundary
- -
Phase Boundary
– — — — –
Development Area Boundary
Phase 1
Phase 2
Phase 3
Notes: 1. Phasing plan reflects the anticipated construction
sequence. It is conceptual and subject to refinement
in response to market conditions.
2. Numbers 1 - 8 indicate Development Areas.
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N.T.S.
MSA CONSULTING, INC. / '[ CONCEPTUAL DEVELOPMENT PLAN
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760320.9811 msaconsultinginc.com
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
6
AVENUE 58
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NOTE: ADDITIONAL CONSTRUCTION ACCESS MAY BE ADDED IN A LOCATION SUBJECT TO CITY APPROVAL.
/
/
MSA CONSULTING, INC.
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760.320.9811 msaconsultinginc.com
WAVE BASIN SDP
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
7
3.3 Planning Areas
The project proposes the development of four planning areas, defined in this section. Table 3,
below, indicates each planning area, and their proposed acreages, and dwelling units. Exhibit 8,
Planning Area Land Use Plan, illustrates the proposed planning area locations
Table 3
Proposed Planning Area Summary
PA
Land Use (Zone)'
Acres
Commercial (SF)
Max. Units
I
Neighborhood Commercial (CN)
7.7
60,000 SF
11
Low Density Residential (RL)
232.3
496 Units
III
Resort (TC)
III -A: Resort Hotel
8.5
150 rooms
III -B: The Wave
31.2'
III -C: Wave Club
3.2
III -D: Resort Residential West
40.5
104 units
III -E: Resort Residential East
III -F: The Farm
11
III -G: Back of House
26.5
PA III Total acreage
120.8
57,000 SF
IV
Open Space Recreational (PR)
23.6
Roads
1.6
Total
386
60,000 CN
57,000 TC
600 DU
150 rooms
1. Zone Codes: Neighborhood Commercial = CN; Low Density Residential = RL; Tourist Commercial = TC;
Parks and Recreation = PR
2. The Wave Subarea is 31.2 acres and contains a 16.62 -acre artificial surf wave basin.
Coral Mountain Resort Specific Plan NOP 16 Febraury 2021
Legend:
Project Boundary
Planning Area Boundary
- — — — -
Planning Area Sub -Boundary
Neighborhood Commercial
Low Density Residential
Resort
Open Space (Recreation)
■ ■
MI . - .. _ ■ ■ - . ■
AVENUE 58
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LOW DENSITY
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EXHIBIT
MSA CONSULTING, INC. / '[ PLANNING AREA LAND USE PLAN
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760.320.9811 msaconsultinginc.com
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
8
3.5 Circulation Plan
The circulation plan for the project proposes a multi -modal approach providing transportation
facilities within the Specific Plan area for a variety of user groups including motorists, cyclists,
pedestrians, and drivers of electric vehicles, thereby decreasing automobile dependency.
Convenient access and parking are planned in close proximity to retail and resort areas. The
internal system of private local roadways will allow residents of individual neighborhoods to
access all Planning Areas internally without exiting onto surrounding public streets. The project's
multi -modal transportation system will consist of sidewalks, multi -use trails, and shared use of
low -speed, low-volume roadways, specifically including: off-street bicycle and pedestrian
paths/routes; sidewalks in higher traffic areas; pedestrian/bicycle crosswalks; pedestrian and
multi -use paths and streets; traffic calming methods; short street segments with frequent
caution zones and stopping points; and golf cart routes and other alternative forms of personal
transportation.
Vehicular Circulation
Vehicular access to the project site will utilize existing public arterial roads, including Avenue 58,
and Madison Street. These roads are largely improved to their ultimate lane width, needing only
the addition of minor widening, a meandering multi-purpose trail, sidewalks, and parkway
landscaping along the boundary of the Specific Plan area. The surrounding roadways will be
improved to the standards of the City of La Quinta General Plan Circulation Element. The internal
circulation system will consist of a series of roads providing access to the individual residential
and recreational components within the Specific Plan area. The proposed internal rights of way
will vary from 32-foot/33-foot private drives to the 100 -foot entry drive.
As shown in Exhibit 9, Circulation Plan, the interior street system proposed for the project is an
internal system of private streets linking all neighborhoods to provide open circulation. Per
Exhibit 9, the project proposes various road categories and rights-of-way. These include the Entry
Drive, Local Road "A", Resort Drive, and Resort Commercial Drive. The Entry Drive is the main
entry off of Madison Street that provides access to the resort area. Local Roads branch off of the
primary entry drives and link residential and resort residential areas to the Entry Drive. Resort
Drives are open to the guests and residences of the community to convey vehicles, pedestrians,
and bicycles throughout the project. A secondary entrance is provided from Avenue 60.
The project site is bordered on the north and east sides by public streets designated as Secondary
Arterials in the City of La Quinta General Plan. The segment of Avenue 60 located south of the
project site is designated as a Collector Road.
The project provides access to the Neighborhood Commercial in Planning Area 1 with a primary
public entry from Madison Street, two public entries from Avenue 58 and one from the Entry
Coral Mountain Resort Specific Plan NOP 18 Febraury 2021
Drive. Entries to residential neighborhoods will be provided from the primary entry drive and
their conceptual locations illustrated in Exhibit 9.
Non -Vehicular Circulation
Non -vehicular circulation proposed for the project is intended to include multi -use trails,
sidewalks, walk streets, and a boardwalk feature. The features are described as follows:
- Multi -Use Trail: An 8 -foot -wide multi -use trail along the main spine road to provide
future neighborhoods with a central bike and pedestrian connection to the resort core
as well as the main entry gate.
- Sidewalk: Sidewalks are included along key streets in the resort core to provide a
completely interconnected pedestrian grid experience so that resort guests can walk or
bike to all activities at the wave basin and resort facilities.
- Walk Streets: Designed as narrow walkways between homes, Walk Streets provide
connectivity with immediate residential frontage. The Walk Street network is one of the
primary organizing components of the community plan. Terminating at the boardwalk,
Walk Streets link residents to The Wave, The Farm, and the greater network of trails
and open spaces, enabling movement throughout the community.
- The Boardwalk: The Wave basin and its integrated pedestrian boardwalk is the
terminus for nearly all the Walk Streets — functioning as a gathering space as well as an
active recreational amenity.
Exhibit 10, Non -Vehicular Circulation Plan, illustrates the proposed locations for the multi -use
trail, connecting boardwalk feature, sidewalks, and walk streets.
Coral Mountain Resort Specific Plan NOP 19 Febraury 2021
Legend:
Project Boundary
OConceptual
Residential Entry Point
3
Conceptual Residential Gated Entry Point
24' Right of Way: Entry Drive
24' Right of Way: Local Road "A"
24' Right of Way: Resort Drive
26' Right of Way: Resort / Commercial Drive
32' Right of Way: Resort / Commercial Drive
40' Right of Way: Entry Drive
40' Right of Way: Resort Drive
60' Right of Way: Resort Drive
..
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AVENUE 58
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Notes:
1. Conceptual residential entry points ■
reflect anticipated locations only.
Entry locations are conceptual and
subject to refinement as the project
is built out. ■
2. Local Road Sections "B" and "C" ■
(not shown) may be used in future
development areas.
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N.T.S.
MSA CONSULTING, INC.
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760320.9811 msaconsultinginc.com
VEHICULAR CIRCULATION PLAN
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
9
Legend:
•
Project Boundary
•
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Multi -Use Trail
Connecting Boardwalk Feature
Sidewalk
Walk Street
A VENUE
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AVENUE 60
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N.T.S.
MSA CONSULTING, INC.
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760320.9811 msaconsultinginc.com
NON -VEHICULAR CIRCULATION PLAN
0
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
10
3.6 Infrastructure Plan
The infrastructure system planned to serve the project described below will be designed to
provide a coordinated system of infrastructure and public services to adequately serve the
project area at full buildout. The project will be served by the following utilities:
- Water and Sewer: Coachella Valley Water District (CVWD)
- Electricity: Imperial Irrigation District (IID)
- Gas: Southern California Gas Company
Water and Sewer
Water and sewer service for the Specific Plan area are provided by the Coachella Valley Water
District (CVWD). The CVWD provides domestic water from wells. Non -potable water sources
are intended to be used for the irrigation of common landscape areas. The project proposes to
connect to the existing water lines located on Avenue 58 (north) and Madison Street (east). The
proposed water lines will consist of 18 -inch, 12 -inch, and 8 -inch public water lines. Sewer lines
in the area currently exist along Avenue 58 and along a portion of Avenue 60 (southeast of the
project). The project proposes 15 -inch, 12 -inch and 8 -in sewer lines that will connect to the
existing sewer lines and provide sewer service to the project. The project will conform to the
requirements of the CVWD's programs and requirements pertaining to water management and
conservation. See Exhibit 11 for the Conceptual Water Plan and Exhibit 12 for the Conceptual
Sewer Plan.
Coral Mountain Resort Specific Plan NOP 22 Febraury 2021
Legend:
Project Boundary
•
■w— —
Existing Water Main
OProposed
C.V.W.D. Well Site
Proposed Public 8" Water Main
Proposed Public 12" Water Main
�12W-
Proposed Public 18" Water Main
�18W-
Notes: 1. Information shown is conceptual only.
Final engineering design plans may deviate.
2. Number and location of wells is preliminary &
subject to further discussion with C.V.W.D.
EXHIBIT
MSA CONSULTING, INC./ j�� CONCEPTUAL WATER PLAN
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760320.9811 msaconsultinginc.com
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
11
Legend:
Project Boundary
•
Existing Sewer Main
— s —
Proposed 8" Sewer Main
Proposed 12" Sewer Main
�12S—
Proposed 15" Sewer Main
�15S—
Note: Information shown is conceptual only.
Final engineering design plans may deviate.
AVENUE 5 8rL___ —ems
AVENUE 60 s— _s J
MSA CONSULTING, INC./ j�� CONCEPTUAL SEWER PLAN
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760.320.9811 msaconsultinginc.com
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
12
Grading and Drainage
As shown in Exhibit 13, Conceptual Drainage Plan, the project includes a comprehensive
drainage system that collects storm flows, retains the incremental post -development increase
and discharges surface water at pre -development levels to protect individual residences, the
resort, and commercial uses as well as downstream properties. Surface drainage will be
conveyed by the local street system from development areas to a system of basins and
underground storm drains. As illustrated in the conceptual drainage plan, multiple retention
basins and lakes (including the Wave), will be used to convey and safely capture surface flows.
Retention basins will be constructed and sized to retain the worst-case flood volume from a
100- year storm event. These basins will also include water quality elements that serve as
structural Best Management Practices (BMPs) in accordance with the Municipal Separate Storm
Sewer System (MS -4) Whitewater River Watershed Municipal Stormwater Program.
Off -Site Electrical Improvements
Electric utilities for the site are provided by the Imperial Irrigation District (IID). The project EIR
will analyze the improvements in further detail. Exhibit 14, Off -Site Electrical Improvements,
illustrates the location of the existing substation and proposed distribution line(s) and
upgrades.
Other Utilities
The site is within the Southern California Gas Company's service area for natural gas, and Frontier
and Charter Communications for telecommunications. The project will tie into the existing cable,
gas and telecommunications lines located along Avenue 58 and Madison Street. The project will
not require or result in the relocation or construction of new natural gas, or telecommunication
facilities.
Coral Mountain Resort Specific Plan NOP 25 Febraury 2021
Legend:
Project Boundary
- -
1
Water Feature / Retention
Conceptual Drainage Sub -Area
•
Conceptual 100 -Year Sub -Area Retention
■
Site Drainage Flows
Off -Site Drainage Direction
—>
Note: Drainage and retention is conceptual and subject
to refinement with final engineering design.
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AVENUE 60
MSA CONSULTING, INC. / '[ CONCEPTUAL DRAINAGE PLAN
> PLANNING > CIVIL ENGINEERING > LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760320.9811 msaconsultinginc.com
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
13
Legend:
Project Boundary
Proposed Conduit System
Proposed Transformer Bank
AVENUE 58
PROJECT SITE
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EXISTING I.I.D. SUBSTATION —•
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AVENUE 60
MSA CONSULTING, INC
>
PLANNING CIVIL ENGINEERING LAND SURVEYING
34200 Bob Hope Drive, Rancho Mirage, CA 92270
760320.9811 msaconsultinginc.com
OFF-SITE ELECTRICAL IMPROVEMENTS
0
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
EXHIBIT
14
3.7 Project Implementation
Implementation of the proposed project includes the approval of the following entitlement
processes:
General Plan Amendment (GPA) - The GPA will amend the current General Plan land use
designations from General Commercial, Low Density Residential, Open Space — Recreation, to
Neighborhood Commercial, Low Density Residential, Resort, and Open Space - Recreation. The
GPA requires public hearings before the Commission and the Council.
Zone Change (ZC) - The ZC will revise the existing zoning of the Specific Plan Area from
Neighborhood Commercial, Low Density Residential, and Golf Course, to Neighborhood
Commercial (CN), Low Density Residential (RL), Parks and Recreation (PR), and Tourist
Commercial (TC). The ZC requires public hearings before the Commission and Council.
Specific Plan (SP) — The Coral Mountain Resort Specific Plan will be adopted as the master plan
governing the allowable land uses, development standards and design guidelines for the project.
The SP requires public hearings before the Planning Commission (Commission) and the City
Council (Council).
Tentative Tract Map (TTM) — TTMs are intended to implement the project and subdivide the
property into smaller lots for development. The TTM which is currently under consideration will
implement the Specific Plan and subdivide all of PA III, the Wave resort, and the western corner
of PA II into lots suitable for the development of the uses permitted for these areas in the
Specific Plan. Future TTMs may be filed with each phase of development as necessary to
implement the balance of the project. Each TTM will require review by the Planning Commission.
Site Development Permit (SDP): SDPs are required by the City for final approval of landscape
design, architectural design, and site plans. An SDP for the Wave Basin is being sought in
connection with the current entitlements, and will establish the location, architectural design
and landscape plan for the Wave Basin along with associated mechanical equipment and
improvements (Planning Area III -B).
Future entitlements for project -specific components will also include:
Site Development Permit (SDP): Additional SDPs will be required by the City for final approval of
landscape design, architectural design, and site plans for each phase of development. These may
be processed concurrent with or subsequent to other entitlement approvals. Each SDP will
require public hearings before the Commission.
Conditional Use Permit (CUP): Allowable uses that require a CUP shall be processed in
accordance with Section 9.210.020 of the La Quinta Municipal Code.
Temporary Use Permit (TUP): TUPs are required by the City to accommodate special, unique, or
limited duration activities that might otherwise be outside the provisions of normal zoning.
Coral Mountain Resort Specific Plan NOP 28 Febraury 2021
Temporary uses are anticipated and allowed by the Specific Plan. TUPs are reviewed
administratively by the Design and Development Director and do not require a public hearing.
Coral Mountain Resort Specific Plan NOP 29 Febraury 2021
4.0 Environmental Impact Report (EIR)
As stated in the section, 3.6, Project Implementation, the Applicant is requesting approval of a
General Plan Amendment to change the Land Use Map for the project area to General
Commercial, Low Density Residential, Tourist Commercial, and Open Space Recreation; a Zone
Change to revise the City's Zoning Map to Neighborhood Commercial, Low Density Residential,
Parks and Recreation, and Tourist Commercial; a Specific Plan (SP); a Tentative Tract Map
(TTM); and a Site Development Permit (SDP) for the Wave basin..
4.1 Need for an EIR
The City of La Quinta, as Lead Agency under CEQA, has determined that the project has the
potential to significantly impact the environment, and has determined that an EIR shall be
prepared. The EIR will be prepared in conformance with CEQA (California Public Resources
Code, Section 21000, et seq.), and the CEQA Guidelines (California Code of Regulations, Title
14, Section 15000, et seq.).
The EIR will evaluate the environmental effects of the project in accordance with the latest
regulatory requirements, determine whether significant impacts will occur, identify feasible
mitigation measures to minimize or avoid any potentially significant environmental effects of the
proposed project, and evaluate a reasonable range of alternatives to the proposed project.
4.2 Summary of Environmental Issues
The EIR will evaluate all environmental issues set forth in the CEQA Environmental Checklist
(per Appendix G of the CEQA Guidelines) where the project could potentially have any
significant effects. The issue areas that will be evaluated in the Draft EIR include:
• Aesthetics • Geology and Soils • Noise
• Air Quality • Greenhouse Gases • Public Services
• Biological Resources • Hazards/Hazardous Materials • Transportation
• Cultural Resources • Hydrology and Water Quality • Tribal Cultural Resources
• Energy Resources • Land Use and Planning • Utilities
The environmental topics that are not anticipated to result in any impacts include Agricultural
Resources, Mineral Resources, Population and Housing, Recreation, and Wildfire (discussed in
subsections 4.2.2, 4.2.11, 4.2.13, 4.2.15, and 4.2.18, respectively). Therefore, these sections
will not be further discussed in the Draft EIR.
Coral Mountain Resort Specific Plan NOP 30 Febraury 2021
4.2.1 Aesthetics
The City of La Quinta is located along the base of the Santa Rosa Mountains that form
the backdrop to the City's western boundary and the project site. The Santa Rosa
Mountains and their foothills and peaks are part of the Santa Rosa and San Jacinto
Mountains National Monument and contribute to the natural scenic vista. Coral Mountain
occurs, in part, on the project site. The project will involve the construction of a mixed-use
community consisting of residential units, general commercial uses, tourist commercial uses,
a resort, open space recreational uses, as well as an artificial surf Wave basin. The proposed
uses and structures would have a potential effect on aesthetic resources. Analysis of the
impacts of existing aesthetic resources from adjacent viewpoints will be evaluated in the EIR.
The proposed project's impact on existing scenic vistas as well as the scenic quality in the area will be
evaluated in the EIR. This evaluation will analyze the proposed features, such as the Wave basin, associated
structure heights, building character, mass and heights, and project landscaping. The proposed project
will be required to comply with the lighting and landscape requirements City of La Quinta
Municipal Code. On-site native environments have been modified by prior agricultural
operations and clearing activities that occurred over multiple decades. Historic structures
occur on the project site, as does the significant rock outcropping that is Coral Mountain.
Therefore, the project's impact to scenic resources, including but not limited to, trees, rock
outcroppings, and historic buildings within a state scenic highway will also be analyzed in the
EIR. Development adjacent to the City of La Quinta General Planned Image Corridors located
on Avenue 60, Madison Street, and Avenue 58 shall be restricted to a height limitation of 22
feet from pad grade within 150 feet from the right-of-way. Rear and side yard setbacks for lots
adjacent to Image Corridors shall be expanded to a minimum of 25 feet per La Quinta
Municipal Zoning Code Section 9.50.020. The project will introduce light and glare associated
with commercial, residential and resort development to a site that is currently vacant and
does not emit any light or glare. The project proposes a recreational Wave basin, including
80 -foot light poles, to illuminate the Wave basin in the evenings. Therefore, potential light
and glare impacts to daytime and nighttime views in the area as a result of project
development will be analyzed in the EIR. The EIR will evaluate CEQA Guideline Thresholds "a"
through "d" and mitigation measures will be developed, if necessary, and analyzed to
determine whether impacts can feasibly be reduced to less than significant levels.
4.2.2 Agricultural Resources and Forestry
Per the most recent (2016) California Farmland Mapping and Monitoring Program, the project
site is located in an area designated as Farmland of Local Importance, but will not convert any
Prime Farmland, Unique Farmland or Farmland of Statewide Importance to non-agricultural use.
According to the United States Geological Survey (USGS) 1959 topographic map, Palm Desert
Coral Mountain Resort Specific Plan NOP 31 Febraury 2021
Quadrangle (15 -minute series), the project property previously operated as agricultural land,
likely vineyards. Historical aerial imagery dating back from 1996 indicates that the site had been
cleared of all agricultural remnants prior to 1996. The project site currently lies within a
suburban area of La Quinta, with residential uses to the north, east and south.
Additionally, the project area currently is designated Low Density Residential, Open Space
Recreational and General Commercial by the City of La Quinta, and has been so designated since
1993 when the property was annexed to the City. The project site is not currently designated
within an agriculture land use category and the site has not been in agricultural use for over 25
years. Overall, the project will not convert Prime Farmland, Unique Farmland or Farmland of
Statewide Importance to non-agricultural use. The project site is not in use as Farmland of Local
Importance and is not planned for such use in the General Plan.
The project property is not located in an area under the Williamson Act contract, and there are
no lands within the Williamson Act contract in the immediate project vicinity. No forest land,
timberland, or timberland zoned for timberland production occurs on the project site or in the
surrounding area because forest vegetation is not characteristic of the Coachella Valley desert
environment. Based on the foregoing, the project will not result in any impacts to agricultural
and forestry resources, and the EIR will provide no further analysis of this topic.
4.2.3 Air Quality and Greenhouse Gas Emissions
The project site is located within the Riverside County portion of the Salton Sea Air Basin
(SSAB), under the jurisdiction of the South Coast Air Quality Management District (SCAQMD).
Existing air quality in relation to the applicable air quality standards for criteria air pollutants is
measured at established air quality monitoring stations throughout the SCAQMD jurisdiction.
The three permanent ambient air quality monitoring stations in the Coachella Valley are in
Palm Springs (AQS ID 060655001), Indio (AQS ID 060652002), and Mecca (Saul Martinez - AQS
ID 060652005). The project site is located approximately 18 miles southeast of the Palm
Springs station, 6 miles southwest of the Indio station, and approximately 11 miles northwest
of the Mecca (Saul Martinez) station.
The project has the potential to generate criteria emissions and greenhouse gas emissions in
excess of SCAQMD standards. The EIR analysis will include a stand-alone air quality study
to evaluate whether construction and operation of the proposed development will comply
with the applicable SCAQMD air quality standards. The EIR analysis will also include a greenhouse
gas (GHG) study to evaluate project -related construction and operational emissions and
determine the level of GHG impacts as a result of constructing and operating the proposed
project. The EIR will provide an in-depth evaluation of CEQA Thresholds "a" through "d"
regarding project impacts to air quality; and CEQA Thresholds "a" and "b" regarding project -
Coral Mountain Resort Specific Plan NOP 32 Febraury 2021
generated greenhouse gas emissions. In addition, mitigation measures will be developed, if
necessary, and analyzed to determine whether impacts can feasibly be reduced to less than
significant levels.
4.2.4 Biological Resources
The Coral Mountain Resort property is located on relatively flat land within elevations ranging
from approximately 72 feet below mean sea level to 65 feet above mean sea level. Vegetation
within the study area is best described as Desert Saltbush scrub, Tamarisk scrub, and Mesquite
Hummock. Land is disturbed in the southern and northeast portions of the study area and a
stand of blue palo verde is present in the eastern portion of the study area. Dominant species
include fourwind saltbush, bush seepweed, athel, and common Mediterranean grass (Schismus
barbatus). The majority of the project area was previously agricultural land. As a result, the
Desert Saltbush scrub is fairly disturbed throughout the project area. Common wildlife species
expected on the project site include common raven, mourning dove, and greater roadrunner.
A biological survey and records search is required to determine whether any sensitive or special
status animal species are located within the boundary of the project site. The findings of the
project -specific biological survey and records search will be fully addressed in the EIR. The project
is not anticipated to have a substantial adverse effect on any riparian habitat or other sensitive
natural communities, since there are no jurisdictional waters and no lakes, rivers, or streambeds
onsite. Additionally, the project property does not contain, nor is adjacent to, federally protected
wetlands, marshes, or other drainage features. No blue -line stream corridors (streams or dry
washes) occur in the project area, and the project would not impact federally protected
wetlands.
The project's consistency with adopted habitat policies and plans will be analyzed in the EIR,
including the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP).
In short, the project EIR will evaluate the findings of the project -specific biological survey and
records search, and mitigation measures will be developed, if necessary, and analyzed to
determine whether impacts can feasibly be reduced to less than significant levels.
4.2.5 Cultural Resources and Tribal Cultural Resources
The EIR will include a project -specific Historical/Archaeological Resource Survey Report. The
project area is located on the southcentral outskirts of the City and is adjacent to the eastern
foothills of the Santa Rosa Mountains, and includes a portion of a rocky knoll known as Coral
Mountain. The ground surface in much of the project area has been disturbed to various
Coral Mountain Resort Specific Plan NOP 33 Febraury 2021
degrees, except for the portion in and around Coral Mountain. The northeast portion of the
site does not appear to have been farmed but it has been cleared of vegetation.
The analysis in the EIR will include a review of the project -specific cultural evaluation, an
assessment of the potential impacts to cultural and tribal cultural resources associated with
project construction, and the results of AB 52 consultation with Native American Tribes.
Therefore, CEQA Guideline Thresholds "a", "b", and "c", regarding cultural resources, and Thresholds
"a) i" and "a) ii", regarding Tribal Cultural Resources will be included in the EIR, and mitigation measures
will be developed, if necessary, and analyzed to determine whether impacts can feasibly be
reduced to less than significant levels.
4.2.6 Energy Resources
The project will consist of residential, commercial, open space/recreational and resort uses.
Low density residential uses will occupy approximately 232.3 acres of the site, commercial
uses will occupy 7.7 acres, resort uses will occupy 120.8 acres, and the open
space/recreational uses will occupy 23.6 acres of the project site. The project site, located at
the southwest corner of Avenue 58 and Madison Street, lies within the service area
boundaries of Imperial Irrigation District (IID) for electricity and Southern California Gas
Company for natural gas. As a part of project implementation, the project will be required to
install an off-site transformer bank at an existing IID substation located at 81600 Avenue 58 as
part of proposed upgrades. Construction for the conduits and line extension would occur in
the existing right-of-way.
The Coral Mountain Resort EIR will analyze project -related impacts to energy resources during
construction activities and operation. The impacts of the offsite improvements will also be
analyzed in the EIR. The EIR will evaluate CEQA Guideline Thresholds "a" and "b" to
determine the project's potential energy impacts, and mitigation measures will be
developed, if necessary, and analyzed to determine whether impacts can feasibly be reduced
to less than significant levels.
4.2.7 Geology and Soils
A site-specific Geotechnical Investigation is required for the project property, to investigate
the geotechnical and soil conditions at the site.
The project site is not located within an Alquist-Priolo fault zone. However, seismic activity
that may occur on either the San Andreas fault zone (approximately 7.75 miles
northeast of the project site), or San Jacinto fault zone (approximately 14 miles southwest
of the project site) could result in severe ground shaking. The California Building Code
Coral Mountain Resort Specific Plan NOP 34 Febraury 2021
contains specific requirements and standards to ensure safe building design. The EIR will
evaluate the impacts of seismic hazards and geologic hazards at the project site. Therefore,
CEQA Thresholds "a" through "d" will be analyzed in the EIR. Mitigation will be provided in the
EIR, if necessary.
The project is currently located within the Coachella Valley Water District's (CVWD) service area
for water and sewer services. The project proposes to connect with the existing sewer
infrastructure to provide sewer to the residents and guests of the proposed project. The project
site will not use septic systems. Additionally, CVWD has sufficient capacity to treat effluent
generated by the project. Further discussion regarding project -related sewer and wastewater
use will be provided in the Utilities and Service Systems section of the EIR. Since the project will
not use septic systems , CEQA Threshold "e" will not be analyzed in the EIR.
In addition to the project -specific Geotechnical Investigation, a project specific Paleontological
Resources Assessment will be included in the EIR to identify any significant, non-renewable
paleontological resources that may exist within or adjacent to the project site. The findings of
the Paleontological Resources Assessment will be analyzed in the CEQA Threshold "f" discussion
of the EIR. Mitigation measures will be provided, if necessary, and analyzed to determine
whether impacts can feasibly be reduced to less than significant levels.
4.2.8 Hazards and Hazardous Materials
Implementation of the project would facilitate new growth and development throughout
the project area. Resort, commercial, residential, and recreational developments would result
in an increased population of residents and non-residents that would have both the potential
to be susceptible to hazards, and to utilize hazardous materials.
The project site is located within the boundary of the Coachella Valley Unified School District.
The closest school is the Westside Elementary School, located approximately 1.30 miles
northeast of the project site at 82225 Airport Boulevard in Thermal. The project site is not
located within one-quarter mile of an existing or proposed school; therefore, CEQA Threshold
"c" will not be analyzed in the EIR.
The project is not located on a site which is included on a list of hazardous materials sites,
pursuant to Government Code Section 65962.5, and therefore, CEQA Threshold "d" will not be
analyzed in the EIR.
Moreover, the closest airport to the proposed project is the Jacqueline Cochran Regional
Airport, located at 56-850 Higgins Drive in Thermal, California. The project is located
approximately 4.25 miles west of the Airport, and outside of the Airport's Land Use
Compatibility Zone. Therefore, CEQA Threshold "e" will not be analyzed in the EIR.
Coral Mountain Resort Specific Plan NOP 35 Febraury 2021
Although the project will not result in impacts to CEQA Thresholds "c", "d", and "e", the EIR will
analyze project -related impacts to the transport, use, or disposal of hazardous materials; the
release of hazardous materials into the environment; the implementation of an emergency
response or evacuation plan; and wildfire impacts (CEQA Thresholds "a", "b", "f", and "g".
These topics will be discussed in detail, and mitigation measures will be developed, if necessary,
and analyzed to determine whether impacts can feasibly be reduced to less than significant
levels.
4.2.9 Hydrology and Water Quality
The project site is defined by a relatively level terrain with scattered vegetation coverage. This
setting occurs on the east side of Coral Mountain and two engineered flood control dikes (No.
2 and No. 4). The dikes form part of the regional flood control system and the planned Eastern
Coachella Valley Stormwater Master Plan Project (Master Plan). The on-site conditions have
been modified by prior agricultural operations and clearing activities that occurred over
multiple decades. The site has also been altered by dirt roads, hiking paths, and various
underground irrigation lines. Current on-site drainage is controlled via sheet flow generally
trending from west to east. In addition to the on-site drainage conditions, vacant land and
Coral Mountain west of the project are tributary to the project area. The off-site hillside
portion of Coral Mountain primarily consists of rock outcrop, while the vacant land is relatively
flat with conditions similar to those that occur on-site.
The project site is covered by three Federal Emergency Management Agency (FEMA) Flood
Insurance Rate Map (FIRM) Panels: 06065C2244H and 06065C2900H effective April 19, 2017,
and 06065C2925H, effective March 6, 2018. Based on these sources, the project area is
designated Zone X, an "area with reduced flood risk due to levee". The levee system being
referenced includes Dike No. 2 and Dike No. 4 located west and upgradient of the project site.
A project specific hydrology study will be prepared to analyze project on-site facilities and off-
site tributary flows.
The EIR analysis will consider how the flood protection solutions will be incorporated into the
site design, storm drain infrastructure, and water quality management practices in relation to
the applicable regulatory standards that apply during construction and operation of the
proposed development.
The EIR will analyze the project's site design measures to prevent interference with existing
groundwater recharge facilities located south of the project. A Water Supply Assessment
and Water Supply Verification has been completed and was adopted by CVWD in March
2020. This report analyzes the project demand for water and the supply availability for the
project area. Its findings will be described in the EIR.
Coral Mountain Resort Specific Plan NOP 36 Febraury 2021
The introduction of impervious land cover (i.e., roadways, hardscape, buildings) resulting
from project implementation would result in an increase in the rate and amount of
surface runoff produced by a site. The EIR will analyze the surface runoff generated by project
implementation, and the proposed onsite stormwater retention system.
The Coral Mountain Resort EIR will evaluate CEQA Guideline Thresholds "a" through "e" in
order to determine project -related impacts to hydrology and water quality and mitigation
measures will be developed, if necessary, and analyzed to determine whether impacts can
feasibly be reduced to less than significant levels.
4.2.10 Land Use Planning
The project site, located at the southwest corner of Avenue 58 and Madison Street, is
surrounded by developed residential communities to the north, east, and south, vacant land to
the north, west and south, and Coral Mountain to the southwest. The surrounding
developments are gated and operate separately from each other. The proposed project occurs
on vacant land, and will not impact operation of surrounding residential projects, currently or in
the future, and development of the proposed project will not divide an established community.
Therefore, CEQA Threshold "a" regarding project land use and planning will not be analyzed in
the Coral Mountain Resort EIR.
The project will include a General Plan Amendment to revise the existing City of La Quinta
General Plan Map to be consistent with the proposed land uses. The proposed project consists
of a variety of land uses including Low Density Residential, Tourist Commercial, General
Commercial, and Open Space Recreation. A Zone Change is required to revise the City's
Zoning Map to be consistent with the proposed land uses. The EIR will analyze whether the
proposed General Plan Amendment and Zone Change are consistent with the City's General
Plan and zoning, in the discussion of CEQA Threshold "b", and mitigation measures will be
developed, if necessary, and analyzed to determine whether impacts can feasibly be reduced
to less than significant levels.
4.2.11 Mineral Resources
Mineral resources found throughout the region include sand, gravel, crushed stone, copper,
limestone, and tungsten. Many of these resources are important for common construction
projects including asphalt, concrete, road base, stucco, and plaster. There are currently several
active sand and gravel mines in the Coachella Valley, but none are in the City of La Quinta.
Future mining within the City of La Quinta is unlikely due to existing urbanization.
Coral Mountain Resort Specific Plan NOP 37 Febraury 2021
According to the Mineral Land Classification Map, the approximately 386 -acre project site is
located within Mineral Resource Zone 1 (MRZ-1) and Mineral Resource Zone 3 (MRZ-3). The
northeast portion of the project is located with the MRZ-1 zone, which specifies areas where
geologic information indicates no significant mineral deposits are present or likely to be
present. The southwest portion of the project property is located within the MRZ-3 zone which
indicates areas containing known or inferred mineral occurrences where the significance cannot
be evaluated from available data. The Mineral Resource Zone Map within the 2035 La Quinta
General Plan, also classifies the project property to be located within zones MRZ-1 and MRZ-3.
A small portion of MRZ-3, located just north of Avenue 60 and west of Madison (i.e. the project
site), is undeveloped vacant land designated for low density residential development. A barrow
pit, used temporarily for the development of the Thomas Levy water recharge facility, is located
within the project area. However, the use was temporary, and the barrow pit is not currently
used for mining. The site has been designated for low density residential and golf course uses,
and any barrow pits have been abandoned.
The La Quinta General Plan Environmental Impact Report (LQGP EIR) states that undeveloped
sites located in MRZ-3 zones in the City are surrounded by urban development and mineral
extraction activities are incompatible and unlikely on the remaining vacant parcels. The project
site, designated for urban uses, is not conducive to mineral extraction. Therefore, the LQGP
EIR concludes that development of areas within these land use categories will not result in the
loss of availability of locally important mineral resources considered valuable to the region and
state and will not result in the loss of availability of mineral resource recovery sites.
The project site is not recognized as a mineral resource recovery site delineated in the City of
LQGP, General Plan EIR or resource maps prepared pursuant to SMARA. The use of a small
portion of the property as a barrow pit was temporary and associated with the construction of
the Thomas Levy water recharge facility to the northwest. The land is currently and has for
many years been designated for residential and golf course development, and not for mineral
extraction. Therefore, the proposed project will have no impact on mineral resources, and
analysis of CEQA Thresholds "a" and "b" regarding mineral resources will not be included in the
EIR.
4.2.12 Noise
The project is located on vacant land on the southwest corner of Avenue 58 and Madison
Street. The closest airport to the project is the Jacqueline Cochran Regional Airport, located at
56-850 Higgins Drive in Thermal, California. The project is located approximately 4.25 miles
west of the Airport. Since the project is not located within two miles of a public airport or in
Coral Mountain Resort Specific Plan NOP 38 Febraury 2021
the vicinity of a private airstrip, CEQA Threshold "c", regarding noise -related impacts, will not
be analyzed in the EIR.
The proposed project is consistent with the City's residential and residential and resort
character. A project -specific noise impact analysis will be prepared. Potential impacts of noise
associated with project construction and operation will be analyzed and addressed in the EIR,
as required by CEQA Threshold "a". Appropriate design measures and all applicable restrictions
and requirements will be identified within the EIR and, if necessary, mitigation measures will
be identified and analyzed to determine whether impacts can feasibly be reduced to less than
significant levels.
Additionally, project -generated groundborne vibration and groundborne noise levels will also
be analyzed in the EIR to determine whether impacts are significant, and if necessary,
mitigation measures will be identified and analyzed to determine whether impacts can
feasibly be reduced to less than significant levels (CEQA Threshold "b").
4.2.13 Population and Housing
A maximum of 600 dwelling units are proposed to be developed within the Coral Mountain
Resort Specific Plan.
According to the 2020 California Department of Finance population and housing estimates,
the City of La Quinta's total population is approximately 40,660 with an average household
size of 2.60. The City of La Quinta's General Plan (LQGP) Environmental Impact Report (EIR)
analyzed future growth in Section III, Part L, Population and Housing. The EIR forecasts a
population of 46,297 people by year 2035.
As a result of project build -out, the proposed development could add approximately 2,181
new residents to the City for an approximate population of 42,841. This is an increase of 5
percent, and still below the projected 2035 population forecast of 46,297. Although the
project would contribute to growth within the City of La Quinta, significant growth to
population, housing and employment is already anticipated in the City's General Plan and EIR,
including based upon the prior entitlement approvals for the project site. In addition, this
projected increase is a conservative figure because it assumes that the project's future
residents will not be current residents of La Quinta. However, it is anticipated that some of
the project's residents will be existing residents from within the City and/or from neighboring
incorporated and unincorporated areas. Additionally, the 150 hotel keys will not lead to
permanent residents of the project. The employment generated by the project will include
hotel, commercial and surf -related employees. However, the project will not result in a large
Coral Mountain Resort Specific Plan NOP 39 Febraury 2021
employment base, and jobs created at the project will be absorbed by new and existing
residents of the City and surrounding jurisdictions.
The proposed project lies adjacent to the existing paved roadways, Avenue 58 (north) and
Madison Street (east). Extensions of these roadways are not proposed as part of project
implementation. Avenue 60, south of the proposed project, provides approximately 750 feet
of paved access (from the Madison Street intersection) to the residential properties south of
the site. Implementation of the proposed project will extend Avenue 60 approximately 525
feet to the west, to provide access to the southern portion of the project property.
The project will be required to make offsite improvements for electrical power to the site. The
project will be required to install an off-site transformer bank at an existing IID substation
located at 81600 Avenue 58 and extend a distribution line along Avenue 58. Conduit systems
will also be installed along Avenue 58 as part of the proposed upgrades. Construction of the
conduits and line extension would occur in the existing right-of-way. The extension of IID's
infrastructure will provide electricity exclusivity to the proposed project. The project's
connection to the existing IID infrastructure will occur during the first phase of development
and will be for exclusive use of the proposed project. In a letter dated May 26, 2020, IID
concluded that electrical facilities can be extended to serve the project, under the conditions
in the will serve letter.
Water lines currently occur along Avenue 58 and Madison Street, and sanitary sewer lines
occur on Avenue 58 and Avenue 60. No additional extensions of infrastructure will be
required.
The project is not anticipated to result in an indirect growth inducing impact because the
existing infrastructure has been sized to accommodate long term growth by the applicable
providers and because the projected population growth is already included in the City of La
Quinta's General Plan. Therefore, the EIR will not analyze project -related direct and indirect
population growth (CEQA Threshold "a") of the population and housing section.
The project site is currently vacant and does not provide housing. Development of the project
site would not displace substantial numbers of existing housing or people necessitating the
construction of replacement housing and there would be no impact. Therefore, CEQA
Threshold "b", regarding project -related impacts to population and housing, will not be
analyzed in the EIR.
Coral Mountain Resort Specific Plan NOP 40 Febraury 2021
4.2.14 Public Services
The Riverside County Fire Department (RCFD), under contract with the City of La Quinta,
provides 24-hour fire protection and emergency medical services to the City. Law enforcement
services are provided to the City of La Quinta through a contractual agreement with the
Riverside County Sheriff's Department. The Sheriff's department provides 24-hour municipal
police services associated with a City police department. The City of La Quinta is served by
two school districts: Desert Sands Unified School District (DSUSD) and Coachella Valley
Unified School District (CVUSD). DSUSD serves the portion of the City west of Jefferson Street
and north of Avenue 48, which includes the northern Sphere of Influence. CVUSD boundaries
include the areas of Jefferson Street and east of Avenue 48. Implementation of the proposed
project will increase the permanent population which could have an impact on the City's
public services. CEQA Threshold "a" (fire protection; police protection; schools; parks; and
other public facilities) will be analyzed in EIR to quantify the potential impacts of the demand to
public services, and mitigation measures will be developed, if necessary, and analyzed to
determine whether impacts can feasibly be reduced to less than significant levels.
4.2.15 Recreation
The project proposes a mixed-use development consisting of commercial, tourist commercial,
low density residential, and open space recreational uses on approximately 386 acres of vacant
land. The project proposes the development of a golf practice facilities (i.e., par 3 golf, or
putting green), clubhouse and resort amenities, supporting uses and the Wave basin. Additional
recreational uses include:
• The Wave contains an artificial surf wave basin (The Wave basin), that will recreate
ocean waves for recreational surfing by individual resort residents and hotel guests as
well as the hosting of limited private and public events by reservation.
• The Wave Club will function as a private clubhouse with amenities for exclusive use by
project residents and guests. The clubhouse may feature changing rooms, surfboard
storage, pool, and a casual dining/lounging area.
• The Farm will include private resort -serving entertainment and fitness facilities. It will
offer a wide range of community and active lifestyle amenities , including hiking, biking,
bicycle pump track, fitness, and swimming pool areas. In addition, spa and dining
facilities may be provided for residents and hotel guests.
• Planning Area IV, located on approximately 24 acres on the western side of the project
property, allows open space, and low -impact active and passive recreational activities,
such as hiking, biking, and ropes courses.
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The recreational amenities, parks, and open space areas proposed for the project would
reduce use of City parks and recreation facilities, since the proposed site would provide
various recreational opportunities within the project boundaries. Some visitors may attend
events and participate in activities at local parks; however, such visits are expected to be
minimal. The project will comply with the City's parkland in lieu fee (Quimby) and other
development impact fees. The amount of recreational space provided within the project will
reduce the likelihood of project residents' use of existing City facilities.
Since the project will comply with Quimby fees, and the project proposes on-site recreational
facilities, the project will not result in significant impacts to recreation, and the EIR will not
analyze CEQA Thresholds "a" and "b" regrading recreation.
4.2.16 Transportation
The proposed project is located on vacant property at the southwest corner of Madison Street
and Avenue 58 in the City of La Quinta. Vehicular access to the project is provided by existing
public arterial roads, including Avenue 58 and Madison Street. The project will be required to
widen and improve these roadways to their ultimate General Plan half -width. The property is
surrounded by Low Density Residential land uses and natural open space. Regional access to
the site is provided by Interstate 10, Highway 111, Madison Street, Monroe Street and other
major arterials. The project will generate trips associated with residential, commercial and
resort development, which could impact the City's circulation system. In addition, the project
includes special events at the wave basin facility which would result in increases in trip
generation during short periods of time.
A traffic impact analysis (TIA) is being prepared to assess potential traffic -related impacts
relating to development of the project site. The TIA will be based upon an analysis of existing
roadway conditions in the project vicinity, a variety of traffic count sources (including peak
hour counts collected by the consulting traffic engineers), the General Plan Circulation
Element, planned roadway improvements and other data and information. The TIA will
provide documentation and analysis of existing traffic conditions, trips generated by the
project, distribution of the project trips to roads outside the project, and projected future
traffic conditions.
A project -specific Vehicle Miles Traveled (VMT) Analysis is also being conducted (pursuant to
Senate Bill 743, and the City's VMT Analysis Policy) to evaluate the impacts of VMTs generated
by the project. The findings of the VMT Analysis will be provided in the EIR.
Moreover, the EIR will analyze hazards associated with transportation/roadway features, as
well as emergency access proposed for the site. The EIR will analyze CEQA Thresholds "a", "b",
Coral Mountain Resort Specific Plan NOP 42 Febraury 2021
"c", and "d" in order to determine project -related impacts to traffic, and mitigation measures
will be developed, if necessary, and analyzed to determine whether impacts can feasibly be
reduced to less than significant levels.
4.2.17 Utilities and Service Systems
Water and wastewater services would be provided by the Coachella Valley Water District
(CVWD). Currently, domestic water service lines exist along Avenue 58 and Madison Street.
The project will require two well sites to adequately serve the site. The well sites will be located
within the project's existing footprint and will be analyzed in the EIR. No new wastewater
treatment facilities are required as a result of the project's development.
The City determined that the proposed project requires the preparation and approval of a
Water Supply Assessment and Water Supply Verification, consistent with Water Code Section
10912.
A Water Supply Assessment (WSA) and Water Supply Verification (WSV) were completed for
the proposed project and adopted by the water provider, CVWD, in March 2020. The
findings of the WSA/WSV will be included in the EIR.
Electrical service to the project would be provided by the Imperial Irrigation District (IID).
Connection to an offsite substation is required in order to provide electrical power to the
project.
CVWD will also provide wastewater services to the site. The offsite sewer alignment and
improvements will come from the east in Avenue 60. Wastewater will go to CVWD's
water reclamation plan number 4 (WRP-4) located at 63-002 Fillmore St., Thermal CA.
As a standard requirement, the project site design will incorporate stormwater management by
conveying site runoff into on-site retention basins with a combined capacity to handle the water
quality management plan design capture volume and the controlling 100 -year storm event
volume. This will also be analyzed in the Hydrology and Water Quality Section of the EIR.
Southern California Gas Company is the provider of natural gas. Telephone and Internet
communications will be provided by Frontier and Charter Communications. Burrtec will
provide solid waste and recycling services. The project will be able to tie into the existing
cable, gas and telecommunications lines located along Avenue 58 and Madison Street. The
project will not require or result in the relocation or construction of new or expanded water,
wastewater treatment, storm water drainage systems, natural gas, or telecommunication
facilities.
Coral Mountain Resort Specific Plan NOP 43 Febraury 2021
The development of the proposed Coral Mountain Resort project would increase the demand for
utilities in the City. The service, location, timing and construction of on- and off-site
improvements required for all utilities will be included in the EIR analysis. Project design
features and mitigation measures during construction and operation would be identified in the
Draft EIR. CEQA Thresholds "a" through "e", regarding project impacts to utilities and service
systems, will be evaluated in the EIR, and mitigation measures will be developed, if necessary,
and analyzed to determine whether impacts can feasibly be reduced to less than significant
levels.
4.2.18 Wildfires
The project site is currently characterized as vacant land with scattered vegetation of varying
densities. Vegetation within the project area includes Desert Saltbush scrub, Tamarisk scrub,
Mesquite Hummock, and Sonoran creosote. Residential land uses surround the property to the
north and east. The property's western and southern boundaries abut vacant land and Coral
Mountain. Scattered residential estate properties lie south of the project site.
According to CAL Fire's Fire Hazard Severity Zones (FHSZ) in State Responsibility Areas (SRA)
Map, the project site is not located in an SRA or located in an area classified as very high fire
hazard severity zone. Per CAL Fire's map, the property is located in a (incorporated) Local
Responsibility Area (LRA) that is designated "non -Very High Fire Hazard Severity Zone". The
project is not located in or near state responsibility areas or lands classified as very high, high or
moderate fire hazard severity zones, therefore, no impacts are anticipated. The FHSZ map
designates the area west of the project site, i.e., Coral Mountain, as a Federal Responsibility
Area (FRA). However, this site is also not designated as a very high, high or moderate FHSZ.
Wildfire risk is related to a number of parameters, including fuel loading (vegetation), fire
weather (winds, temperatures, humidity levels and fuel moisture contents) and topography
(degree of slope). Steep slopes contribute to fire hazards by intensifying the effects of wind and
make fire suppression difficult. Fuels such as grass are highly flammable because they have a
high surface area to mass ratio and require less heat to reach the ignition point. According to
the Riverside County General Plan, wildfire susceptibility is moderate to low in the valley and
desert regions on the western and eastern sides of the Salton Sea. The project is not located in
or near a State Responsibility Area, or an area classified as a Very High Fire Hazard Severity
Zone. Therefore, the project site is not expected to expose project occupants to pollutant
concentrations from a wildfire or the uncontrolled spread of a wildfire.
In addition to this, the La Quinta General Plan (LQGP) Environmental Impact Report (EIR) states
that fire hazards exist where wildland areas are adjacent to or are intermixed with urbanized
areas. The open space and wilderness areas on the western portion of the City are made up
Coral Mountain Resort Specific Plan NOP 44 Febraury 2021
primarily of Granitic rock and sparse desert vegetation. Therefore, there is limited vegetation to
burn that could cause a major wildfire. The flat urbanized areas of La Quinta are considered
very low wildfire areas. The project will not expose people or structures to a significant risk of
loss, injury or death involving wildland fires because the City of La Quinta does not provide
conditions, such as dense vegetation, conducive for the spread of wildfires.
The project would not impair implementation of or physically interfere with an adopted
emergency response plan or emergency evacuation plan because it will provide emergency fire
access to the project site, and will not alter the City's existing street system. Emergency access
would be compliant with the standards of the Fire Department to ensure proper vehicular
access for emergency vehicles to the site. As a result, the project is not expected to require the
installation or maintenance of associated infrastructure that may exacerbate fire risk or that
may result in temporary or ongoing impacts to the environment.
Wildfires are not expected to occur at the project site, or within the City of La Quinta. This is
due to the Granitic Rock and sparse vegetation that characterize the Santa Rosa Mountains, as
well as the developed and landscaped urban areas of La Quinta. Since the City is not expected
to be impacted by wildfires, the project would not expose people or structures to significant
risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire
slope instability, or drainage changes as a result of a wildfire. No impact is expected to result
from the project, and CEQA Thresholds "a" through "d" regarding wildfire impacts are not
analyzed in the EIR.
5.0 Conclusion
An EIR will be prepared for the proposed project that addresses the environmental
impacts associated with the development of the Coral Mountain Resort project. The EIR will
also analyze a reasonable range of alternatives to the Project, including the CEQA-mandated
"No Project Alternative", and other potential alternatives that may be capable of avoiding or
substantially reducing any of the significant effects of the Project. All environmental issues
identified in the CEQA Guidelines Appendix G, and other issues that may be raised by
responsible or trustee agencies or other parties commenting on this Notice of Preparation will
also be fully addressed in the EIR.
Coral Mountain Resort Specific Plan NOP 45 Febraury 2021
CITY OF LA QUINTA
— GEM of the DESERT — NOTICE OF PREPARATION
Project Title: Coral Mountain Resort
Project Location: Within the City of La
Quinta, the project encompasses an area of
approximately 929 acres south of Avenue
58, north of Avenue 60, and east and west
of Madison Street. As a part of the proposed
project, the 386 -acre portion of the site west
of Madison Street is proposed to be removed
from the existing Andalusia Specific Plan (SP
03-067) and developed under Specific Plan
2019-0003. This area is generally bounded
by the Avenue 58 to the north; Madison
Street to the east; the extension of Avenue
60 to the south; and Coral Mountain to the
west. Located in portions of Section 27 and
28, Township 6 South, Range 7 East, San
Bernardino Base Line and Meridian; Latitude
33° 37' 15" N Longitude 116° 15' 21" W
(approximate geographic center of the site).
Project Description: The proposed project
would result in the development of a master
planned resort community, and the removal
of the 386 -acre development site from the existing 929 -acre Andalusia at Coral Mountain
Specific Plan. The project proposes to develop the 386 -acre site with a mix of uses
including up to 600 dwelling units of varying product types, a resort facility with up to 150
rooms, 57,000 square feet of tourist commercial uses, 60,000 square feet of neighborhood
commercial uses, and open space recreational uses on approximately 23.6 acres. In
addition, the project proposes a 16.62 -acre artificial wave basin for recreational purposes.
The project consists of the following entitlement applications: a General Plan Amendment
(GPA 2019-0002), a Zone Change (ZC 2019-0004), a Specific Plan Amendment to SP 03-
067, a Specific Plan (SP 2019-0003), a Tentative Tract Map (TTM 2019-0005), and a Site
Development Permit (SDP) for a portion of the project consisting of an artificial wave
basin.
52ND AVENUE
Lu
z
0
54TH AVENUE
CITY OF
LA QUINTA
z
O
Q
0
O
AIRPORT BLVD.
COUNTY OF
RIVERSIDE
JACKSON STRE
58TH AVENUE
SITE
AMENDMENT V
OF SP 03-067
60TH A VENUE
The City of La Quinta, acting as the Lead Agency, has determined that an Environmental
Impact Report (EIR) should be prepared for the proposed project. The EIR will be
prepared in accordance with the California Environmental Quality Act (CEQA) to evaluate
the potential environmental impacts associated with the implementation of the project.
This Notice of Preparation also solicits comments and questions from responsible agencies,
trustee agencies, federal, State and local agencies and the general public, on the scope
and content of the environmental document to be prepared to analyze the potential
environmental impacts of the proposed project. Comments received in response to this
Notice of Preparation will be reviewed and considered in determining the scope of the EIR.
The time period to submit comments will begin February 17, 2021 and will end March 19,
2021.
Comments and questions may be directed to: Nicole Sauviat Criste, Consulting Planner,
City of La Quinta, 78-495 Calle Tampico, La Quinta, CA 92253, or
consultingplannerC@laquintaca.gov. Please include the name, phone number, and address
of your agency's contact person in your response.
PUBLISH ONCE ON FEBRUARY 16, 2021 1/8 PAGE DISPLAY AD
www.iid.com
A century of service. Since 1911
August 4, 2021
Nicole Sauviat Criste
Consulting Planner
Design and Development Department
City of La Quinta
78495 Calle Tampico
La Quinta, California 92253
SUBJECT: NOA of a DEIR for the Coral Mountain Resort Project
Dear Ms. Sauviat Criste:
On June 28, 2021, the Imperial Irrigation District received from the City of La Quinta, the Notice
of Availability of a Draft Environmental Impact Report for the Coral Mountain Resort project. The
project proposes to develop a 386 -acre site with a mix of uses including up to 600 dwelling units
of varying product types, a resort facility with up to 150 rooms, 57,000 sq. ft. of tourist commercial
uses, a 16.62 -acre artificial wave basin for recreational purposes, 60,000 sq. ft. of neighborhood
commercial uses and 23.6 acres of open space recreational uses. The project includes the
installation of an off-site transformer bank at an existing IID substation (Ave. 58 Substation) as
part of the proposed upgrades. The 386 -acre site is generally bounded by Avenue 58 to the north;
Madison Street to the east; the extension of Avenue 60 to the south; and Coral Mountain to the
west in La Quinta, CA.
The IID has reviewed the project information and found that the comments provided in the March
18, 2021 district letter (see attached letter) continue to apply.
Should you have any questions, please do not hesitate to contact me at (760) 482-3609 or at
dvargas@iid.com. Thank you for the opportunity to comment on this matter.
Respectfully,
(/'
/ L--
Dori Id Vargas
Compliance Administrator II
Enrique B. Martinez— General Manager
Mike Pacheco — Manager, Water Dept.
Marilyn Del Bosque Gilbert — Manager, Energy Dept.
Constance Bergmark — Mgr. of Planning & Eng./Chief Elect. Engineer, Energy Dept.
Daryl Buckley — Mgr. of Distribution Srvcs. & Maint. Oprtns., Energy Dept.
Enrique De Leon — Asst. Mgr., Energy Dept., Distr., Planning, Eng. & Customer Service
Jamie Asbury — Assoc. General Counsel
Vance Taylor — Asst. General Counsel
Michael P. Kemp — Superintendent, Regulatory & Environmental Compliance
Laura Cervantes — Supervisor, Real Estate
IMPERIAL IRRIGATION DISTRICT • P.O. BOX 937 • IMPERIAL, CA 92251
www.iid.com
A cent y of serpice. Since 1911
March 18, 2021
Nicole Sauviat Criste
Consulting Planner
Design and Development Department
City of La Quinta
78495 Calle Tampico
La Quinta, California 92253
SUBJECT; NOP of an EIR for the Coral Mountain Resort Specific Plan and Tentative
Tract Map in La Quinta, CA
Dear Ms. Sauviat Criste:
On February 23, 2021, the Imperial Irrigation District received from the City of La Quinta,
a Notice of Preparation of an Environmental Impact Report for the Coral Mountain
Specific Plan and Tentative Tract Map. The applicant, CM Wave Development, LLC;
proposes the development of approximately 386 acres located south of Avenue 58, north
of Avenue 60, and east and west of Madison Street in la Quinta, California to build 600
dwelling units, 150 -room resort facility, 57,000 sq. ft. for tourist commercial uses, 60,000
sq. ft. of neighborhood commercial space, 23.6 acres for open space recreational uses
and a 16.62 -acre artificial wave basin for recreational purposes.
The Imperial Irrigation District has reviewed the project information and has the following
comments:
1. Based on the preliminary information provided to the IID for phase 1 and
subsequent phases, the installation of a new distribution substation 1-40MVA
92/13.2kV transformer bank at the existing Avenue 58 Substation, including the
reconfiguration of the 92kV transmission lines and all bank addition infrastructure,
will be required to accommodate the power requirements of the project.
2. Applicant will be required to install a double conduit/vault system from the new
Avenue 58 substation bank to the project for a minimum of six (6) distribution
backbone feeders. The proposed route for this system is planned to come out of
the Avenue 58 Substation, cross Avenue 58 and continue on the south side of
Avenue 58 going west all the way to the project. The whole conduit system will be
required to be in place prior to extending the new feeders/backbone line extensions
(conduit, cable) from the Avenue 58 Substation's new 40MVA transformer circuit
breakers to the project for phase 1 and subsequent phases.
IMPERIAL IRRIGATION DISTRICT • P.O. BOX 937 • IMPERIAL, CA 92251
Nicole Sauviat Criste
March 18, 2021
Page 2
3. Applicant will be required to extend six (6) distribution backbone feeders as part of
the new substation transformer implementation, including the associated
backbone cable/terminations from Avenue 58 Substation's new 40MVA
transformer circuit breakers to the project's load centers, all which are at the
expense of the applicant.
4. The applicant shall bear the cost of the substation infrastructure to serve the
project but would be reimbursed for any oversizing required, subject to approval
by the IID Board of Directors.
5. Applicant (and other developers in the area) shall bear all costs associated with
providing electrical service to the project, including but not limited to the
construction of new substation facilities, transmission line extensions or upgrades,
distribution backbone feeders, conduit/vault systems, distribution overhead and/or
underground line extensions, the reconfiguration of distribution circuits,
transmission line extensions or other upgrades as well as applicable permits,
zoning changes, landscaping (if required by the City) and rights-of-way and
easements.
6. Applicant should be advised that pursuant to IID process, the standard timeframe
for the implementation of a new substation transformer (engineering, equipment
procurement and construction) is 18 months at minimum. As a result, Applicant
should adjust its project's in-service dates accordingly. The procurement of the
new substation bank would start upon receipt of a customer project application for
the substation bank acquisition including payment for the full cost of the required
equipment.
7. Applicant is encouraged to submit a new Will Serve letter request with updated
loading and construction phasing schedule to prepare a required full impact study
for a revised Plan of Service. To avoid ambiguity and delays, this information will
be required for all phases of the project. The information should be submitted well
in advance of any required in-service date to ensure sufficient time for procurement
and construction.
8. The district's ability to provide electrical service is based on currently available
capacity as of this date, which may be impacted by future development in the area.
It is important to note that a detailed and final study will be developed once a
customer project application and loading calculations are received. This detailed
information will allow IID to perform an accurate assessment and provide a full
report of any potential impacts and mitigation measures. However, other projects
could impact existing resources which may affect IID's ability to serve this load, if
the buildout of the mitigation measures are not completed in a timely manner The
conditions of service could change as a result of the additional studies.
Nicole Sauviat Cristo
March 18, 2021
Page 3
9. HD will not begin any studies, engineering or estimate costs to provide electrical
service to the project until the applicant submits a customer project application
(available at the website http://www.iid.com/home/showdocument?id=12923) and
detailed loading information, panel sizes, project schedule and estimated in-
service date, etc. are submitted as well.
10. Underground infrastructure that includes trenching, conduits, pull boxes, switch
boxes and pads should be installed following IID approved plans. Physical field
installation of underground infrastructures should be verified and approved by an
IID inspector prior to cable installation as per IID Developer's Guide (available at
the district website https://wvvw.iid.com/home/showdocument?id=14229).
11.IID Regulations governing line extensions can be found at:
No. 2 (http://www.iid.com/home/showdocument?id=2540),
No. 13 (http://www.lid.com/home/showdocument?id=2553),
No. 15 (http://www.iid.com/home/showdocument?id=2555),
No. 20 (http://www.iid.com/home/showdocument?id=2560) and
No. 23 (hftps://www.iid.com/home/showdocument?id =17897).
12. For additional information regarding electrical service for the project, the applicant
should be advised to contact the IID Energy - La Quinta Division Customer
Operations, 81-600 Avenue 58 La Quinta, CA 92253, at (760) 398-5841 and speak
with the project development planner assigned to the area.
13.1t is important to note that IlD's policy is to extend its electrical facilities only to
those projects that have obtained the approval of a city or county planning
commission and such other governmental authority or decision-making body
having jurisdiction over said developments.
14.The applicant will be required to provide rights-of-way and easements for
substation, transmission and distribution line extensions and overhead or
underground infrastructure needed to serve the project.
15.Any construction or operation on IID property or within its existing and proposed
right of way or easements including but not limited to: surface improvements such
as proposed new streets, driveways, parking lots, landscape; and all water, sewer,
storm water, or any other above ground or underground utilities; will require an
encroachment permit, or encroachment agreement (depending on the
circumstances). A copy of the IID encroachment permit application and instructions
for its completion are available at https://www.iid.com/about-iid/department-
directory/real-estate. The IID Real Estate Section should be contacted at (760)
339-9239 for additional information regarding encroachment permits or
agreements.
Nicole Sauvlat Cristo
March 18, 2021
Page 4
16. Relocation of existing IID facilities to accommodate the project and/or to
accommodate street widening improvements imposed by the City will be deemed
project -driven and all costs, as well as securing of rights of way and easements for
relocated facilities, shall be borne by the applicant.
17. Public utility easements over all private public roads and additional ten (10) feet in
width on both side of the private and public roads shall be dedicated to IID for the
construction, operation, and maintenance of its electrical infrastructure.
18. Any new, relocated, modified or reconstructed IID facilities required for and by the
project (which can include but is not limited to electrical utility substations, electrical
transmission and distribution lines, etc.) need to be included as part of the project's
CEQA and/or NEPA documentation, environmental impact analysis and mitigation.
Failure to do so will result in postponement of any construction and/or modification
of IID facilities until such time as the environmental documentation is amended and
environmental impacts are fully mitigated. Ariy mitigation necessary as a result
of the construction, relocation and/or upgrade of ltD facilities is the
responsibility of the project proponent.
19. Dividing a project into two or more pieces and evaluating each piece in a separate
environmental document (Piecemealing or Segmenting), rather than evaluating
the whole of the project in one environmental document, is explicitly forbidden by
CEQA, because dividing a project into a number of pieces would allow a Lead
Agency to minimize the apparent environmental impacts of a project by evaluating
individual pieces separately, each of which may have a less -than -significant impact
on the environment, but which together may result in a significant impact.
Segmenting a project may also hinder developing comprehensive mitigation
strategies. In general, if an activity or facility is necessary for the operation of a
project, or necessary to achieve the project objectives, or a reasonably foreseeable
consequence of approving the project, then it should be considered an integral
project component that should be analyzed within the environmental analysis. The
project description should include all project components, including those that will
have to be approved by responsible agencies. The State CEQA Guidelines define
a project under CEQA as "the whole of the action" that may result either directly or
indirectly in physical changes to the environment. This broad definition is intended
to provide the maximum protection of the environment. CEQA case law has
established general principles on project segmentation for different project types.
For a project requiring construction of offsite infrastructure, the offsite infrastructure
must be included in the project description. San Joaquin Raptor/Wildlife Rescue
Center v. County of Stanislaus (1994) 27 Cal.App. 4th 713.
20.Applicant should be advised that landscaping can be dangerous if items are
planted too close to HD's electrical equipment. In the event of an outage, or
equipment failure, it is vital that IID personnel have immediate and safe access to
Nicole Sauviat Cristo
March 18, 2021
Page 5
its equipment to make the needed repairs. For public safety, and that of the
electrical workers, it is important to adhere to standards that limit landscaping
around electrical facilities. IID landscaping guidelines are available at
https://www.lid.cam/energy/vegetation-management.
Should you have any questions, please do not hesitate to contact me at (760) 482-3609
or at dvargas@iid.com. Thank you for the opportunity to comment on this matter.
Respe Ily,
Donald Vargas
Compliance Administrator II
Enrique B. Martinez— General Manager
Mike Pacheco — Manager, Water Dept.
Marilyn Del Basque Gilbert — Manager, Energy Dept.
Constance Bergmark — Mgr. of Planning & Eng./Chief Elect. Engineer, Energy Dept.
Enrique De Leon — Asst. Mgr., Energy Dept., Distr., Planning, Eng. & Customer Service
Jamie Asbury—Assoc. General Counsel
Vance Taylor—Asst. General Counsel
Michael P. Kemp — Superintendent, Regulatory & Environmental Compliance
Laura Cervantes Supervisor, Real Estate
CactusToCloud
www.CactusToCloud.org
@CactustoCloud
August 6, 2021
Nicole Sauviat Criste,
Consulting Planner
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Via: consultingplanner@laquinta.gov
Subject: Comments on Coral Mountain Resort Draft EIR SCH #2021020310
Dear Ms. Sauviat Criste,
CactusToCloud values the opportunity to submit comments for the project above referenced, and we
respectfully request you please share our comments with the La Quinta City Council. CactusToCloud is a
group of desert advocates collaborating on community science and environmental education projects in
the Coachella Valley, and our goal is to celebrate and protect our desert home. We represent diverse
backgrounds and life experiences, and we are all UCR-Palm Desert California Naturalists and Climate
Stewards. As it happens, we are also all homeowners in the City of La Quinta.
As concerned La Quinta residents, and given our training and time spent in our community, we consider
it imperative that we, CactusToCloud, oppose this project, and we ask that the DEIR be revised to
address the concerns contained in this letter, and other letters of concerned residents and conservation
organizations.
This project threatens to negatively impact the existing cultural, ecological, and recreational features in
this area. Coral Mountain itself is a cultural and historically rich space, where Native American
petroglyphs, intact honey mesquite hummocks, and the ancient Lake Cahuilla Shoreline are visible and
accessible to our community. We are concerned irresponsible development of this area would damage
these irreplaceable assets in our beautiful city, and that access to public lands will be limited.
It is common knowledge that we are in the middle of one of the worst droughts in the history of our
state. The use of our ever -diminishing water resources to fill and maintain a 20 -acre basin would be
short-sighted and does not consider reduced water availability during an unprecedented drought, or
uncertain future conditions due to a changing climate. We fear the DEIR has not properly address this,
and if this project is approved our community risks water shortages and similar water restrictions to
those now in effect in other parts of our state. California's water board recently unanimously approved
emergency regulations to temporarily stop thousands of landowners, residents and farmers alike, from
using water from the Sacramento — San Joaquin Delta watershed. Consumers are now living with a 55
gallon per person per day allowance, and face penalties up to $1000 per day, plus $2500 per acre-foot,
for illegally diverting water. Only through responsible use of water, both imported and from our
underground aquifer, can we avoid similar restriction in La Quinta.
While we oppose this specific project as presented, we support the responsible development of this site
in general. Indeed, smart development around Coral Mountain has the potential to fulfill important
community needs such as affordable housing, equitable access to public lands, and climate resilience
planning (as required of city governments by SB 379). Any development should incorporate resilience
best practices, such as community input and consideration of environmental justice, sustainable water
use, native plant landscaping, and outdoor recreational access to Coral Mountain, Boo Hoff Trail, and
the Santa Rosa Wilderness.
Instead of a surf park which is out of character with our desert, a development that not only preserves
but enhances the natural and cultural heritage of our City would be an asset to the community. The
CactusToCloud team is ready and interested in working with the City and developers to assist in the
implementation of these features, and working together to build a resilient and inclusive community for
people and wild plants and animals to thrive in the Coachella Valley.
Thank you for your time and consideration,
CactusToCloud
Sendy Barrows
Colin Barrows
Tracy Bartlett
Elizabeth Ogren Erickson
CAL FIRE - RIVERSIDE UNIT
RIVERSIDE COUNTY FIRE DEPARTMENT
BILL WEISER - FIRE CHIEF
2300 Market Street Ste. #150, Riverside, CA 92501 • (951) 955-4777
• Fax (951) 955-4886
www.rvcfire.org
PROUDLY SERVING THE
UNINCORPORATED AREAS
OF RIVERSIDE COUNTY
AND THE CITIES OF:
BANNING
BEAUMONT
CANYON LAKE
COACHELLA
DESERT HOT SPRINGS
EASTVALE
INDIAN WELLS
INDIO
JURUPA VALLEY
LAKE ELSINORE
LA QUINTA
MENIFEE
MORENO VALLEY
NORCO
PALM DESERT
PERRIS
RANCHO MIRAGE
RUBIDOux CSD
SAN JACINTO
TEMECULA
WILDOMAR
BOARD OF
SUPERVISORS:
KEVIN JEFFRIES
DISTRICT 1
KAREN SPIEGEL
DISTRICT 2
CHARLES WASHINGTON
DISTRICT 3
V. MANUEL PEREZ
DISTRICT 4
JEFF HEWITT
DISTRICT 5
August 6, 2021
Ms. Nicole Sauviat Criste
Consulting Planner
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Re: Coral Mountain Resort Draft EIR
Ms. Criste,
The Riverside County Fire Department Strategic Planning Division has reviewed the Draft
Environmental Imapct Report for the Coral Mountain Resort. Section 3.5.3 Project Components
makes mention of the potential of up to four special events per year with no more than 2,500
guests at each event. We are requesting further information on these events as well as
clarification on the daily operation of The Wave in respect to anticipated daily attendance, hours
of operation, whether the venue is open to the public, etc. Clarification of these items will assist
the Riverside County Fire Department in determining the anticipated need for service and if
additional mitigations will be needed to provide service to the proposed developemt.
Thank you for the opportunity to review the Draft EIR and comment. Should you have any
questions or comments, I can be reached at (951) 955-5272 or via email at
adria.reinertson@fire.ca.gov.
Sincerely,
Adria Reinertson
Deputy Fire Marshal
Friday, August 6, 2021 at 15:30:56 Pacific Daylight Time
Subject: FW: Coral Mtn Resort DEIR comments from CVWD
Date: Friday, August 6, 2021 at 3:16:45 PM Pacific Daylight Time
From: William Patterson
To: consultingplanner@laquintaca.gov
Attachments: image001.png
Ms. Criste,
Please also include the following comment:
Pages 88, 89 (Section 3.8), 609, and 617 (Section 4.15) of the pdf refer to and/or depict the proposed
water infrastructure through the project. CVWD will require an offsite pipeline in Ave. 60 in
accordance with the existing Agreement. In addition, there are changes to other portions of the
onsite pipeline that will be needed. We suggest the project proponent meet with CVWD to discuss
these requirements.
Sincerely,
William Patterson
Environmental Supervisor
Environmental Services Department
Coachella Valley Water District
75-519 Hovley Lane East
Palm Desert, CA 92211
(760) 398-2651
From: William Patterson
Sent: Friday, August 6, 2021 9:50 AM
To: 'consulting' <Planner@laquintaca.gov>
Subject: Coral Mtn Resort DEIR comments from CVWD
Hello Ms. Criste,
CVWD would like to submit the following comments in response to the Public review period for the Coral
Mountain Resort Draft Environmental Impact Report. The Coachella Valley Water district (CVWD) received
noticed that the 45 -day public review period would begin on June 22, 2021 and end on August 6, 2021.
CVWD has the following comments for your consideration in the document.
Location
Comment
Page 3-5
Draft EIR states "CVWD Levees". Please correct to "USBR Levees."
General
Project is adjacent to USBR lands managed by CVWD; any impacts to these
lands will require CVWD's review.
Page 1 of 2
General I The project's footprint is within CVWD's irrigation lateral system. Project will
require review by CVWD.
Sincerely,
William Patterson
Environmental Supervisor
Environmental Services Department
Coachella Valley Water District
75-519 Hovley Lane East
Palm Desert, CA 92211
(760) 398-2651
Page 2 of 2
CENTER for BIOLOGICAL DIVERSITY Because life rsgood.
August 6, 2021
Sent via email
Nicole Sauviat Criste, Consulting Planner
City of La Quinta,
78-495 Calle Tampico,
La Quinta, CA 92253
consultingplanner@laquintaca.gov
Re: Comments on Coral Mountain Resort Draft EIR SCH# 2021020310
Dear Ms. Sauviat Criste:
These comments are submitted on behalf of the Center for Biological Diversity (the
"Center") regarding the Coral Mountain Resort Draft Environmental Impact Report (DEIR)
drafted and released by the City of La Quinta (the "City"). The Center has reviewed the Coral
Mountain Resort (the "Project") DEIR closely and is concerned that the DEIR fails to adequately
assess the Project's impacts on biological resources and water supply, among other impacts. The
Center urges the City to address the deficiencies identified in this letter and recirculate a new
DEIR for public comment prior to preparing a final EIR for the Project.
The Center is a non-profit, public interest environmental organization dedicated to the
protection of native species and their habitats through science, policy, and environmental law.
The Center has over 1.7 million members and online activists throughout California and the
United States. The Center has worked for many years to protect imperiled plants and wildlife,
open space, air and water quality, and overall quality of life for people in and around La Quinta.
CEQA and the CEQA Guidelines impose numerous requirements on public agencies
proposing to approve or carry out projects. Among other things, CEQA mandates that significant
environmental effects be avoided or substantially lessened where feasible. (Pub. Res. Code §
21002; CEQA Guidelines §§ 15002(a)(3), 15021(a)(2), 15126(d).) Unfortunately, the DEIR for
the Project fails to comply with CEQA and the CEQA Guidelines in numerous respects
I. Biological Issues
While we recognize that the project area is within the "take" boundary of the Coachella
Valley Multiple Species Habitat Conservation Plan, concerns still remain about the absence of
mechanisms to prevent Peninsular bighorn sheep from being attracted to the wave pool feature
and non-native plantings. We also have concerns about the night lighting as described below.
A. Peninsular Bighorn Sheep
The Center has worked for years trying to protect and recover the Peninsular bighorn
sheep, a federally endangered species protected under the federal Endangered Species Act and
state -listed and fully protected species under State law. Nearby projects in La Quinta have been
responsible for numerous Peninsular bighorn sheep deaths (Hurt 2016). At the city -owned
SilverRock golf course, fences have been erected to preclude bighorn from coming onto the golf
course and associated facilities, helping to keep bighorn out of harm's way (KESQ News Team
2019). The U.S. Fish and Wildlife Service's Peninsular Bighorn Sheep Recovery Plan (2000)
recommends the following measures be implemented to help in the recovery of Peninsular
bighorn, which is particularly important in the La Quinta area where mortalities of bighorn
continue.
1.2.1.1 Construct fences to exclude bighorn sheep from urban areas where they
have begun or may begin using urban sources of food and water. Fences serve
several functions including: (1) separating bighorn sheep from potential threats of
urbanization (e.g., toxic plants, parasites, accidents, vector-borne diseases, traffic,
herbicides, pesticides, behavioral habituation), (2) controlling human and pet
access to remaining bighorn sheep habitat, (3) preventing bighorn sheep from
becoming habituated to and dependent upon artificial sources of food and water,
and (4) modifying habituated behaviors and redirection into remaining native
habitat. In the northern Santa Rosa Mountains, ongoing coordination with cities
and landowners on a regional fencing strategy will be critical to the long-term
health and maintenance of this ewe group... cooperation by residential
landowners will be critical to the success of excluding the northern Santa Rosa
Mountains ewe group from urban habitats. Along the remainder of the urban
interface, where sheep have not yet shown indications of habituation to human
habitats, future behavioral habituation also may occur. Although fencing may be
viewed as a last resort to other potential forms of aversive conditioning, prudent
planning dictates that mitigation be required to offset the likelihood of future
adverse effects (behavioral habituation and increased mortality rates) when new
projects are approved along the urban interface. Though actual fence construction
could be contingent upon future use by sheep and the ineffectiveness of other
potential deterrents, the wherewithal, responsibilities, and easements for fences
should be determined and secured at the time of project approval. (emphasis
added) Fences should be 2.4 meters (8 feet) high, or functionally equivalent, and
should not contain gaps in which bighorn sheep can be entangled. Gaps should be
l lcentimeters (4.3 inches) or less. This fence design should only be used at the
urban interface."
1.2.1.2 Avoid non-native vegetation along unfenced habitat interfaces where it
may attract or concentrate bighorn sheep. Along fenced sections of the urban
interface,
ornamental and toxic plants should not extend over or through fences where they
may be accessible to browsing bighorn sheep.
August 6, 2021
Page 2
1.2.1.4 Prohibit the use of any known toxic plants where they may be accessible to
bighorn sheep or potentially invade bighorn sheep habitat. A list of known toxic
plants
should be provided to all developers, landscapers, and homeowners.
1.2.1.5 Discourage the use of plants known to invade and degrade bighorn sheep
habitat (e.g., tamarisk, fountain grass).
1.2.1.6 Prohibit intentional enticement of bighorn sheep onto private property.
This item includes, but is not limited to, vegetation, mineral licks, or unfenced
swimming pools, ponds, or fountains upon which bighorn sheep may become
dependent for water.
1.2.1.9 Prohibit the construction of water bodies in developed areas adjoining
sheep habitat that may promote the breeding of midges (Culicoides sp) and
monitor/control vectors in existing problematic ponds. Water features should be
designed to eliminate blue -tongue and other vector-borne diseases by providing
deeper water (over 0.9 meters [3 feet]), steeper slopes (greater than 30 degrees),
and if possible, rapidly fluctuating water levels (see Mullens 1989, Mullens and
Rodriquez 1990). Landowners and managers should coordinate with local
mosquito and vector control districts to ensure management of existing water
bodies that harbor vector species.
1.2.1.10 Discourage the artificial feeding of coyotes because of the potential for
increasing predator abundance and consequent predation on bighorn sheep.
USFWS at 80-83.
We request that these recommendations be incorporated into the conditions for approval for this
proposed project.
B. Light Study Needed in DEIR Review
While Mitigation Measure BIO -4 requires a Light Study to be performed in the future in
order to evaluate how the proposed lighting plan will affect Coral Mountain, this type of study
should have been provided in the DEIR. The detrimental effects of artificial night lighting on
wildlife are scientifically well documented (Longcore and Rich 2004, Gaston et al. 2013, Gaston
and Bennie 2014). While the proposed shielded lighting is likely to be helpful to offset impacts,
until the Light Study is actually implemented and the results are identified, it may be insufficient
to offset impacts to the plants and animals that reside on Coral Mountain. The results of the Light
Study should be included in a revised DEIR for public review.
August 6, 2021
Page 3
II. The DEIR's Analysis of Water Supply Impacts is Inadequate
California, and much of the western United States, is suffering the effects of a historic
drought, the end of which is not predicted any time soon. The majority of Riverside County is
experiencing either "severe", or "extreme" drought conditions, with a small portion in the most
dire, "exceptional" drought category. (U.S. Drought Monitor.) As the frequency and intensity of
droughts in California increase due to climate change, it is critical that land use decision-making
be made based on robust and thorough water supply analyses. Unfortunately, the DEIR
completely ignores the reality in which the proposed Project would operate, and fails to include a
legally adequate discussion of the Projects demand for water, the available supply, nor the
environmental consequences of providing the needed supply.
A. The DEIR's Presentation of Project Water Demand is Misleading
The DEIR attempts to frame the Project's water use as an improvement compared to what
could be used under different plans for the site. It's a false comparison that distracts from the
Project's astronomically high per capita water use. The DEIR presents the Project's water use in
comparison to uses approved under the current Specific Plan, which would use a total of 1,058.4
acre-feet per year ("AFY"), compared with the Project's water demand of 958.63 AFY. (DEIR at
4.15-28-29.) The Project site is currently undeveloped (DEIR at 3-5), and not currently receiving
any water from the Coachella Valley Water District ("CVWD"), who will serve the Project. The
DEIR must describe the Project's existing conditions so that the public and decision -makers are
adequately informed of the impacts of supplying this Project with water. (See Woodward Park
Homeowners Assn., Inc. v. City of Fresno (2007) 150 Cal.App.4th 683, 709-10 ["[i]n assessing
the impacts of a project proposed for an undeveloped piece of property, agencies should compare
project impacts against the existing environment, rather than some hypothetical, impacted future
environment that might occur without the project under existing general plan and/or zoning
designations" (internal quotations omitted)].) The Project is a standalone land use proposal for a
site that is not developed, the water supply impacts of the Project must be presented as such,
without any misleading comparisons to irrelevant preexisting land use designations. A wave park
may be a more conservative use of water compared to a hypothetical golf course, but a wave
park where once was parched desert earth is a different consideration all together.
The DEIR fails to adequately describe the Project's water use in terms of per capita use.
The DEIR notes that CVWD's per capita use is dropping so that in 2015 users within the CVWD
service area used 383 gallons per day per capita ("gpdc"). (DEIR at 4.15-30.) As a threshold
matter, this is an astonishing amount of water use, especially compared to the statewide average
in 2016 of 85 gpdc.' After noting CVWD's purportedly positive achievement of recent
reductions meaning per capita use is now only 4 times the state average of water per person, the
DEIR fails to disclose what the Project's per capita water use will be. Instead, the DEIR presents
the Project's water use in terms of AF/acre, without any explanation of why this metric is used,
or what an acceptable threshold is compared to other development within CVWD's service area.
1 Legislative Analyst's Office, Residential Water Use Trends and Implications for Conservation Policy, available at:
https://lao.ca.gov/Publications/Report/3611, viewed 8/4/2021.
August 6, 2021
Page 4
(See DEIR at 4.15-31.) The Project would include 600 residential dwelling units, with 2.63
persons per units. (DEIR App. M [hereinafter "Water Supply Assessment (WSA)" at 21.) Should
the public presume that the Project's 958.63 AFY of use will be attributed to these 1,578 new
residents, such that per capita use is approximately 532 gpdc? The DEIR must be revised to
present the Project's per capita water use, and it must present this information using metrics
consistent with other CVWD planning documents so that the public and decision -makers can
properly judge the Project's water supply impacts.
B. The DEIR Fails to Assess the Environmental Impacts Associated
Providing Project Water
Beyond its muddled presentation of the Project's exceedingly high water demands, the
DEIR fails to address the impacts associated with acquiring the water supplies needed for the
Project and other users in the CVWD service area. CEQA requires lead agencies both to
demonstrate that an adequate water supply is available for the lifespan of a project, and to
analyze the environmental impacts associated with providing that supply. (See Vineyard Area
Citizens v. Rancho Cordova (2007) 40 Ca1.4th 412, 434.)
A majority of the high per capita use within the CVWD service area is supplied by
groundwater from the Indio Subbasin. (WSA at 29.) The Indio Subbasin has experienced
historical overdraft, which CVWD has been addressing with artificial recharge using imported
surface water supplies. (See WSA at 35.) The imported surface water used to replenish the
historically over -taxed groundwater basin comes from the Colorado River, with annual CVWD
diversions totaling more than 335,000 AF. (WSA at 41.) The WSA states that this supply will
increase in the future to well over 400,000 AFY, which will be used to meet increased demand
within the CVWD service area so that reliance on groundwater is lessened. (Id.) This discussion
ignores the reality that the Colorado River is in a state of crisis, with the major water supply
reservoirs at historically low levels. The level of Lake Mead has dropped to below the 1,075 feet
mean sea level ("feet msl") threshold where mandatory cuts to water sent to Arizona and Nevada
will occur.2 If the Lake Mead levels drop further, which is predicted to occur, California will see
its deliveries curtailed. The DEIR is silent when it comes to whether CVWD will be able to
receive its full allocation of Colorado River water into the future, nor does it address what
continued extraction to supplement CVWD's groundwater use will mean to the environment.
The DEIR creates further uncertainty to its future supply, and the impacts associated
therewith, when discussing the amount of State Water Project ("SWP") water it will import to
facilitate an exchange agreement with Metropolitan Water District ("MWD"). (WSA at 42-43.)
The projected SWP deliveries provided in the DEIR are misleading, as these totals represent
nothing more than "paper water" allocations, not what will actually be delivered. The DEIR only
lists the actual allocations up until 2018. (WSA at 43.) Table A allocation for 2020 was 20%, and
only 5% for 2021.3 Existing constraints on deliveries from the SWP will only increase as climate
2 U.S. Bureau of Reclamation, Lower Colorado River Operations, Lake Mead at Hoover Dam, end of months
elevation. Available at: https://www.usbr.gov/lc/region/g4000/hourly/mead-elv.html, viewed 8/4/2021.
3 California Department of Water Resources, Bulletin 132 Management of the California State Water Project.
available at: https://water.ca.gov/Programs/State-Water-Project/Management/Bulletin-132. Viewed 8/4/2021.
August 6, 2021
Page 5
change alters precipitation patterns and droughts intensify. The DEIR should properly recognize
this reality, and revise its discussion to present how much SWP is actually received by CVWD,
so that the public is adequately informed of the potential to serve the Project.
III. Conclusion
Given the possibility that the Center will be required to pursue appropriate legal remedies
in order to ensure enforcement of CEQA, we would like to remind the City of its duty to
maintain and preserve all documents and communications that may constitute part of the
"administrative record." As you may know, the administrative record encompasses any and all
documents and communications which relate to any and all actions taken by the City with
respect to the Project, and includes "pretty much everything that ever came near a proposed
[project] or [] the agency's compliance with CEQA ...." (County of Orange v. Superior Court
(2003) 113 Cal.App.4th 1, 8.) The administrative record further contains all correspondence,
emails, and text messages sent to or received by the City's representatives or employees, which
relate to the Project, including any correspondence, emails, and text messages sent between the
City's representatives or employees and the project proponent's representatives or employees.
Maintenance and preservation of the administrative record requires that, inter alia, the City (1)
suspend all data destruction policies; and (2) preserve all relevant hardware unless an exact
replica of each file is made.
Thank you for the opportunity to submit comments on the Draft Environmental Impact
Report for the proposed Coral Mountain Resort Project. The Center is deeply concerned by the
significant environmental and social impacts of the proposed Project. The DEIR fails to meet
CEQA's requirements for thorough, transparent and evidence -based environmental review, and
is thus legally deficient. We ask the City to address and correct the deficiencies we have
identified above and recirculate an updated Draft EIR for public review and comment.
Please add the Center to your notice list for all future updates to the Project and do not
hesitate to contact the Center with any questions at the number or email listed below.
Sincerely,
Ross Middlemiss
Staff Attorney
1212 Broadway, Suite #800
Oakland, CA 94612
rmiddlemiss@biologicaldiversity.org
Tel: (510) 844-7115
Page 6
August 6, 2021
Ileene Anderson
Senior Scientist/Public Lands Desert Director
Center for Biological Diversity
660 S. Figueroa St., Suite 1000
Los Angeles, CA 90017
ianderson@biologicaldiversity.org
(213) 785-5407
cc:
Brian Croft, USFWS, Brian_Croft@fws.gov
Leslie MacNair, CDFW Leslie.MacNair@,wildlife.ca.gov
Elizabeth Meyerhoff, CVWD emeyerhoff@cvwd.org
August 6, 2021
Page 7
References
Gaston, K.J., and J. Bennie 2014. Demographic effects of artificial nighttime lighting on animal
Populations. Environ. Rev. 22: 323-330
Gaston, K.J., J. Bennie, Davies, T.W. and J. Hopkins 2013. The ecological impacts of
nighttime light pollution: a mechanistic appraisal. Biol. Rev. 88: 912-927.
Hurt, S. (2016, September 27) Environmental groups to sue over endangered bighorn sheep
deaths. Press Enterprise. Available at: https://www.pe.com/2016/09/27/environmental-groups-
to-sue-over-endangered-bighorn-sheep-deaths/
https ://kesq.com/news/2019/08/22/more-fencing-possible-in-la-quinta-to-protect-bighorn-sheep/
KESQ News Team (2019, August 22) More fencing possible in La Quinta to protect bighorn
sheep. Available at https://kesq.com/news/2019/08/22/more-fencing-possible-in-la-quinta-to-
protect-bighorn-sheep/
Longcore, T. and K. Rich 2004. Ecological Light Pollution. Front Ecol Environ 2(4): 191-198
United States Drought Monitor, Current Map California. July 29, 2021.
U.S. Fish and Wildlife Service 2000. Recovery plan for bighorn sheep in the Peninsular Ranges,
California. U.S. Fish and Wildlife Service, Portland, OR. xv+251 pp. Available at
https://ecos.fws.gov/docs/recovery plan/001025.pdf
August 6, 2021
Page 8
Monday, August 9, 2021 at 08:30:11 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR - request for late submittal of comments
Date: Monday, August 9, 2021 at 8:25:32 AM Pacific Daylight Time
From: Pert, Heather@Wildlife
To: consultingplanner@laquintaca.gov
CC: Beck, Carly@Wildlife
Attachments: image001.png
Hello Nicole Sauviat Criste,
The California Department of Fish and Wildlife is requesting an extension to submit comments to 8/13/21 on
the draft EIR for Coral Mountain Resort DEIR. We had some staffing changes around the time of release for
this document and in combination with a heavy workload were not aware of the release of the draft EIR.
Our specific concerns are that the draft EIR does not adequately address the documented presence of
Peninsular bighorn sheep (PBS) on the project site, PBS are a California fully -protected species and a covered
species under the Coachella Valley Multiple Species Habitat Conservation Plan. The draft EIR states
"this species [Peninsular Bighorn Sheep] is not present at the site due to the absence of suitable habitat" (EIR
page 231), however, CDFW wildlife biologist have documented use of the area by PBS. It appears that CDFW
wildlife biologist were not consulted in preparation of the draft EIR. In addition, this project is adjacent to the
east side of the mountain (map on EIR page 16) where sheep are present. If the project moves forward,
CDFW recommends fencing around the property to keep both sheep and people in their respective areas.
However, our initial request is consultation with CDFW staff to discuss presence of PBS and develop
appropriate avoidance and minimization measures. Given the adjacency of the project site to PBS habitat,
avoidance and minimization measures should be included in the draft EIR that are consistent with the
Coachella Valley MSHCP.
We would appreciate additional time to provide a more detailed response.
Sincerely,
Heather
Recuthev-A. Pev't
Senior Environmental Scientist (Supervisor)
California Department of Fish and Wildlife
Inland Deserts Region
3602 Inland Empire Boulevard, Suite C-220
Ontario, CA 91764
858-395-9692
CALIFORNIA DEPARTMENT OF
FISH and WILDLIFE
**Please note that due to the COVID-19 Pandemic, I will be working remotely until further notice.**
Page 1 of 1
CALIFORNIA
DEPARTMENT OF
FISH &
WILDLIFE
State of California - Natural Resources Agency
CDFW OF FISH AND WILDLIFE
Inland Deserts Region
3602 Inland Empire Blvd., Suite C-220
Ontario, CA 91764
(909) 484-0459
www.wildlife.ca.gov
August 13, 2021
Sent via email
Nicole Sauviat Criste, Consulting Planner
City of La Quinta
78495 Calle Tampico
La Quinta, CA 92253
consultingplanner@laquintaca.gov
EDMUND G. BROWN, Jr., Governor
CHARLTON H. BONHAM, Director
Subject: Draft Environmental Impact Report Coral Mountain Resort
State Clearinghouse No. 2021020310
Dear Nicole Criste:
The California Department of Fish and Wildlife (CDFW) received and reviewed the Draft
Environmental Impact Report (DEIR) from the City of La Quinta for Coral Mountain Resort
(Project), State Clearinghouse No. 2021020310, pursuant the California Environmental Quality
Act (CEQA) statute and guidelines1. Thank you for the opportunity and extension of August 13,
2021 to provide comments and recommendations regarding those activities involved in the
Project that may affect California fish, wildlife, plants, and their habitats. Likewise, CDFW
appreciates the opportunity to provide comments regarding those aspects of the Project that
CDFW, by law, may need to exercise its own regulatory authority under the Fish and Game
Code (Fish & G. Code).
CDFW ROLE
CDFW is California's Trustee Agency for fish and wildlife resources and holds those resources
in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd. (a) & 1802;
Pub. Resources Code, § 21070; CEQA Guidelines § 15386, subd. (a)) CDFW, in its trustee
capacity, has jurisdiction over the conservation, protection, and management of fish, wildlife,
native plants, and habitat necessary for biologically sustainable populations of those species.
(Fish & G. Code, § 1802.) Similarly, for purposes of CEQA, CDFW provides, as available,
biological expertise during public agency environmental review efforts, focusing specifically on
Projects and related activities that have the potential to adversely affect fish and wildlife
resources.
10EQA is codified in the California Public Resources Code in section 21000 et seq. The "CEQA Guidelines"
are found in Title 14 of the California Code of Regulations, commencing with section 15000.
Conserving Cal fornia's Wildlife Since 1870
Draft Environmental Impact Report
Coral Mountain Resort
State Clearinghouse No. 2021020310
Page 2 of 24
CDFW may also act as a Responsible Agency regarding any discretionary actions under
CEQA (Pub. Resources Code, § 21069; CEQA Guidelines, § 15381), such as the issuance of
a Lake or Streambed Alteration Agreement (Fish & G. Code Sections 1600 et seq.), a
California Endangered Species Act (CESA) Permit for Incidental Take of Endangered,
Threatened, and/or Candidate species (Fish & G. Code Sections 2080 and 2080.1), and/or for
administering the Natural Community Conservation Planning Program (NCCP). CDFW also
administers the Native Plant Protection Act, Natural Community Conservation Program, and
other provisions of the Fish and Game Code that afford protection to California's fish and
wildlife resources.
CDFW issued Natural Community Conservation Plan Approval and Take Authorization in 2008
for the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP), as per
Section 2800, et seq., of the California Fish and Game Code. The CVMSHCP established a
multiple species conservation program to minimize and mitigate habitat loss and the Incidental
Take of Covered Species in association with activities covered under the permit. CDFW is
providing the following comments as they relate to the Project's consistency with the
CVMSHCP and the CEQA.
PROJECT DESCRIPTION SUMMARY
Project Location
The Project site encompasses an area of approximately 929 acres in the southeastern portion
of the City of La Quinta. The local area is characterized as a developing area with a number of
golf course and residential communities to the north, west, east, and southeast, the Santa
Rosa Mountains to the west and south, and open space and the Coachella Valley Water
District (CVWD) percolation ponds to the south. The Santa Rosa Mountains are to the west
and south and Coral Mountain is within the southwest portion of the Project property. The
approximately 386 -acre portion of the Project site, to be developed under SP 2020-0002, is
bounded by vacant land and Avenue 58 to the north; Madison Street to the east; residential
estates, vacant land, and the Avenue 60 alignment to the south; and Coral Mountain, and
vacant land to the west.
Project Description
The Project area consists of 929 acres in total. Of that, 543 acres occur on the east side of
Madison Street, and will continue to develop as provided under SP 03-067, as a residential
and golf country club. The western portion of the Project, on the west side of Madison Street,
proposes the development of the approximately 386 -acre area and is the focus of the DEIR.
This portion of the Project would be developed under a new Specific Plan (SP 2020-0002) with
up to 496 low density residential units on 232.3 acres; tourist and commercial land uses
including a resort hotel with up to 150 rooms, a 16.62 -acre recreational Wave Basin facility,
104 resort residential units, and 57,000 square feet of commercial development on
approximately 120.8 acres; 60,000 square feet of neighborhood commercial uses on
approximately 7.7 acres; and open space recreational uses on approximately 23.6 acres
adjacent to Coral Mountain.
Draft Environmental Impact Report
Coral Mountain Resort
State Clearinghouse No. 2021020310
Page 3 of 24
Within the 386 acres west of Madison Street, the Project also requests approval of General
Plan Amendment (GPA 2019-0002), Zone Change (ZC 2019-0004), Specific Plan Amendment
(SP 03-067), Specific Plan (SP 2020-0002), Tentative Tract Map (TTM 2019-0005), Site
Development Permit (SDP 2021-0001), and Development Agreement (DA 2021-0002), as
detailed below.
1. General Plan Amendment
The General Plan Amendment (GPA 2019-0002) will amend the current General Plan land
use designations from General Commercial, Low Density Residential, and Open Space —
Recreation to Neighborhood Commercial, Low Density Residential, Tourist Commercial,
and Open Space —Recreation.
2. Zone Change
The proposed Zone Change (ZC 2019-0004) will revise the existing zoning of the Specific
Plan Area from Neighborhood Commercial, Low Density Residential, and Golf Course, to
Neighborhood Commercial (CN), Low Density Residential (RL), Parks and Recreation
(PR), and Tourist Commercial (CT).
3. Specific Plan Amendment
The Specific Plan Amendment (Amendment V of Specific Plan 03-067) is being processed
to remove the area west of Madison Street from Specific Plan 03-067, thus, creating two
separate and distinct communities, "Coral Mountain Resort", west of Madison Street, and
"Andalusia Country Club", east of Madison Street. The Specific Plan Amendment will result
in only the deletion of the westerly 386 acres. No changes to land use designations,
densities or intensities, development standards or guidelines are proposed for the lands
east of Madison Street. It is expected that Andalusia will continue to build out under the
requirements of the SPA.
4. Specific Plan
Approval of the Coral Mountain Resort Specific Plan (SP 2020-0002) will establish a new
master plan governing the allowable land uses, design guidelines, and development
standards for the 386 -acre property west of Madison Street, to allow creation of a boutique
resort and master -planned community. The Project will result in a variety of land uses on
the westerly 386 acres, as shown in Exhibit 3-5 of the DEIR. Low Density Residential land
uses will occupy approximately 232.3 acres and result in a maximum of 496 dwelling units.
Tourist Commercial land uses will result in 104 dwelling units, 150 hotel rooms, and 57,000
square feet of private resort -serving commercial uses available to residents and hotel
guests, on approximately 120.8 acres. General Commercial land uses will occupy
approximately 7.7 acres, with up to 60,000 square feet of retail commercial uses available
to the general public. Open Space Recreation land uses will occur on approximately 23.6
acres in the southwest portion of the site.
The Project proposes four planning areas, identified as Planning Areas (PA) I, II, III, and IV, on
the 386 -acre property. PA I is designated for Neighborhood Commercial; PA II is designated
for Low Density Residential; PA III is designated for Tourist Commercial; and PA IV is
designated for open space Parks and Recreation located adjacent to Coral Mountain.
Draft Environmental Impact Report
Coral Mountain Resort
State Clearinghouse No. 2021020310
Page 4 of 24
COMMENTS AND RECOMMENDATIONS
CDFW's comments and recommendations on the DEIR are explained in greater detail below
and summarized here. CDFW has concerns regarding the completeness of the DEIR and finds
the conclusion in the DEIR that Peninsular bighorn sheep (PBS; Sheep; Ovis canadensis
nelsoni) are not on the Project site inaccurate, and the corresponding lack of avoidance and
minimization measures inadequate to protect fish and wildlife resources, specifically
Peninsular bighorn sheep. Specific comments include that there is: no discussion or analysis
that addresses the presence of sheep on and directly adjacent to the Project site; inadequate
avoidance and minimization measures for Peninsular bighorn sheep, burrowing owl, bats, and
nesting birds; questions about land ownership and adjacency to the Santa Rosa Mountains
Wildlife Area; and concerns about the adequacy and enforceability of mitigation measures
proposed by the City of La Quinta (the CEQA lead agency). CDFW is concerned that the DEIR
fails to adequately address Peninsular bighorn sheep and requests that the DEIR be revised
and recirculated pursuant to CEQA Guidelines §15088.5(a). The revised DEIR should include:
biological surveys to assess Peninsular bighorn sheep use of the site and the areas
immediately adjacent to the Project site; clear identification of any proposed avoidance and
minimization measures to avoid take of Peninsular bighorn sheep; discussion and analysis
based on documented sheep use of the Coral Mountain which demonstrates the reduction or
elimination of potential impacts; and discussion on land ownership for the Coral Mountain area,
specifically regarding Bureau of Land Management owned property; additional analysis of light
and noise -related impacts on Coral Mountain, among other items included in the discussion
below. Additional details on these comments are provided below.
Mitigation Measures for Project Impacts to Biological Resources
Coachella Valley MSHCP Implementation
The proposed Project occurs within the CVMSHCP area and is subject to the provisions and
policies of the CVMSHCP. To be considered a covered activity, Permittees need to
demonstrate that proposed actions are consistent with the CVMSHCP and its associated
Implementing Agreement. The City of La Quinta is the Lead Agency and is signatory to the
Implementing Agreement of the CVMSHCP. To demonstrate consistency with the CVMSHCP,
the DEIR should address, at a minimum, the City's obligations as follows:
a. Addressing the collection of fees as set forth in Section 8.5 of the CVMSHCP.
b. Demonstrating how the Project complies with the CVMSHCP requirements and
policies, including: 1) compliance with relevant processes to ensure application of
the Conservation Area requirements set forth in Section 4.0 of the CVMSHCP and
thus, satisfaction of the local acquisition obligation; 2) compliance with the applicable
Land Use Adjacency Guidelines set forth in Section 4.5 of the CVMSHCP; 3)
compliance with the Avoidance, Minimization and Mitigation Measures in Section 4.4
of the CVMSHCP; and 4) implementation consistent with the Species Conservation
Goals and Objectives in Section 9 of the CVMSHCP.
Draft Environmental Impact Report
Coral Mountain Resort
State Clearinghouse No. 2021020310
Page 5 of 24
Thus, CDFW would like to make a clarification to the following statement within the DEIR:
"The construction of the proposed project will change the physical environment of the project
site, which is currently vacant and undeveloped. The site is surrounded by development to the
north, east, and south, and vacant land to the north, west, and south. Although the proposed
project will result in the permanent loss of approximately 386 acres of vacant land, the project
will be required to pay fees to assure the off-site conservation of habitat lands for sensitive
species covered by the Coachella Valley Multiple Species Habitat Conservation Plan
(CVMSHCP). Therefore, the loss of biological resources will be less than significant with the
payment of fees to avoid impacts on special status species. Additionally, the project is required
to conduct burrowing owl, bat, and nesting bird surveys to determine whether roosting or
nesting is occurring at the site. If roosting or nesting is discovered at the project site during the
surveys, the mitigation measures include performance standards to ensure construction of the
project does not significant impact biological resources (see Section 4.3, Biological
Resources)."
This statement is inaccurate. Demonstrating implementation of the CVMSHCP is not simply
paying the required development fee; it requires demonstrating consistency with all the
CVMSHCP's requirements that provides a permittee's project with Take coverage through the
CVMSHCP for project impacts to Covered Species and covered natural communities classified
by the CVMSHCP as "adequately conserved" by the overall CVMSHCP. Please revise the
DEIR to include a complete analysis of how the City ensures the Project fully implements the
required terms and conditions of the CVMSHCP.
Peninsular Bighorn Sheep
The proposed Project occurs in or immediately adjacent to Essential Habitat for Peninsular
bighorn sheep (U.S. Fish and Wildlife Service, 2000) and has the potential to impact
Peninsular bighorn sheep, a federally endangered species (Fed. Register, Vol. 63, No. 52,
1998) and a State endangered and California Fully Protected species (Calif. Dep. Fish and
Game 1992), and a Covered Species under CVMSHCP. Fully Protected Mammals may not be
taken or possessed at any time and no licenses or permits may be issued for their Take except
for necessary scientific research, including efforts to recover fully protected species (Fish & G.
Code Section 4700). All Covered Activities of the CVMSHCP must avoid actions that will result
in violations of the fully protected species provisions (NCCP Permit # 2835-2008-001-06).
Take cannot be provided under the CVMSHCP for Peninsular bighorn sheep, however, CDFW
has acknowledged and agreed that if the measures set forth in the CVMSHCP are fully
complied with, the Covered Activities are not likely to result in Take of these species. It is
critical that to receive coverage for potential Take of Peninsular bighorn sheep habitat that the
Project properly implements the CVMSHCP. CDFW requests that the DEIR is modified to
include a discussion of State Fully Protected Mammals which should clearly state that no Take
is allowed of Peninsular bighorn sheep including under the CVMSHCP.
The proposed Project occurs in Essential Habitat for Peninsular bighorn sheep (U.S. Fish and
Wildlife Service, 2000) and has the potential to impact Peninsular bighorn sheep, a federally
Draft Environmental Impact Report
Coral Mountain Resort
State Clearinghouse No. 2021020310
Page 6 of 24
endangered species (Fed. Register, Vol. 63, No. 52, 1998) and a State endangered and
California Fully Protected species (Calif. Dep. Fish and Game 1992), and a Covered Species
under CVMSHCP. The DEIR incorrectly identifies that "this species [PBS] is not present at the
site due to the absence of suitable habitat" (page 231). This statement is inaccurate. CDFW
has monitored PBS movement in the Santa Rosa and Santa Jacinto mountains since 2009
with GPS collars and direct observation. CDFW's GPS data documents current and historic
sheep use of Coral Mountain (Figure 1; CDFW 2020).
•
•r
• of
i
• •
&a .. 6.1 N n�. o.mA. Inw..i;. ' fi rcaa . oEe 66. LAO& NO. NAL as r . r,.obere. KW.
Kir
L. P L. PE'✓be w+we- ex..; m; I.ETf. EwY Cnrr'l7 W Mop). 1.4.04•444•110.•• unitrdaa..ro
H 315 U.r Cer.nrr ry
• Historical Peninsular Bighorn Sheep GPS Data- Coral Mountain
0 33 06
7.2 Miles
Figure 1. Historical Peninsular Bighorn Sheep Use of Project Site and Surrounding Area.
CDFW research on sheep movement, based on GPS data and direct observation, shows a
trend of ewes spending a greater portion of their time in low -elevation habitat particularly
during the Iamb -rearing season (CDFW 2020). This temporal shift to lower elevations may be a
response to long-term drought conditions. Alluvial fans and washes, where more productive
soils support greater plant growth than steeper, rockier soils, tend to have more concentrated,
nutritious forage (US Fish and Wildlife Service 2000). Following lambing, ewes have high
energy needs for lactation and the time -period surrounding lambing and nursing is very
demanding in terms of the energy and protein required by bighorn ewes. A wide range of
forage resources and vegetation associations is needed to meet annual and drought related
Draft Environmental Impact Report
Coral Mountain Resort
State Clearinghouse No. 2021020310
Page 7 of 24
variations in forage quality and availability. Lower elevation habitat can include alluvial fans,
washes, and desert flats that provide more abundant and high-quality vegetation, such as
water -rich cactus, than steeper terrain, and are crucial to the viability of bighorn sheep
populations during times of drought (FWS 2000), and provide an important source of nutrition
and water during lactation (Hansen and Deming 1980) and Iamb -rearing (Hines 2019).
CDFW is concerned that the proposed development will introduce forage and water sources
that will attract rams, ewes, and Iambs, where they may become at risk to injury and death
from drowning in swimming pools, toxic plants poisoning, vehicle strikes, the effects of
ingesting intestinal parasites present among watered lawns and grasses, and other potential
urban hazards. In the City of La Quinta, existing developments (including SilverRock, PGA
West, and The Quarry at La Quinta) along the wildland-urban interface have become attractive
nuisances for sheep because of artificial features that attract sheep, for example grass and
artificial water sources. This results in sheep habituated to urban environments, and can lead
to increased mortality risk through transmission of disease, ingestion of toxic materials, vehicle
strikes, and drowning in artificial water sources. These developments are adjacent to
Peninsular bighorn sheep habitat in the Santa Rosa and San Jacinto Mountains Conservation
Area of the CVMSHCP. As a result of these issues, the MSHCP requirement for building a
fence at this interface was triggered and the City of La Quinta is currently working with the
Coachella Valley Conservation Commission to build a sheep fence. CDFW is concerned that
this Project will create similar conditions and become an attractive nuisance to sheep that
currently use Coral Mountain. Further, once the fence is built to exclude sheep in other areas
of La Quinta the sheep may migrate to this Project site if it has attractive features. The revised
DEIR should identify and implement specific measures, such as fencing, to keep sheep out of
urban areas and prevent trespass of humans and domestic animals into adjacent sheep
habitat.
Prior to the adoption of the DEIR, CDFW requests completion surveys and a habitat use
assessment of Peninsular bighorn sheep, a California Fully Protected Species (Fish and Game
Code § 3511), located within the Project footprint and within offsite areas with the potential to
be affected. The surveys and assessment should address seasonal variations in use of the
Project area. Focused species-specific surveys, completed by a qualified biologist and
conducted at the appropriate time of year and time of day when the sensitive species are
active or otherwise identifiable, are required. Acceptable species-specific survey procedures
should be developed in consultation with CDFW and the U.S. Fish and Wildlife Service. Note
that CDFW generally considers biological field assessments for wildlife to be valid for a one-
year period, and assessments for rare plants to be valid for a period of up to three years.
Some aspects of the proposed Project may warrant periodic updated surveys for certain
sensitive taxa, particularly if the Project is proposed to occur over a protracted time frame, or in
phases, or if surveys are completed during periods of drought.
Survey information and results in coordination with CDFW staff should be used to develop
avoidance and minimization measures to avoid Take of Peninsular bighorn sheep. Based on
the survey results and historic use of the Project site, Project modifications may be required to
avoid Take of sheep.
Draft Environmental Impact Report
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Recreational Effects on Peninsular Bighorn Sheep
CDFW is concerned that the impacts of the increased human activity on Peninsular bighorn
sheep and other sensitive resources was not adequately addressed in the DEIR. The DEIR
assumes no presence of Peninsular bighorn sheep and therefore does not address edge
effects on Essential Habitat for Peninsular bighorn sheep. In the CVMSHCP, Species
Objective 1d for Peninsular bighorn sheep is "Ensure that any Development allowed does not
fragment Essential Habitat, and that edge effects from such Development are minimized." The
Project is adjacent to Essential Habitat and the Santa Rosa Mountains Habitat Wildlife Area.
Addressing edge effects is a CVMSHCP requirement that has not been adequately addressed
and therefore the Permittee has not ensured that the Project demonstrates compliance with
the CVMSHCP.
The CEQA document describes Plan Area IV as 23.6 acres of natural open space for low -
impact active and passive recreational activities, including hiking, biking and rope and zipline
courses. This open space area is located adjacent to Coral Mountain, which has rock outcrops
known to be used as roosting habitat for several species of bats. Coral Mountain is also known
to be used by Peninsular bighorn sheep. Limited details are provided in the CEQA document
on the types and locations of proposed recreational infrastructure, e.g., multi -use trails,
restroom facilities, trail and other recreational lightning, etc., or the permitted recreational uses
within the open space areas, and enforcement plans.
Unauthorized public recreational use off trails by people, bikes, and dogs in sheep habitat
within the Santa Rosa mountains may impact sheep use of the habitat. The current lack of
enforcement of trail use and trail development in the adjacent conservation areas is creating
undesirable conditions for the Peninsular bighorn sheep (Colby and Botta 2016). Potential
issues include startling of ewes and Iambs foraging in washes by mountain bikes; off -leash
dogs and dogs in areas that don't allow dogs potentially chasing and harassing sheep; and
creation of unauthorized trespass trails by user groups that intrude into sensitive sheep habitat.
While some recreationists observe the trail rules and keep their dogs on leash, many people
are observed not complying with the trail use regulations. The Project should provide clear
measures to avoid contributing to trespass issues and ensure a safe environment for PBS.
CDFW recommends that inclusion of biological mitigation measures for sheep that identify
funding and resources for enforcing trail use rules which could include signage, enforcement,
public education, and removal of unauthorized trails.
Most of these measures will require enforcement to ensure they are enacted and properly
followed throughout the life of the Project. The trails, rope courses, and zipline may create an
easy and tempting access point for the residents into the open space areas. Without
enforcement of trail use rules within the Project's open space the adjacent habitat, Coral
Mountain could become saturated with unauthorized trails. Measures such as leash laws,
Covenants, Conditions and Restriction for invasive plants and pets, trail regulations, and
fencing requirements require constant enforcement.
CDFW requests that the City revise and recirculate the DEIR to analyze impacts to sheep,
burrowing owl, and bats prior to Project implementation and final approval. The level of
Draft Environmental Impact Report
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significance should be revised from "Less than significant" to "Significant" for biological
resources unless the City provides adequate analysis to the contrary. The Lead agency must
commit itself to mitigation and either adopt performance standard for future approval or
analyze alternatives in detail. The strategy for identifying and evaluating the mitigation should
be identified and in place before the Project is initiated.
The revised DEIR should provide clear details on recreational infrastructure and permitted
recreational activities; control of access to areas outside of the development; and enforcement
methods to ensure trespass, lighting, and noise does not affect adjacent sheep and bat
roosting habitat. The revised DEIR should identify who will be responsible for this enforcement
and funding to support enforcement of the land use adjacency mitigation measures to ensure
they are properly implemented throughout the life of the project. The CVMSHCP identifies a
simple barrier fence as a mitigation concept to separate PBS from lethal threats in urban
environments. We request coordination with CDFW to identify suitable locations for trails and
fencing surrounding the property, to keep both sheep and people in their respective areas.
CDFW further requests that the City add a mitigation measure for fencing along the boundaries
of the property accessible to sheep to minimize potential impacts to PBS from the project
development.
The Recovery Plan for Peninsular Bighorn Sheep identifies that fences should be constructed
to exclude bighorn sheep from urban areas where they may begin using urban sources of food
and water. Fences serve several functions including: "(1) separating bighorn sheep from
potential threats of urbanization (e.g., toxic plants, parasites, accidents, vector-borne diseases,
traffic, herbicides, pesticides, behavioral habituation), (2) controlling human and pet access to
remaining bighorn sheep habitat, (3) preventing bighorn sheep from becoming habituated to
and dependent upon artificial sources of food and water, and (4) modifying habituated
behaviors and redirection into remaining native habitat. Although fencing may be viewed as a
last resort to other potential forms of aversive conditioning, prudent planning dictates that
mitigation be required to offset the likelihood of future adverse effects (behavioral habituation
and increased mortality rates) when new projects are approved along the urban interface.
Though actual fence construction could be contingent upon future use by sheep and the
ineffectiveness of other potential deterrents, the wherewithal, responsibilities, and easements
for fences should be determined and secured at the time of project approval". CDFW requests
the incorporation of the following measures to help protect bighorn sheep from development
effects:
BIO -[XX]: Project activities and infrastructure should be designed to avoid Take of
Peninsular bighorn sheep, a State fully protected species, which has the potential to
be present within or adjacent to the Project area. Peninsular bighorn sheep use
Coral Mountain and the surrounding conserved habitat within the Santa Rosa
Wildlife Area for roaming, foraging, and lambing. To ensure no Incidental Take of
Peninsular bighorn sheep, the following measures are required:
1. A biological survey and assessment of year-round habitat use by Peninsular
sheep will be conducted by a qualified biologist, pre -approved by CDFW, prior to
Project approval.
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2. All recreational infrastructure and activities such as trails, rope courses, and
zipline(s) shall be contained within the development footprint. Trails and other
recreational activities will not lead into or encourage use of adjacent natural
areas.
3. No plant species toxic to bighorn sheep, such as oleander (Nerium oleander),
lantana (Lantana sp.) and laurel cherry (Prunus sp.), shall be used for
landscaping within or around the development. Control and do not plant non-
native vegetation, including grass, in the development where it may attract or
concentrate bighorn sheep or invade and degrade bighorn sheep habitat (e.g.,
tamarisk, fountain grass). Use native vegetation in the development landscaping.
Along fenced sections of the urban interface, ornamental and toxic plants should
not extend over or through fences where they may be accessible to browsing
bighorn sheep. The Project will use Table 4-112: Coachella Valley Native Plants
Recommended for Landscaping of the CVMSHCP as guidance on a landscaping
planting palette.
4. To prevent sheep from entering the Project site or human intrusion into sheep
habitat, fences will be placed along the western boundary of PA II and PA III
including III -G (DEIR Exhibit 1.2, pg. 1-8), and PA IV; and the southern edge of PA
II, PA III, and PA IV development site (Figure 2). A fencing plan and further
avoidance and minimization measure shall be developed in coordination with the
Wildlife Agencies. Fences should be functionally equivalent or better than fencing
designs in the Recovery Plan, which are describes as 2.4 meters (8 feet) high and
should not contain gaps in which bighorn sheep can be entangled. Gaps should
be 11 centimeters (4.3 inches) or less.
5. Intentional enticement of bighorn sheep onto private property shall be prohibited
and enforced using fines if necessary, including vegetation, mineral licks, or
unfenced swimming pools, ponds, or fountains upon which bighorn sheep may
become dependent for water.
6. Construction of water bodies that may promote the breeding of midges
(Culicoides sp.) shall be prohibited. Water features should be designed to
eliminate blue -tongue and other vector-borne diseases by providing deeper water
(over 0.9 meters [3 feet]), steeper slopes (greater than 30 degrees), and if
possible, rapidly fluctuating water levels, or other current best practices. As
needed, coordinate with local mosquito and vector control district to ensure
management of existing water bodies that may harbor vector species.
7. An educational program about the Peninsular bighorn sheep and their associated
habitat shall be implemented and maintained throughout the resort, open space,
and low-density community programs through the use of signage, pamphlets,
and staff education. The Education Program should inform the reason of why
specific measures are being taken to support recovery of Peninsular bighorn
sheep. The Education Program should include the ecology of Peninsular bighorn
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sheep, what threats this species is currently facing, and how recovery actions will
reduce these threats. This includes information that explains: (1) why restrictions
on toxic plants, fences, and pesticides are needed; (2) how artificial feeding of
coyotes could adversely affect bighorn sheep; and (3) how recreational activities
may affect sheep. The use of interpretive signs is encouraged.
8. Ensure funding for implementation, enforcement, and effectiveness assessment
of the above measures, for the life of the development, to help ensure protection
of sheep and to prevent trespass from the Project site into adjacent sheep habitat
Figure 2. Proposed Sheep fencing plan shown in blue outline on the edge of Project site.
Fuel Modification
The DEIR states that the Project is not within an area mapped as "very high, high, or
moderate fire hazard severity zones, therefore, no impacts are anticipated" by the
development. While CDFW recognizes that the area is not classified as being within a fire
hazard area, we are concerned that the Project's design puts an additional burden on public
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lands to operate as defensible space rather than include the defensible space within the
development footprint. According to Public Resource Code 4291 the development should
include a minimum of 100 feet of defensible space within the development footprint.
Additionally, County of Riverside Ordinance NO. 695, Section 3, states that:
"(1) a one hundred (100) foot wide strip of land at the boundary of an unimproved
parcel adjacent to a roadway; and/or
(2) a one hundred (100) foot wide strip of land around structure(s) located on an
adjacent improved parcel (some or all of this clearance may be required on the
unimproved parcel depending upon the location of the structure on the improved
parcel).
The County Fire Chief or his or her designee may require more than a one hundred
(100) foot width or less than a one hundred (100) foot width for the protection of public
health, safety or welfare or the environment."
As development increases within the area near or adjacent to conservation or public natural
lands, the risk of wildfire increases and the need for defensible space rises. Additionally,
climate change has increased the frequency and duration in which wildfire season occurs (Li
and Banerjee, 2021). As the climate continues to change and development continues to
encroach upon natural resources, wildfires will continue to increase even in areas not
designated as high fire risk. Thus, CDFW requests the incorporation of the following measure
to help protect natural resources on public open space and conservation lands from
development effects:
BIO -[XX]: With respect to defensible space and impacts to biological
resources, the Project shall consult with the Riverside County Fire Department
and fully describe and identify the location, acreage, and composition of
defensible space within the proposed Project footprint. Base on the consultation
the Project shall be designed so that impacts associated with defensible space
(fuel modification, fire breaks, etc.) shall not be transferred to adjacent open
space or conservation lands.
Burrowing Owls
A project -specific biology report in the DEIR identifies suitable burrowing habitat within the
Project area. To increase the probability of detecting burrows occupied by burrowing owls,
multiple surveys should be conducted depending on the proposed start of construction
activities and how it coincides with the burrowing owl breeding or non -breeding seasons. To
minimize the chance of Project activities resulting in Take of nesting burrowing owls, CDFW
recommends that the City revise MM BIO -1 and condition the measure to include the following
(edits are in bold and ctrikcthrough):
BIO -1: A bBurrowing owl clearance surveys shall be performed by a qualified biologist,
pre -approved by the California Department of Fish and Wildlife, not more than 30
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clays prior to any site disturbance activities - . - : _ .: - - , - - - - A
minimum of two surveys, occurring at least three weeks apart, shall be completed
in advance of any site disturbance activities. If disturbance activities are expected
to start during the burrowing owl breeding season, three surveys shall be
completed. The final burrowing owl survey shall be completed within three days
prior to initiation of any site disturbance activities. The pre -construction survey
shall be conducted following guidelines in the CDFW 2012, Staff Report on
Burrowing Owl Mitigation. is required to use accepted protocol (as determined
CDFW). Prior to construction, a qualified biologist will survey the construction area and
an area up to 500 feet 150 meters outside the Project limits for burrows that could be
used by burrowing owls. If the burrow is determined to be occupied, the burrow will be
flagged, and a 160 foot 200 -meter diameter buffer will be established during non -
breeding season or a 250 foot 500 -meter diameter buffer during the breeding season.
The buffer area will be staked and flagged. A list of avoidance and minimization
measures such as, but not limited to, the use of hay bales, daily biological
monitoring, and trail cameras shall be provided to CDFW for review prior to any
ground disturbance. No development activities will be permitted within the buffer until
the young are no longer dependent on the burrow and have left the burrow. For# the
burrows isfound to be unoccupied, the qualified biologist will coordinate with
CDFW on the methods to make the burrows will be mads inaccessible to owls, and
construction may proceed. If either a nesting or escape burrow is occupied and
impacts to the owl(s) cannot be avoided, a Burrowing Owl Relocation Plan will be
developed and reviewed by the Wildlife Agencies prior to the relocation of owls.
owls shall be relocated pursuant to accepted Wildlifc Agency protocols. Determination
of the appropriate method of relocation, such as eviction/passive relocation or active
relocation, shall be based on the specific site conditions (e.g., distance to nearest
suitable habitat and presence of burrow within that habitat) in coordination with the
Wildlife Agencies. If burrowing owls are observed with the Project site during
construction activities, CDFW shall be notified immediately and provided with
proposed avoidance and minimization measures for CDFW to review.
Nesting Birds
Regarding the protection of nesting birds, it is the Project proponent's responsibility to avoid
Take of all nesting birds. The timing of birds starting and finishing nesting activities is variable
from year to year based on the species, rainfall conditions, shifts in local climate conditions,
and other factors. CDFW recommends that qualified biologist(s) are pre -approved by CDFW to
confirm they have the experience necessary to fulfill their biological monitoring responsibilities.
Additionally, biological monitoring activities are required for the duration of construction
activities. CDFW recommends that at minimum, the City revise MM BIO -6 and conditions the
Project to include the following (edits are in bold and strikethrough):
BIO -6: To ensure compliance with California Fish and Game Code and the MBTA and
to avoid potential impacts to nesting birds, vegetation removal and ground -disturbing
activities shall be conducted outside the general bird nesting season {January 15
through August 31). Any vegetation removal, ground disturbance, and/or construction
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activities that occur during the nesting season will require that all suitable habitats be
thoroughly surveyed for the presence of nesting birds by a qualified biologist that is
pre -approved by CDFW. Prior to commencement of clearing, a qualified biologist shall
conduct preconstruction surveys within 14 days and repeated 3 days prior to ground
disturbing activities. If any active nests are detected, a buffer of 300 feet (500 feet for
raptors) around the nest adjacent to construction will be delineated, flagged, and
avoided until the nesting cycle is complete. The buffer may be modified and/or other
recommendations proposed as determined appropriate by the biologist to minimize
impacts. During construction activities, the qualified biologist shall continue
biological monitoring activities at a frequency recommended by the qualified
biologist using their best professional judgment, or as otherwise directed by the
Wildlife Agencies. If nesting birds are detected, avoidance and minimization
measures may be adjusted and construction activities stopped or redirected by
the qualified biologist using their best professional judgement as otherwise
directed by the Wildlife Agencies to avoid Take of nesting birds.
Noise
The noise study in the CEQA document identifies a significant noise threshold of 85 dBH and
finds that noise levels associated with the construction and operations of the Project would be
close to, but not exceed, the noise threshold. CDFW requests the incorporation of the
following measure to help protect wildlife from development impacts:
BIO -[XX]: To reduce noise -related impacts to wildlife using Coral Mountain, the
Project shall continue taking noise level measurements during both Project
construction and post -construction operations to determine if noise levels
exceed thresholds outlined in the CEQA document and inform if additional
avoidance and minimization measures are required. To protect wildlife using
Coral Mountain, the noise threshold affecting this area shall be reduced to 75
dBA as determined appropriate in the Land Use Adjacency Guidelines in
CVMSHCP Section 4.5. If noise levels exceed this threshold, the Project shall
make changes to their operations and/or adopt other minimization measures to
reduce noise impacts below 75 dBA to minimize noise -related impacts on wildlife
using Coral Mountain.
Lighting
The CEQA document includes an analysis of lighting with a focus on impacts to aesthetics. A
significant source of artificial nighttime lighting with the potential to impact wildlife using Coral
Mountain (e.g., PBS, bats, etc.) comes from lighting associated with the Wave Basin, which
includes seventeen, 80 -foot -high light poles. Further, onsite lightning is planned within PA IV,
the open space area adjacent to Coral Mountain. Although the CEQA document indicates that
all lightning will be shielded and directed away from wildlife areas, CDFW recommends that
additional lightning analysis during Project construction and operations is needed to determine
that lightning impacts to wildlife using Coral Mountain will be less than significant. To
determine if artificial nighttime lighting associated with Project construction and operations will
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result in minimal to no glare (500 or less candela) to all areas of Coral Mountain, CDFW
recommends that lighting and glare impacts continue to be evaluated during both Project
construction and operations. CDFW requests the inclusion of the following new measures in
the DEIR:
BIO -[XX]: To reduce nighttime artificial lighting -related impacts to wildlife using
Coral Mountain, the Project shall continue taking lightning measurements during
both Project construction and post -construction operations to determine impacts
of nighttime artificial lightning on Coral Mountain and the wildlife it supports. To
protect wildlife using Coral Mountain, project construction and operations shall
result in no to minimal glare (500 or less candela) to all areas of Coral Mountain. If
light or glare impacts to Coral Mountain exceed this threshold, the Project shall
make changes to their operations and/or adopt landscape shielding, dimming,
lighting curfews or other appropriate measures that result in the Project causing
minimal to no glare to all areas of Coral Mountain.
Land Ownership
A portion of the property appears to be owned by the Bureau of Land Management (BLM) and
is a part of the Santa Rosa Mountains Wildlife Habitat Area which is jointly managed by BLM
and CDFW (BLM and CDFG 1980). This is an area having permanent protection from
conversion of natural land cover and a management plan for the preservation of the wildlife
resources and their habitats. The Santa Rosa Mountains Habitat Management Plan was
developed and implemented under the Sikes Act of October 18, 1974 (PL 93-452). Please
clarify in the DEIR if a portion of the Project is on or adjacent to the Santa Rosa Mountains
Wildlife Habitat Area, owned by BLM, and identify what mitigation measures will be
implemented to maintain the natural conditions of the area for wildlife resources. Please
provide information in the DEIR on any coordination with BLM and CDFW on use of the Project
site and how that may affect the Santa Rosa Mountains Wildlife Habitat Area.
State Regulatory Environment
In the State Regulatory Environment section (p. 4.3-3), the DEIR fails to identify state
regulations that are applicable to the Project including: Natural Community Conservation
Protection Act (Fish & G. Code Sections 2800 et seq.), Lake and Streambed Agreements (Fish
& G. Code Section 1600 et seq.); Fully Protected Species (Fish & G. Code Section 4700), and
CEQA. Please revise the DEIR to identify the above regulations and how they apply to this
Project.
Drought -tolerant Landscaping
California is experiencing one of the most severe droughts on record. To ameliorate the
water demands of this Project, CDFW recommends incorporation of water -wise concepts in
project landscape design plans. In particular, CDFW recommends xeriscaping with locally
native California species, and installing water -efficient and targeted irrigation systems (such
as drip irrigation). Local water agencies/districts, and resource conservation districts in your
area may be able to provide information on plant nurseries that carry locally native species,
Draft Environmental Impact Report
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State Clearinghouse No. 2021020310
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and some facilities display drought -tolerant locally native species demonstration gardens.
Information on drought -tolerant landscaping and water -efficient irrigation systems is
available on California's Save our Water website: http://saveourwater.com/what-you-can-
do/tips/landscaping/
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative
declarations be incorporated into a database which may be used to make subsequent or
supplemental environmental determinations (Pub. Resources Code, § 21003, subd. (e)).
Accordingly, please report any special -status species and natural communities detected during
Project surveys to the California Natural Diversity Database (CNDDB). The CNNDB field
survey form can be found at the following link:
https://www.wildlife.ca.gov/Data/CNDDB/Submitting-Data. The completed form can be
submitted online or mailed electronically to CNDDB at the following email address:
CNDDB@wildlife.ca.gov.
CDFW CONCLUSIONS AND FURTHER COORDINATION
CDFW appreciates the opportunity to comment on the Coral Mountain Resort Project to assist
in identifying and mitigating Project impacts on biological resources. Our review and analysis
of the DEIR identified a number of significant new Project impacts and provides corresponding
mitigation and minimization measures, as described above, which would clearly lessen
significant project impacts on the biological resources in the area. Therefore, CDFW requests
that the City of La Quinta revise and recirculate the DEIR, for disclosure to the public, once the
requested additional analyses have been prepared and the additional mitigation and
minimization measures have been added to the Project, and all of these substantial
modifications have been documented in the revised Draft EIR for review and comment by the
citizens of California and interested public agencies.
CDFW personnel are available for consultation regarding biological resources and strategies to
minimize impacts. We request a meeting to discuss our comments at your earliest
convenience. Questions regarding this letter or further coordination should be directed to Carly
Beck at carly.beck@wildlife.ca.gov.
Sincerely,
DocuSigned by:
DF423498814B441 _.
For
Scott Wilson
Environmental Program Manager
Draft Environmental Impact Report
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State Clearinghouse No. 2021020310
Page 17 of 24
ec:
Heather Pert, heather.pert@wildlife.ca.gov
Office of Planning and Research, State Clearinghouse, Sacramento
Rollie White, USFWS
Dani Ortiz, BLM
Literature Cited
BLM (U.S. Department of Interior Bureau of Land Management) and CDFG (State of California
Resources Agency Department of Fish and Game),1980. Santa Rosa Wildlife Habitat
Management Plan: A Sikes Act Project. The Santa Rosa Mountains Habitat Management
Plan was developed and will be implemented under the Sikes Act of October 18, 1974. (PL
93-452)
Colby, J., and R. Botta. 2016. Peninsular bighorn sheep annual report 2015. California CDFW
of Fish and Wildlife, South Coast Region.
htts://wiIdIife.ca.qov/Conservation/MammaIs/Biqhorn-
Sheep/Desert/Peninsular/Literature#31 2051 077 -annual -reports
Colby, J., and R. Botta. 2019. Peninsular bighorn sheep annual report 2019-2020. California
CDFW of Fish and Wildlife, South Coast Region.
https://wildlife.ca.gov/Conservation/Mammals/Bighorn-
Sheep/Desert/Peninsular/Literature#31 2051 077 -annual -reports
Hanson, C. G. and O.V. Deming 1980. Growth and Development. Pages 152-171 in G.
Monson and L. Sumner, eds. The desert bighorn: its life history, ecology, and management.
The University of Arizona Press, Tuscan, AZ
Hines, K. 2019. Post -Partum Habitat Use for Peninsular Bighorn Sheep (Ovis canadensis
nelson') in Southern California. (Unpublished master's thesis). California State University,
San Marcos.
Li, S., and T. Banerjee 2021. Spatial and temporal pattern of wildfires in California from 2000
to 2019. Scientific Reports. https://www.nature.com/articles/s41598-021-88131-9.pdf
U.S. Fish and Wildlife Service, 2000. Recovery Plan for Bighorn Sheep in the Peninsular
Ranges, California.
https://www.fws.gov/carlsbad/SpeciesStatusList/RP/20001025 RP PBS.pdf
ATTACHMENT 1
Mitigation Monitoring and Reporting Program for the City of La Quinta, Coral
Mountain Resort Project
Mitigation Measures
Timing and
Methods
Responsible
Parties
MM BIO -[XX]: Project activities and
Timing: Prior
Implementation:
infrastructure should be designed to avoid
to Project
City of La Quinta.
Take of Peninsular bighorn sheep, a State
Approval.
Monitoring and
fully protected species, which has the
Methods: See
Reporting: See
potential to be present within or adjacent to
Mitigation
Mitigation
the Project area. Peninsular bighorn sheep
Measures and
Measures and
use Coral Mountain and the surrounding
conserved habitat within the Santa Rosa
Sub -measures.
Sub -measures.
Wildlife Area for roaming, foraging, and
lambing. To ensure no Incidental Take of
Peninsular bighorn sheep, the following
measures are required:
1. A biological survey and assessment of
year-round habitat use by Peninsular sheep
will be conducted by a qualified biologist,
pre -approved by CDFW, prior to Project
approval.
2. All recreational infrastructure and
activities such as trails, rope courses, and
zipline(s) shall be contained within the
development footprint. Trails and other
recreational activities will not lead into or
encourage use of adjacent natural areas.
3. No plant species toxic to bighorn sheep,
such as oleander (Nerium oleander), lantana
(Lantana sp.) and laurel cherry (Prunus sp.),
shall be used for landscaping within or
around the development. Control and do not
plant non-native vegetation, including grass,
in the development where it may attract or
concentrate bighorn sheep or invade and
degrade bighorn sheep habitat (e.g.,
tamarisk, fountain grass). Use native
vegetation in the development landscaping.
Along fenced sections of the urban
interface, ornamental and toxic plants
should not extend over or through fences
where they may be accessible to browsing
bighorn sheep. The Project will use Table 4-
112: Coachella Valley Native Plants
Recommended for Landscaping of the
CVMSHCP as guidance on a landscaping
planting palette.
4. To prevent sheep from entering the
Project site or human intrusion into sheep
habitat, fences will be placed along the
western boundary of PA II and PA III
including III-G (DEIR Exhibit 1.2, pg. 1-8),
and PA IV; and the southern edge of PA II,
PA III, and PA IV development site (Figure 2).
A fencing plan and further avoidance and
minimization measure shall be developed in
coordination with the Wildlife Agencies.
Fences should be functionally equivalent or
better than fencing designs in the Recovery
Plan, which are describes as 2.4 meters (8
feet) high and should not contain gaps in
which bighorn sheep can be entangled.
Gaps should be 11 centimeters (4.3 inches)
or less.
5. Intentional enticement of bighorn sheep
onto private property shall be prohibited and
enforced using fines if necessary, including
vegetation, mineral licks, or unfenced
swimming pools, ponds, or fountains upon
which bighorn sheep may become
dependent for water.
6. Construction of water bodies that may
promote the breeding of midges (Culicoides
sp.) shall be prohibited. Water features
should be designed to eliminate blue-tongue
and other vector-borne diseases by
providing deeper water (over 0.9 meters [3
feet]), steeper slopes (greater than 30
degrees), and if possible, rapidly fluctuating
water levels, or other current best practices.
As needed, coordinate with local mosquito
and vector control district to ensure
management of existing water bodies that
may harbor vector species.
7. An educational program about the
Peninsular bighorn sheep and their
associated habitat shall be implemented and
maintained throughout the resort, open
space, and low-density community
programs through the use of signage,
pamphlets, and staff education. The
Education Program should inform the
reason of why specific measures are being
taken to support recovery of Peninsular
bighorn sheep. The Education Program
should include the ecology of Peninsular
bighorn sheep, what threats this species is
currently facing, and how recovery actions
will reduce these threats. This includes
information that explains: (1) why
restrictions on toxic plants, fences, and
pesticides are needed; (2) how artificial
feeding of coyotes could adversely affect
bighorn sheep; and (3) how recreational
activities may affect sheep. The use of
interpretive signs is encouraged.
8. Ensure funding for implementation,
enforcement, and effectiveness assessment
of the above measures, for the life of the
development, to help ensure protection of
sheep and to prevent trespass from the
Project site into adjacent sheep habitat.
MM BIO-[XX]: With respect to defensible
Timing: Prior
Implementation:
space and impacts to biological
to final plan
City of La Quinta.
resources, the Project shall consult with the
check, or
Monitoring and
Riverside County Fire Department and fully
equivalent.
Reporting: See
describe and identify the location, acreage,
and composition of defensible
Methods: See
Mitigation
Mitigation
Measure.
space within the proposed Project footprint.
Measure.
Based on the consultation the Project shall
be designed so that impacts associated with
defensible space (fuel modification, fire
breaks, etc.) shall not be transferred to
adjacent open space or conservation lands.
MM BIO-1: A bBurrowing owl clearance
surveys shall be performed by a qualified
biologist, pre-approved by the California
Department of Fish and Wildlife, not more
than 30 day: to any site disturbance
Timing: Prior
to ground
disturbance.
Methods: See
Mitigation
Measure.
Implementation:
City of La Quinta.
Monitoring and
Reporting: See
Mitigation
Measure.
prior
activities e • e, e • e, • e •
- _ _ . _ - _ .
A minimum of two surveys, occurring at
least three weeks apart, shall be completed
in advance of any site disturbance activities.
If disturbance activities are expected to start
during the burrowing owl breeding season,
three surveys shall be completed. The final
burrowing owl survey shall be completed
within three days prior to initiation of any
site disturbance activities. The pre-
construction survey shall be conducted
following guidelines in the CDFW 2012, Staff
Report on Burrowing Owl Mitigation. is
required to accepted (as
use protocol
determined CDFW). Prior to construction, a
qualified biologist will survey the construction
to 500 feet 150
area and an area up meters
outside the Project limits for burrows that could
be used by burrowing owls. If the burrow is
determined to be occupied, the burrow will be
flagged, and a 160 foot 200-meter diameter
buffer will be established during non-breeding
season or a 250 foot 500-meter diameter buffer
during the breeding season. The buffer area will
be staked and flagged. A list of avoidance and
minimization measures such as, but not
limited to, the use of hay bales, daily
biological monitoring, and trail cameras
shall be provided to CDFW for review prior
to any ground disturbance. No development
activities will be permitted within the buffer until
the young are no longer dependent on the
burrow and have left the burrow. For# the
burrows isfound to be unoccupied, the
qualified biologist will coordinate with
CDFW on the methods to make the burrows
be inaccessible to
will made owls, and
construction may proceed. If either a nesting or
escape burrow is occupied and impacts to the
owl(s) cannot be avoided, a Burrowing Owl
Relocation Plan will be developed and
reviewed by the Wildlife Agencies prior to
the relocation of owls. owls shall be relocated
to accepted Wildlife Agency
pursuant protocols.
Determination of the appropriate method of
relocation, such as eviction/passive relocation
or active relocation, shall be based on the
specific site conditions (e.g., distance to nearest
suitable habitat and presence of burrow within
that habitat) in coordination with the Wildlife
Agencies. If burrowing owls are observed
with the Project site during construction
activities, CDFW shall be notified
immediately and provided with proposed
avoidance and minimization measures for
CDFW to review.
MM BIO- 6: To ensure compliance with
California Fish and Game Code and the MBTA
and to avoid potential impacts to nesting birds,
vegetation removal and ground-disturbing
activities shall be conducted outside the
bird nesting season (January 15
Timing: Prior
to ground
disturbance
and during
construction
activities.
Methods: See
Mitigation
Measure.
Implementation:
City of La Quinta.
Monitoring and
Reporting: See
Mitigation
Measure.
general
through August 31). Any vegetation removal,
ground disturbance, and/or construction
activities that occur during the nesting season
will require that all suitable habitats be
thoroughly surveyed for the presence of nesting
birds by a qualified biologist that is pre-
approved by CDFW. Prior to commencement
of clearing, a qualified biologist shall conduct
preconstruction surveys within 14 days and
repeated 3 days prior to ground disturbing
activities. If any active nests are detected, a
buffer of 300 feet (500 feet for raptors) around
the nest adjacent to construction will be
delineated, flagged, and avoided until the
nesting cycle is complete. The buffer may be
modified and/or other recommendations
as determined appropriate by the
proposed
biologist to minimize impacts. During
construction activities, the qualified
biologist shall continue biological
monitoring activities at a frequency
recommended by the qualified biologist
using their best professional judgment, or
as otherwise directed by the Wildlife
Agencies. If nesting birds are detected,
avoidance and minimization measures may
be adjusted and construction activities
stopped or redirected by the qualified
biologist using their best professional
judgement as otherwise directed by the
Wildlife Agencies to avoid Take of nesting
birds.
MM BIO-[XX]: To reduce noise-related
Timing: During
Implementation:
impacts to wildlife using Coral Mountain, the
Project
City of La Quinta.
Project shall continue taking noise level
construction
Monitoring and
measurements during both Project
and post-
Reporting: See
construction and post-construction
construction
Mitigation
operations to determine if noise levels
operations.
Measure.
exceed thresholds outlined in the CEQA
Methods: See
document and inform if additional avoidance
Mitigation
and minimization measures are required. To
protect wildlife using Coral Mountain, the
noise threshold affecting this area shall be
reduced to 75 dBA as determined
appropriate in the Land Use Adjacency
Measure.
Guidelines in CVMSHCP Section 4.5. If noise
levels exceed this threshold, the Project
shall make changes to their operations
and/or adopt other minimization measures
to reduce noise impacts below 75 dBA to
minimize noise-related impacts on wildlife
using Coral Mountain.
MM BIO-[XX]: To reduce nighttime artificial
Timing: During
Implementation:
lighting-related impacts to wildlife using
Project
City of La Quinta.
Coral Mountain, the Project shall continue
construction
Monitoring and
taking lightning measurements during both
and post-
Reporting: See
Project construction and post-construction
construction
Mitigation
operations to determine impacts of
operations.
Measure.
nighttime artificial lightning on Coral
Methods: See
Mountain and the wildlife it supports. To
Mitigation
protect wildlife using Coral Mountain,
project construction and operations shall
result in no to minimal glare (500 or less
Measure.
candela) to all areas of Coral Mountain. If
light or glare impacts to Coral Mountain
exceed this threshold, the Project shall
make changes to their operations and/or
adopt landscape shielding, dimming,
lighting curfews or other appropriate
measures that result in the Project causing
minimal to no glare to all areas of Coral
Mountain.
rl at,npr,!fir
MA -Every' Ur afti: tion
IONORARY CI IA I RMAN
Ol FUNDRAISING
In Memoriam
Gerald R. Ford
1•tlr 1'r.-e'idirot a,i] dre 1 rrit !Stat
1'12I Sllll V'1 I-A11'Itl'l] S
1.a\N since Cone. M.D.
Ernest W. l lahn
Bob Hoy, and
Charles W. Joiner. 1).x'.1\4•
Richard C.A4cClune
Alexandra J. Sheldon
BOARD OF DIRECTORS
Mike Rivkin*
Presitiou
1):n c Stockton*
F,xcculive I i<e PriSident
Roland Burbank. D.V.M.'
1Y, Pre,,idem
Kant A• Roberts!'
TiVEISINVC
Randy 13) n(ier"
\eil'itar'4'
Stuart Barton, M.1).
Danielle Cane
Nicholas J. (sussou]is
S h i N4- i rider
Robert N. Gehhart, M.D.
Judith I.. Sander*
/:.ys stn's (lunrril
ADMINISFRAFION
James R. Der -urge
kvc-eptive Dinxtor
T. sear h BiologiNt
Aimee J. nV-ard
.-Ixxoeime Director
Biologist
ADVISORS
Mark C'..Inrgensen
:1ra_a-isarreea !)wort Saar Park
Raul Valdez. Ph.D.
:New :Ihvieo Store 1 n t'rsin-
J. Craig Williams, Esq.
C'orm.st /
Bighorn Institute
August 3, 2021
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Via Electronic Mail: consultingplanner@laquintaca.gov
Dear Ms. Sauviat Criste:
We are providing comments for the Draft EIR for Coral Mountain Resort (SCH#
2021020310), as it pertains to the endangered Peninsular bighorn sheep (Ovis Canadensis
nelsonii). We are primarily concerned with the likelihood of bighorn sheep being attracted
to and accessing Coral Mountain Resort as a means of artificial food and water if this project
is built.
Bighorn Institute has documented 35 known urban -related Peninsular bighorn deaths on or
near four La Quinta golf courses (Traditions, SilverRock, PGA West and The Quarry) and
Lake Cahuilla since 2012. These bighorn deaths are a result of the sheep being attracted
down to the grass and water features (i.e., artificial food and water sources). Despite the
DEIR declaring the project location as non -habitat for bighorn sheep, there is a real potential
for attracting bighorn sheep from adjacent areas, particularly if and when the required La
Quinta fence is constructed and the sheep are pushed back into their natural habitat. As
such, we strongly recommend this project be fenced prior to construction with fencing
approved in the Recovery Plan for bighorn in the Peninsular Ranges (i.e., an 8 foot chain-
link fence). The City of Rancho Mirage had similar urban -related bighorn issues and in
2002, a 4 1/2 mile long, 8ft high chain-link fence was built there. It completely eliminated
urban -related bighorn deaths and is promoting recovery of this species. We also
recommend no vegetation be planted near the project fence to attract the sheep.
Finally, we are concerned about the water usage for this project, particularly the wave pool
and other water features. We are in the grips of another drought year so it seems
irresponsible and unnecessary to build a project so focused on using such a valuable
resource. Wildlife, such as Peninsular bighorn, struggle to have enough available water to
survive during droughts and this project could contribute to the water shortage.
Thank you for the opportunity to provide comments on this project.
Sincerely,
AL1 -12--
s R. DeForge
cutive Director
Research Biologist
N.J. Box 262 • Pahl Descrl. California 9226l-0262 4fel (7611) 3.6-7334
Email lilta liiehurnlnstitute.org syssss.l3iahornlnstittne.org
Tuesday, June 22, 2021 at 07:41:23 Pacific Daylight Time
Subject: Wave Park La Quinta
Date: Monday, June 21, 2021 at 5:49:41 PM Pacific Daylight Time
From: Anne Smith
To: Consulting Planner
Dear Nicole Sauviat Criste,
I am writing to urge you to please DENY approval of the Wave Park.
We moved here just a year ago because we were impressed by the beauty of La Quinta, and the tranquility of the
neighborhood of Trilogy. We love being able to enjoy the quiet here, and especially enjoy stargazing from our
backyard at night as we have so little light pollution.
The Wave Park, with its constant noise and blaring stadium lights at night, threaten to destroy the very reason we
moved to La Quinta. We are already discussing the possibility of putting our home on the market because of this
proposed project. We did not move here to live next to an amusement park for the very rich that would destroy the
reason we moved from a high density area. And we do feel it would be terrible for our home value.
Even more important than anything else, though, is the unmistakable, overwhelming evidence of serious
unprecedented drought in the west. It is too scary and serious to ignore. All the lakes and reservoirs in the state are
at disastrously low levels. This proposed man made lake would steal from our drinking water. It's just a ridiculous and
incredibly harmful idea at this time in history. The heat and winds will evaporate huge amounts of potable water. I
know that if I voted to approve something like this, I would not be able to sleep at night knowing the harm I'd be
doing to our environment, and endangering people -- farmers, animals -- who desperately need that water for real
life needs.
I have read that 4 wave parks are in various processes of approval in the Coachella Valley. It seems preposterous that
there would be this much demand for this kind of project. And if there is, why put it in an area zoned for residential
development? And what will happen if this project is abandoned mid project for lack of funds? What an awful
eyesore will remain. There's only ever been one other water park in the area, and it failed. Four wave parks?!?
Please, please, listen to concerned citizens. Listen to your conscience and do the right thing and DO NOT APPROVE
THIS PROJECT.
Thank you very much,
Anne and Ron Smith
61120 Topaz Drive
La Quinta CA. 92253
Page 1 of 1
Tuesday, June 22, 2021 at 07:40:00 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR
Date: Monday, June 21, 2021 at 9:34:59 PM Pacific Daylight Time
From: DINA STUART
To: consultingplanner@laquintaca.gov
CC: Dina
To whom it may concern,
The County report that states Significant effect projected to be less than zero refer to topics like land use planning,
public services etc....
That has nothing to do with the Significant effects on neighbors and nearby residents!
The effect on us and our lifestyle is very Significant!
Is there a place in the desert for a surf resort?.... Absolutely' 1 III
But it is NOT across the street from Andalusia and Trilogy, nor nearby The Quarry and PGA West developments....
Head out by the Thermal Airport and beyond....
Plenty of locations!
Better yet, improve the Salton Sea and put it out there and make it a destination resort once again I i I i I
Page 1 of 1
Sunday, August 8, 2021 at 08:51:28 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR objections
Date: Tuesday, June 22, 2021 at 5:25:49 PM Pacific Daylight Time
From: Monica Harrington
To: Consulting Planner
Eighty -foot light poles are incompatible with City Code under the approved use of the proposed site for the Coral
Mountain Surf Park, which is now zoned as low density residential, which is the same zoning that applies to
surrounding properties. And yet, in the EIS report, we learn that the illumination of outdoor recreational facilities is
exempt from the requirements of this section and that passage is slipped in as though it's reasonable to think that
the zoning should be easily transformed into Recreational Use, which is the zoning that applies to amphitheaters, ball
parks, etc.
Why doesn't this section just come out and say: "The use of 80 -foot light poles is ILLEGAL under the current zoning of
the property, so one way to get around this and to accommodate 80 -foot light poles is to quietly change the
designation to "Recreational" and thus get the same lighting requirements that might apply to a huge outdoor
stadium or arena. And by the way, by doing this, you can ensure that the outdoor lights can stay on EVERY DAY until
10:00.
The authors of this study didn't write it that way because they wanted people to come away thinking that it's
reasonable that 80 -foot lights operating until 10:00 pm every night in a low density residential area is somehow
acceptable. It's not.
Sometimes, people agree to tradeoffs on sound/light because the recreational benefits available to all are perceived
to be worth it. E.g., in some municipalities, outdoor summer concerts are allowed a few times a year in close
proximity to residential users, so long as the concerts end before 10:00. The idea is that for a few nights a year, the
tradeoff in noise and light in an otherwise quiet residential area might be worth it to add to the cultural
attractiveness of an area.
Here, there is NO benefit to surrounding communities of 80 -foot -light poles or of an event venue that is active EVERY
evening until 10:00 pm. Surrounding communities get all of the light and noise intrusion, all of the time, with no
benefit.
Viewed in this way, the conversion of the existing zoning for the property does not satisfy the zoning change
requirements embedded in La Quinta Municipal Law:
Required Findings. The following findings shall be made by the city council prior to approval of any zone
map change:
1. Consistency with General Plan. The zone map change is consistent with the goals,
objectives and policies of the general plan.
2. Public Welfare. Approval of the zone map change will not create conditions
materially detrimental to the public health, safety and general welfare.
Page 1 of 2
3. Land Use Compatibility. The new zoning is compatible with the zoning on adjacent
properties.
4. Property Suitability. The new zoning is suitable and appropriate for the subject
property.
5. Change in Circumstances. Approval of the zone map change is warranted because
the situation and the general conditions of the property have substantially changed
since the existing zoning was imposed.
Sincerely,
M.M. Harrington, 58117 Carmona
From the EIS report,
Per Section 9.100.150 of the LQMC, the illumination of outdoor recreational facilities, public and
private, (i.e. the Wave) is exempt from the requirements of this section with the following limitations:
the light fixtures for outdoor recreational facilities shall meet the shielding requirements in the
Municipal Code; and no such outdoor recreational facility shall be illuminated by nonconforming
means after 10:00 p.m. except to conclude a specific recreational or sporting event or any other
activity conducted at a ballpark, outdoor amphitheater, arena, or similar facility in progress prior to
10:00 p.m. Because the operation of the project is governed by the Specific Plan rather than the
Municipal Code, and in order to assure that the operation of the Wave Basin will conclude at 10:00
p.m., compliant with the recreational operational hours allowed by the City of La Quinta, Mitigation
Measure AES -3 has been added. Therefore, with the implementation of Mitigation Measure AES -3,
impacts will be less than significant.
Page 2 of 2
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Wave park
0 You replied on Thu 6/24/2021 10:29 AM
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CG
Connie Glavin <cjglavin@yahoo.com>
Thu 6/24/2021 8:32 AM
To: Consulting Planner
** 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. **
Please do not allow this development, it will spoil the area as far as lights noise traffic.
Animals will be disturbed also. We have big horn sheep and Bob cats ion the area and we
enjoy them. We purchased our home out here for our retirement for the quiet area and
enjoy sitting out at night and seeing the stars afraid the added traffic and lights will interfere
with this nice quiet area please let us know that this will not occur this was zoned residential
correct? Why change it now, we like to bike and with the added traffic will be hard to exit
our development and ride into old town la Quinta. With drivers coming back here for the
wave park development. sincerely Connie Glavin 79460 Tom Fazio Lane North La Wuibta
CA. 92253. We are in The Quarry
Sent from my iPhone
Reply Forward
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Coral Mountain Resort DEIR
Sarah Zappas <szappas@yahoo.com>
Thu 7/1/2021 9:30 AM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>; Linda Evans <Levans@laquintaca.gov>; Robert Radi
<Rradi@laquintaca.gov>; John Pena <jpena@laquintaca.gov>; Steve Sanchez <ssanchez@laquintaca.gov>;
Kathleen Fitzpatrick <kfitzpatrick@laquintaca.gov>
Cc: Greg Zappas <cazap@cox.net>
** 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. **
Hi Nicole Sauviat Croate,
I want to reach out to you as a resident of Andalusia , 58194 Aracena in La Quinta for the last 8
years. The proposed plan to put a water park "wave pool" across the street in a zoned residential
neighborhood, seems like the city has sold out in favor of commercial tax revenues.
My husband and I chose this development for its quiet, and remote location. We were not naive to
think that one day this area around us would not be built up, certainly it would be developed.
However the issues that this project brings to the neighborhood are unacceptable.
First the water that this park ( wave pool) will be using on a daily basis is counter to water
conservation efforts here in the Coachella Valley. The fact that recycled water can't be used and
that every day the "wave pool" will be utilizing our drinking water is negligent at best. I read this
finding that designates this issue as insignificant is ridiculous. I understand it is insignificant to
the developers that want this project to move forward, but greed is what their motivation is.
The second was the zoning change that allows the project to develop 60,000 square feet for
commercial purposes in a residential neighborhood that was originally zoned residential. In
addition to that is the 23.6 acres of Recreational Open Space what is that? What will be allowed
to be developed under that designation, the ability to bring in off road vehicles?
The third issue of the lighting poles , 80 feet high that will illuminate the night sky, every evening
365 days a year. It will be like living next to a football stadium but instead of a couple of months
out of the year , it will be every evening. I beg to differ that this is insignificant , who's says that,
obviously they aren't living across the street.
I would ask that the city of La Quinta, the City Council and the Mayor reconsider the scope of this
water park, after all you represent us the people who live in the city of La Quinta. I'm sure with
the demographic of this city that the population here will not be using this "Wave Pool" but a
tourist population coming to this quiet part of town to party and increase the traffic and above all
destroy the land around this beautiful city.
Best Regards,
Sarah Zappas
1 of 1 7/1/21, 10:08 AM
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Surf park
KRISTINA DAILEY <kristinam_dailey2018@aol.com>
Thu 7/1/2021 8:08 AM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
** 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. **
Dear Nicole and the LQ planning commission,
This email is being written in opposition to the proposed surf park at Coral Mountain. It truly
dismays me how money hungry and dollar driven this counsel has become. Have you read any of
the latest articles in the Desert Sun about the water crisis in the west ? Research Lake Powell and
the Glen Canyon Damn. I was there recently. The damn is one to two years away from being
declared a " dry" damn. If that happens not only will our water supplies for the Colorado River
and the states that depend upon it be depleted but our electrical grid will be compromised as
well.
The proposed water park will depend on under ground water tables and supposedly will use less
water then a golf course which is also the LAST thing this desert community needs. Build your
homes if you must but do it responsibly and sustainably. Why would anyone in their right mind
want to purchase a 2.5 million dollar home next to a surf club especially if there are no member
benefits included ?
The Coral Mountain area is a beautiful, pristine and sacred area of this valley. Let's treat it as
such and be more responsible in our choices for the future.
Sincerely,
Kristina M. Dailey
Sent from my iPhone
1 of 1 7/1/21, 10:07 AM
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Coral Mountain Resort DEIR
Diane Rebryna <drebryna@telusplanet.net>
Fri 7/2/2021 12:44 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Cc: Linda Evans <Levans@laquintaca.gov>; Robert Radi <Rradi@laquintaca.gov>; Kathleen Fitzpatrick
<kfitzpatrick@laquintaca.gov>; John Pena <jpena@laquintaca.gov>; Steve Sanchez <ssanchez@laquintaca.gov>;
cdd@la-quinta.org <cdd@la-quinta.org>
1 1 attachments (64 KB)
July 2, 2021 DRAFT EIR CORAL MOUNTAIN RESORT DEIR.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. **
Dear Ms. Sauviat Criste,
Please see the following email regarding the DEIR for Coral Mountain Resort.
A PDF of this letter is also attached for your reference, should the contents of the email distort during transmission.
Thank you,
The La Quinta Residents for Responsible Development
July 2, 2021
Attention: Ms. Nicole Sauviat Criste, Consulting Planner, City of La Quinta
Dear Ms. Sauviat Criste:
RE: Draft EIR Coral Mountain Resort
We, the La Quinta Residents for Responsible Development, are sending this letter to express our concerns regarding the Draft EIR
that was released for Coral Mountain Resort.
At the outset, we wish to say that this document is beyond comprehension for the average resident of La Quinta.
The DRAFT EIR (DEIR) is not in keeping with the 2021 CEQA Statute and Guidelines https://www.califaep.org
/docs/CEQA Handbook 2021.pdf, particularly those laid out in Article 10. Considerations in Preparing EIRs and Negative Declarations:
The text that follows in black refers to direct excerpts from Article 10. Our concerns are laid out in RED.
15140. WRITING
EIRs shall be written in plain language and may use appropriate graphics so that decision makers and the public can rapidly
understand the documents.
This document is replete with redundancy - paragraphs and statements, obviously boilerplate, are inserted and re-inserted throughout
the document into various categories, where not necessary or where summaries might have been acceptable.
We do see the summary of Environmental Impacts and Mitigation Measures TABLE 1-3. While this summary is useful, the background
information regarding each section MUST be presented in a manner that a reader can understand.
The DEIR fails in this regard.
1 of 4 7/2/21, 2:20 PM
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15141. PAGE LIMITS
The text of draft EIRs should normally be less than150 pages and for proposals of unusual scope or complexity should normally be less
than 300 pages
This statement speaks for itself.
The DRAFT EIR is well over 700 pages, not including Appendices.
This document is unnecessarily LARGE, primarily as a result of of the way it is written - we refer you back to 15140 above.
15145. SPECULATION
If, after thorough investigation, a Lead Agency finds that a particular impact is too speculative for evaluation, the agency should note its
conclusion and terminate discussion of the impact.
The intrusiveness on the surrounding residential communities with, by way of example but not limited to, the:
Lights (including multiple 80 -foot towers and commercial glare from buildings and parking lots)
Noise (during operation, and that associated with Special Events), and
Aesthetics (impacts on the views of Coral Mountain)
as presented in the DEIR with the pretext of supportive "scientific studies/analysis", is difficult to even read let alone understand, and
therefore to allow for our interpretation.
We are of the opinion that the declared "negative" impacts of the above in particular are essentially speculative and should be
acknowledged as such.
The failure to do this greatly concerns us and many residents that we have talked with regarding the DEIR. The phrase that comes to
mind, no disrespect intended, is "smoke and mirrors". This speaks to our concerns about the credibility of the some of the information
presented in the document.
15146. DEGREE OF SPECIFICITY
The degree of specificity required in an EIR will correspond to the degree of specificity involved in the underlying activity which is
described in the EIR.
An EIR on a project such as the adoption or amendment of a comprehensive zoning ordinance or a local general plan should focus on
the secondary effects that can be expected to follow from the adoption or amendment, but the EIR need not be as detailed as an EIR
on the specific construction projects that might follow.
We are of the opinion that the "details" of the DEIR obscure the focus on the secondary effects of the Project - in other words, we as
the readers, cannot see the "forest for the trees" and therefore have trouble understanding exactly what it is that the DEIR is trying to
say.
Every attempt should have been made in the DRAFT EIR to ensure, going back to 15140 above, to ensure that the information
contained is "rapidly understood" by the reader.
We would have liked to stand back upon receipt of the EIR and, after reading, say "WE MAY NOT AGREE... BUT WE DO
UNDERSTAND THE SECONDARY EFFECTS".
As the EIR stands now, we are making it known to you that we are unable to do this.
15147. TECHNICAL DETAIL
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The information contained in an EIR shall include summarized technical data, maps, plot plans, diagrams, and similar relevant
information sufficient to permit full assessment of significant environmental impacts by reviewing agencies and members of the public.
Placement of highly technical and specialized analysis and data in the body of an EIR should be avoided through inclusion of
supporting information and analyses as appendices to the main body of the EIR.
Again, to our points noted. The technical data presented in the body of the DEIR is not summarized or organized in such a manner as
to allow for the understanding of the general reader.
In summary, from the CEQA Guidelines ..."The DEIR serves as a public disclosure document explaining the effects of the proposed
project on the environment, alternatives to the Project, and ways to minimize adverse effects and to increase beneficial effects".
This is the framework that we looked forward to and expected to receive when the DEIR was released, nearly two weeks ago.
In essence, the proclamation of "no negative effects " is evident throughout the document, but the information that is provided within the
document to support those conclusions regarding the DEIR categories is virtually undecipherable to us.
This is not fair. There is a timed `Process" underway and we are the residents who will be impacted by this Project.
We require transparency please.
We require a complete understanding of exactly what is impacting us and how. Any mitigation measures presented must make sense.
If we, the general public, cannot understand the DEIR, how can we possibly respond accordingly in the manner required of us?
Conjecture and opinions will carry no weight.
We respectfully request that this DRAFT EIR be retracted and replaced.
The replacement document should be created with the following in mind - it should be reasonable in length, with clear and concise
language, and without unnecessary repetition. This would allow for "rapid" understanding by readers, and thus it would be in alignment
with the CEQA guidelines.
Thank you for your consideration of our request.
THE LA QUINTA RESIDENTS FOR RESPONSIBLE DEVELOPMENT
https://www.saynotothewave.com
You may direct any questions regarding this communication to:
Diane Rebryna, drebryna@telusplanet.net
Derek Wong derekwong745@yahoo.com
Ramon Baez rfbaez7@gmail.com
cc:
Linda Evans. Mayor E-mail: levans@laquintaca.gov
Robert Radi, Mayor Pro Tem E-mail: rradi@laquintaca.gov.
Kathleen Fitzpatrick, Council Member E-mail: kfitzpatrick@laquintaca.gov
3 of 4 7/2/21, 2:20 PM
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John Pena, Council Member E-mail: jpena@laquintaca.gov
Steve Sanchez, Council Member E-mail: ssanchez@laquintaca.gov
Cherri Flores, Planning Manager, E-mail cdd@la-quinta.org
Carlos Flores, Senior Planner, E-mail cdd@la-quinta.org
Siji Fernandez, Associate Planner, E-mail cdd@la-quinta.org
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Coral Mountain
Derek Wong <derekwong745@yahoo.com>
Sat 7/3/2021 3:19 PM
To: Linda Evans <Levans@laquintaca.gov>; Kathleen Fitzpatrick <kfitzpatrick@laquintaca.gov>;
rrad@laquintaca.gov <rrad@laquintaca.gov>; John Pena <jpena@laquintaca.gov>; Steve Sanchez
<ssanchez@laquintaca.gov>; Consulting Planner <ConsultingPlanner@laquintaca.gov>
** 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. **
Hello,
As concerned Andalusia homeowners, we were very disappointed in the July 1 Desert Sun
article by Sherry Barkas, "Study: Surf park would have little noise impact".
Please consider these concerns and plan future articles accordingly.
1. Please do not state one side's opinion as a headline (it misleads readers...who will think it is a
conclusion...instead of a self -promoting opinion based on highly questionable information by
the developers and their consultants).
2. We have concerns about the neutrality of the firm — MSA Consulting in Rancho Mirage - hired
to conduct the EIR. They seem to have an extremely close relationship with Meriweather, the
developers of the proposed Coral Mountain project. Shouldn't the Sun be certain that there is
no conflict of interest going on here before becoming an unwitting spreader of their biased,
profit -motivated position? Please research MSA to see if they have ever produced EIRs with
findings unfavorable to the developer's side.
3. The "findings" your reporter cites from the EIR are curiously similar to/almost mirror reflections
of Meriweather's pro -development, pre-EIR claims. Therefore, we suggest you (or a Sun
reporter) ask the City Planner Nicole Sauviat Criste for copies of the incredibly well -researched
and well-informed complaints about the project that -dozens of local citizens have submitted.
These letters should help you gain a more critical, less naive stance toward the EIR's
contentions and expose you to the seriousness of many of the issues surrounding this
project. The letters will also provide you with the names of some local citizen experts you can
contact for further elucidation.
4. PLEASE ASK QUESTIONS whenever Meriweather or MSA make claims (don't just take their
word for everything). For instance:
a. Meriweather/MSA claims the project will use "less water than a golf course".
Really? Most desert golf courses use recycled or gray water. A surfpark/wave basin must
use fresh water since human beings will be swimming in it. And are they honestly
including the amount of water that will be used by the project's planned single-family
homes, villas/hotel rooms, restaurants, planned grocery store, spa/fitness facilities,
showers/stalls for surfers, landscaping, continuously needing to refill the wave basin, etc.?
We have NOT seen any of those figures. So their "comparisons" of their project vs. a golf-
course/home project should not be trusted.
b. Meriweather/MSA claims that the project will have "less than significant" impacts on
water quality, usage and depletion of groundwater supplies. DID YOU ASK ABOUT
EVAPORATION...from an 18 -million gallon wave basin sitting in the desert sun...and how
much water they will have to use to continuously refill it?
c. Meriweather/MSA claims the wave basin's LIGHTS will "only impact a small area of
the scenic vista". Really? Have you seen the video from one of the night events held at
Kelly Slater's Surfpark in Leemore? Look here - BEST Wave Pool Experience EVER!
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Kelly Slater Surf Ranch w/ Casey Neistat (START AT 34:25) - and then tell us that Coral
Mountain's seventeen 80 -foot -tall light towers will not be intrusive! PLEASE GET
SERIOUS ABOUT THE LIGHT POLLUTION THIS PROJECT WILL CREATE. They've
already admitted the wave basin will operate until 10pm year-round...and probably later
during their special events. How would you like that kind of lit -up amusement feature in
your backyard...every day...from 7am to 10pm919'9 It will be a MAJOR DISRUPTOR to all
the nearby residents...who bought homes in surrounding communities for the peace and
quiet currently afforded here. La Quinta prides itself on its starry, desert night sky!!! These
outrageous light poles will create too much light...and negatively impact the night sky...for
all the surrounding communities. And will be a MAJOR blight against the nearby
mountains!
BEST Wave Pool Experience EVER! Kelly Slater
Surf Ranch w/ Casey Neistat
d. Local experts claim that the proposed development — specifically the carving out of an
18 -million gallon wave basin and the constant shaking created by the wave -making
motors and the continuous hard pounding into the earth of the waves as they
crash -- could have geologically and seismologically negative effects on the soil around
Coral Mountain. There are also concerns about the damage an earthquake could cause to
an 18 -million gallon wave basin and the surrounding communities. PLEASE COVER THIS
ANGLE. You will see scientific data about these concerns in the letters submitted to the
City that we referenced above. We can also provide you with experts to talk to about these
issues.
e. Meriweather claims NOISE impacts will be "less than significant during
construction...and once the project is completed and the wave basin is operating". Oh
really?!? Ask any resident of Andalusia about the amount of noise that is heard from minor
construction projects at the IID building on Avenue 58 — e.g., repaving their parking lot,
putting on a new roof. All their projects reverberate and are heard loudly...along with the
back-up beeping of all the trucks involved...throughout the Andalusia community. And
these are MINOR projects — nothing like the building of homes, restaurants, a hotel, a
huge wave basin, and surrounding support facilities. GET SERIOUS PLEASE!
f. And what about NOISE once the project is completed? How was "less than
significant" determined? This is crazy! The wave basin will operate NON-STOP from 7am
to lOpm DAILY! LOUD MECHANICAL NOISE is part of the wave -producing
machines...along with the constant back & forth of jet skis to transport surfer-
customers...and the PA system announcing the next waves and playing music. GET
SERIOUS PLEASE! This project will be a MAJOR NOISE PRODUCER!
g. Another consultant obviously in cahoots with Meriweather is called Urban Crossroads.
They submitted this ludicrous claim to the EIR — "The mountain is more likely to absorb
rather than deflect sounds from the wave basin during normal use and special events".
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Again...ARE YOU KIDDING ME? Coral Mountain is a natural rock amphitheater...sounds
that are made in its environs bounce off its walls and echo into surrounding communities.
JUST ASK THE HOMEOWNER who lives at Avenue 60 and Madison. She can hear
hikers at the base of Coral Mountain...and you don't think noises created by a major
machinery -driven wave -pounding water -sports basin...with loudspeakers all around...and
jet skis revving...will be heard? This has not been studied properly!!! And again...we
ask...since you are the community's journalistic outlet...to investigate Urban Crossroads.
ALL of its clients are cities and homebuilders. They are NOT going to say anything that
would derail the development or upset their clients. WHO IS WORKING on behalf of the
surrounding taxpaying homeowners? Clearly not the City...which obviously wants this
development!
h. Meriweather says it will hold four events per year attracting approx. 2,500 attendees
each. And they have the chutzpah to say that the project will have "no significant impact
on surrounding intersections"?!? Really?? So they do not plan to make any changes to the
existing intersections...which are rural/low-density/residential...at Avenue 58 and
Madison...or Avenue 60 and Madison? There are just Stop signs at all these surrounding
intersections. And the developer is not planning to make any contributions to improving
traffic control or noise issues that will result from the project or their large events? We
repeat...this is a LOW-DENSITY, RESIDENTIAL neighborhood...which should NOT be
changed.
Once again, the Coral Mountain property is zoned for "neighborhood commercial, low-
density residential and golf course" for a reason. And this zoning is part of the La Quinta
General Plan...so any change should require much broader buy-in...from taxpaying
homeowners and businesses...instead of just Meriweather and its consultants! Please do
your due diligence for ALL future stories on this topic!
You should also push back when told...or when you come across language...that refers to
something as "less than significant"...or "more likely". Meriweather/MSA/Urban Crossroads
use incredibly VAGUE language. This is NOT ACCEPTABLE when discussing such serious,
life -changing concerns for those of us who live next door to this property! And the
City/citizens/journalistic outlets should NOT let them get away with it! What do those terms
mean? Compared to what? Show us the numbers/actual measurements!
And while you're at it...please talk to Air, Noise, Water, Planning experts about the
ridiculousness of FOUR Water/surf parks being constructed in the middle of the desert!
These are incredibly non -sustainable projects - in an era of water restrictions, air -health
quality concerns, traffic issues, etc! Please start covering this issue more seriously. The
Coachella Valley does NOT need four of these parks! And shouldn't the desert cities get
together to support the one or two that will be OPEN TO THE PUBLIC and provide income
to all the communities...instead of supporting one that will be highly exclusive/private and
JUST benefit the developer (as Coral Mountain would)!!
Thank you,
Bridgett & Phil Novak
Andalusia
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CORAL MT. RESORT DEIR
Bobbie Fleury <bobbie@fleury.tv>
Tue 7/6/2021 8:26 AM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Cc: Linda Evans <Levans@laquintaca.gov>; Robert Radi <Rradi@laquintaca.gov>; John Pena
<jpena@laquintaca.gov>; Steve Sanchez <ssanchez@laquintaca.gov>; Kathleen Fitzpatrick
<kfitzpatrick@laquintaca.gov>; Danny Castro <dcastro@laquintaca.gov>; Cheri Flores <clflores@laquintaca.gov>
** 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. **
Hello Nicole, Mayor Evans, and Council Members Radi, Sanchez,
Fitzpatrick, and Pena, Mr. Castro, and Ms. Flores,
Contrary to what some may believe, I am not anti -development concerning
the Coral Mt. Resort. In fact, I have no issues with this parcel of land
being approved for homes, a hotel and restaurant,
hiking and biking trails, and perhaps even have the developer throw in a
9 hole putt -putt course for fun - on fake grass!
However, I am extremely opposed to the current request for a zoning
change to accommodate what amounts to an amusement park for
out-of-towners in the middle of residential communities,
and especially a park whose main feature is an 18 million gallon water
guzzling ditch that will continuously be draining our fresh water from
the aquifer due to evaporation in our hot, dry, climate.
I also have to wonder if anyone at Meriwether realizes that the water in
the wave pool will be uncomfortably hot for about 4 months out of the
year and therefore not much fun to surf in.
It's why many don't use their pools in the summer.
According to the recently released draft EIR, most of what is planned
for the site won't have any "significant" impact on the surrounding
environment. That's like saying someone is "slightly" pregnant!
The developer - Meriwether Co. - hired the people who did the DEIR. Are
we supposed to believe that their report is totally OBJECTIVE?
The developer continues to cite that the wave won't use more water than
a golf course, while ignoring the fact that more and more courses have
now gone to non -potable water, something that cannot be done with the
surf park. For our City Council to approve the rezoning so this can
proceed is unconscionable especially in light of La Quinta's own land
and water use guidelines. Just like Slater did in Lemoore, where the
wave park is in the middle of empty land, that's where this should go -
and not in our desert where water use is of critical importance.
Considering that California is back into a drought situation, if the
developer has a conscious, or any inkling of being environmentally
sensitive, they should pull back their request for the wave portion of
their plans.
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And I would hope, that when it comes before you for a vote, your answer
will be "no."
Thank you for your consideration.
Bobbie Fleury
2 of 2 7/7/21, 11:26 AM
Sunday, August 8, 2021 at 08:50:37 Pacific Daylight Time
Subject: Draft Environmental Impact Report Coral Mountain
Date: Wednesday, July 7, 2021 at 10:18:14 PM Pacific Daylight Time
From: Agnes Collins
To: consultingplanner@laquintaca.gov
Dear Mayor and Council, and
Ms. Nicole Sauviat Criste, Consulting Planner
City of La Quinta
We, the La Quinta Residents for Responsible Development, are sending this letter to express our concerns regarding
the Draft EIR that was released for Coral Mountain Resort.
At the outset, we wish to say that this document is beyond comprehension for the average resident of La Quinta.
The DRAFT EIR (DEIR) is not in keeping with the 2021 CEQA Statute and Guidelines
https://www.califaep.org/docs/CEQA Handbook 2021.pdf, particularly those laid out in Article 10. Considerations in
Preparing EIRs and Negative Declarations, as laid out here:
15140. WRITING
EIRs shall be written in plain language and may use appropriate graphics so that decision makers and the public can
rapidly understand the documents.
This document is replete with redundancy - paragraphs and statements, obviously boilerplate, are inserted and re-
inserted throughout the document into various categories, where not necessary or where summaries might have
been acceptable.
We do see the summary of Environmental Impacts and Mitigation Measures TABLE 1-3. While this summary is useful,
the background information regarding each section MUST be presented in a manner that a reader can understand.
The DEIR fails in this regard.
15141. PAGE LIMITS
The text of draft EIRs should normally be less than150 pages and for proposals of unusual scope or complexity should
normally be less than 300 pages
This statement speaks for itself.pagelimage56365184 pagelimage56450752 pagelimage56444800
The DRAFT EIR is well over 700 pages, not including Appendices.
This document is unnecessarily LARGE, primarily as a result of of the way it is written - we refer you back to 15140
above.
15145. SPECULATION
If, after thorough investigation, a Lead Agency finds that a particular impact is too speculative for evaluation, the
agency should note its conclusion and terminate discussion of the impact.
The intrusiveness on the surrounding residential communities with, by way of example but not limited to, the:
Lights (including multiple 80 -foot towers and commercial glare from buildings and parking lots)
Page 1 of 3
Noise (during operation, and that associated with Special Events), and
Aesthetics (impacts on the views of Coral Mountain)
as presented in the DEIR with the pretext of supportive "scientific studies/analysis", is difficult to even read let alone
understand, and therefore to allow for our interpretation.
We are of the opinion that the declared "negative" impacts of the above in particular are essentially speculative and
should be acknowledged as such.
The failure to do this greatly concerns us and many residents that we have talked with regarding the DEIR. The phrase
that comes to mind, no disrespect intended, is "smoke and mirrors". This speaks to our concern
about the credibility of the some of the information presented in the document.
15146. DEGREE OF SPECIFICITY
The degree of specificity required in an EIR will correspond to the degree of specificity involved in the underlying
activity which is described in the EIR.
An EIR on a project such as the adoption or amendment of a comprehensive zoning ordinance or a local general plan
should focus on the secondary effects that can be expected to follow from the adoption or amendment, but the EIR
need not be as detailed as an EIR on the specific construction projects that might follow.
We are of the opinion that the "details" of the DEIR obscure the focus on the secondary effects of the Project - in
other words, we as the readers, cannot see the "forest for the trees" and therefore have trouble understanding
exactly what it is that the DEIR is trying to say.
Every attempt should have been made in the DRAFT EIR to ensure, going back to 15140 above, to ensure that the
information contained is "rapidly understood" by the reader.
We would have liked to stand back upon receipt of the EIR and, after reading, say "WE MAY NOT AGREE... BUT WE DO
UNDERSTAND THE SECONDARY EFFECTS".
As the EIR stands now, we are making it known to you that we are unable to do this.
15147. TECHNICAL DETAIL
The information contained in an EIR shall include summarized technical data, maps, plot plans, diagrams, and similar
relevant information sufficient to permit full assessment of significant environmental impacts by reviewing agencies
and members of the public.
Placement of highly technical and specialized analysis and data in the body of an EIR should be avoided through
inclusion of supporting information and analyses as appendices to the main body of the EIR.
Again, to our points noted. The technical data presented in the body of the DEIR is not summarized or organized in
such a manner as to allow for the understanding of the general reader.
In summary, from the CEQA Guidelines ..."The DEIR serves as a public disclosure document explaining the effects of
the proposed project on the environment, alternatives to the Project, and ways to minimize adverse effects and to
increase beneficial effects".
This is the framework that we looked forward to and expected to receive when the DEIR was released, nearly two
weeks ago.
Page 2 of 3
In essence, the proclamation of "no negative effects " is evident throughout the document, but the information that
is provided within the document to support those conclusions regarding the DEIR categories is virtually
undecipherable to us.
This is not fair. There is a timed "Process" underway and we are the residents who will be impacted by this Project.
We require transparency please.
We require a complete understanding of exactly what is impacting us and how. Any mitigation measures presented
must make sense.
If we, the general public, cannot understand the DEIR, how can we possibly respond accordingly in the manner
required of us? Conjecture and opinions will carry no weight.
We respectfully request that this DRAFT EIR be retracted and replaced.
The replacement document should be created with the following in mind - it should be reasonable in length, with
clear and concise language, and without unnecessary repetition. This would allow for "rapid" understanding by
readers, and thus it would be in alignment with the CEQA guidelines.
Thank you for your consideration of our request.
THE LA QUINTA RESIDENTS FOR RESPONSIBLE DEVELOPMENT
Agnes Nilsen Collins
Page 3 of 3
Dear Nicole Sauviat Criste,
I am a concerned citizen of the desert and am opposed to building the Coral Mountain Resort. We are
in a drought emergency and not only will water be necessary to build this Resort, but adding an 18
million gallon wave pool, too? Water evaporates. Where is this water coming from—the underground
aquifer? We are in the middle of climate change. Temperatures are getting hotter every year. The
2014 Sustainable Groundwater Management Act—SGMA was adopted during California's last drought.
The law states that groundwater is a shared resource. I don't believe sharing a finite resource with more
million dollar homes, a four story hotel, and another wave pool in the desert is sustainable. I conserve
water but yet see projects like these springing up all over the desert and wonder why I should do my
part?
Sincerely,
Maggie Hamilton
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Coral Mountain proposal
IS
Label: 60 Days Delete (60 days) Expires: Mon 9/6/2021 6:46 AM
Ilona Sala <ilonalsala@gmail.com>
Thu 7/8/2021 6:46 AM
To: Consulting Planner
** 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. **
I concur with the letter written to the planning committee of the ridiculous length and
unfriendly wording in the Coral Mountain proposal. If the people cannot who are going to
be most affected by this super project are not given a document that can be understood
by them, it ought not be written as such. Don't make this similar to what the
Washington bourgeoisie do and write a book size document filled with legaleze and vote
before the document has been decimated and understood by the proletariats who pay
taxes but stand to lose.
Ilona Sala
Reply Forward
1 of 1 7/8/21, 10:37 AM
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Coral mountain resort Nicole criste consulting planner
JC
Label: 60 Days Delete (60 days) Expires: Tue 9/7/2021 3:43 PM
Judy Carey <rosencarey@verizon.net>
Fri 7/9/2021 3:43 PM
To: Consulting Planner
** 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. **
I am a full time desert and La Quinta city resident, and have been here 37 years.
I am Opposed to the building of the Coral Mountain Resort with it's proposed 18 million
gallon
wave pool, 4 story hotel, and many new homes.
We are living in a drought Again, and with climate change happening it seems
irresponsible to
think that such a project which would require so much of an Important resource would even
be considered.
According to the 2014 Sustainable Groundwater Management Act, groundwater is a
"shared resource" ,
and therefore this finite resource needs to be used appropriately. Water from our aquifer
needs to be used in
A sustainable and justifiable manner. Drinking water, water for crops, plants and gardens
seems more important
than a wave pool! Think of the evaporation factor alone.
I do my part with water conservation, shouldn't we ALL be doing the same?
Sincerely,
Judy Carey
53380 Avenida Cardenas
LQ
Reply Forward
1 of 1 7/12/21, 8:05 AM
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Coral Mountain Development
K
Label: 60 Days Delete (60 days) Expires: Wed 9/8/2021 2:04 PM
kelly <kelwelrt@gmail.com>
Sat 7/10/2021 2:04 PM
To: Consulting Planner
** 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. **
Dear Nicole,
My name is Kelly Welton and my fiance and I live in Trilogy. We moved here in Feb
2020.
Tired of Los Angeles and Orange counties' traffic and noise, we were lured to La Qui
open mountains, sightings of Bighorn sheep, and the quiet beauty of all the visible sty
We are VERY opposed to the proposed "Coral Mountain" wave park. We strongly
not to approve any zoning variances that would allow this project to go forward. The
variances effectively allow the equivalent of commercial -scale traffic, noise, lights, ar
in a high density residential area. We understand the property will be developed sor
when we considered and ultimately purchased our retirement home, we never dream
zoning could change from residential with golf course to amusement park so quickly
quietly.
Why jeopardize our "Gem of the Desert" reputation?
And, to be frank, the Environmental Impact Report seems to have been prepared by
developers rather than by neutral third parties. This truly is the wrong project in the
place.
I believe you have a responsibility to the residents of La Quinta, at the very least to a
our efforts and listen to our concerns.
We seem to have been `brushed aside' whenever voicing our concerns for this projec
Please, we urge you to fully consider the impact this development will have on La Qu
La Quinta, to the ends of the city limits.
Thank You.
Sincerely,
Kelly Welton
1 of 1 7/12/21, 8:07 AM
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Draft EIR Wavepark
MC
Label: 60 Days Delete (60 days) Expires: Thu 9/9/2021 8:39 PM
mike charles <mgacharles@yahoo.com>
Sun 7/11/2021 8:39 PM
To: Consulting Planner
** 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. **
Please make MSA redo the Draft EIR so we can all understand what is being said as it
pertains to the Wavepark proposal. Personally, I have spent hours trying to come to some
understanding of what is being said or referenced. I simple cannot understand their
research or early conclusions. I have given up as well as many others who have sought out
help for same reason. The general public has a right to understand this document. The
city has a similar obligation per Ca statute to make this document readable and
understandable to the average resident. I personally have asked two land use attorneys for
help in the matter and they have reached the same conclusion.
If the goal by MSA is to complicate and confuse the general public then they have
succeeded. In order to move forward this document needs to be understood.
Unbelievable that this even needs to be brought forward.
Mike Charles
8134.3 Andalusia
La Quinta, Ca 9Z=53
mgacharlesca yahoo.com
cell: =53-381-4565
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1 of 1 7/12/21, 8:08 AM
Dear Nicole Sauviat Criste
I am writing to let you know my objection to the proposed development of the
Coral Mountain Resort.
I have lived in La Quinta since 1972 and have seen some good development in
La Quinta and some bad. Unfortunately highway 111 has some terrible and
unnecessary development, ie car lots and big box stores.
There are many things to consider when planning a city. It is extremely
important to consider the environmental impact of a development. With global
warming and droughts in California it is responsible for the city to consider how
a development would impact our water resources.
The idea of having an 18 million gallon wave pool, a four story hotel and million
dollar homes is not environmentally responsible.
Please deny the application of this development and save our water resources.
Sincerely,
Dorothy Dupree
78430 Cameo Dunes Place
La Quinta, Ca 92253
760 861-9442
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Coral Mountain Resort - Draft EIR
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Ken Jones <kenjonesmail@aol.com> <5
Mon 7/12/2021 12:51 PM
To: Consulting Planner
Cc: Linda Evans; Robert Radi; Kathleen Fitzpatrick; John Pena; Steve Sanchez; cdd@la-quinta.org
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Dear Ms. Sauviat Criste:
I send this letter to express significant objections regarding the Coral Mountain Resort Draft EIR.
In brief, the subject document fails to comport with CEQA 2021 Guidelines:
https://www.califaep.org/statute and guidelines.php
• The subject document is 5x the volume stated in CEQA guidelines. As such the purpose and
intent of the guidelines are rendered impossible of performance.
• The current document is - in my opinion - an affront to the audience for which it is intended. A
reasonable person may ask why the developer and its agents sought to avalanche the
audience with such a grossly over -written, unnecessarily complicated document.
• Redundancies are pervasive throughout the document. Such writing techniques are
experience -proven methods to confuse, obfuscate and discourage the audience from
accomplishing a complete read. One wonders why the developer and its agents would adopt
this communications approach for a project they know to be controversial and objectionable to
many.
I respectfully request the subject DRAFT EIR be withdrawn. Further, I ask that the City of La Quinta
respect and observe CEQA guidelines in publishing a replacement DRAFT EIR. In doing so, readers
would have opportunity to absorb and comprehend contents presented in clear, concise, everyday terms
- as intended by CEQA. A corollary benefit would accrue to the City of La Quinta in the form of reader
audience appreciation for transparency.
Your consideration of my request is appreciated. Thank you.
Kenneth D. Jones
60179 Honeysuckle St.
La Quinta, CA 92253
KenJonesMail@aol.com
1 of 1 7/13/21, 8:58 AM
July 12, 2021
Attention: Ms. Nicole Sauviat Criste,
Consulting Planner
City of La Quinta
ConsultingPlanner@laquintaca.gov
Dear Ms. Sauviat Criste:
RE: Draft EIR Coral Mountain Resort
I am sending this letter to express my concerns regarding the Draft EIR that was
released for Coral Mountain Resort.
This document is not in keeping with the CEQA 2021 Guidelines
https://www.califaep.org/statute and guidelines.php
• It is too long. The CEQA guidelines stipulate that the document for a project should be
no more than 300 pages.
• It is not "rapidly understood" as required by the CEQA guidelines, again due in part to
its length, but particularly due to redundancy and repetition.
I respectfully request that this DRAFT EIR be retracted and reissued.
The replacement document should be created with the following in mind - it should be
reasonable in length, with clear and concise language, and without unnecessary
repetition. This would allow for "rapid" understanding by readers, and thus it would be in
alignment with the CEQA guidelines.
Thank you for your consideration of my request.
Brenda Vatlanc'
bdvatland@gmail.com
/9345 Toronja
La Quinta, CA 92253
cc: Linda Evans. Mayor E-mail: levans@laquintaca.gov
Robert Radi, Mayor Pro Tem E-mail: rradi@laquintaca.gov.
Kathleen Fitzpatrick, Council Member E-mail: kfitzpatrick@laquintaca.gov
John Pena, Council Member E-mail: jpena@laquintaca.gov
Steve Sanchez, Council Member E-mail: ssanchez@laquintaca.gov
Cherri Flores, Planning Manager, E-mail cdd@la-quinta.org
Carlos Flores, Senior Planner, E-mail cdd@la-quinta.org
Siji Fernandez, Associate Planner, E-mail cdd@la-quinta.org
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Dave Wiezel <hnldjw@yahoo.com>
Mon 7/12/2021 10:53 AM
To: Consulting Planner
Cc: Linda Evans; Robert Radi; Kathleen Fitzpatrick; John Pena; Steve Sanchez; cdd@la-quinta.org
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caution when opening attachments, clicking links or responding to requests for information.
To: Ms. Nicole Sauviate Criste, Consulting Planner, City of La Quinta
We are sending this email to express our concerns regarding the Draft EIR that was
submitted for Coral Mountain Resort recently.
The document, as currently submitted, is not in keeping with the CEQA 2021 Guidelines, as
specified at: https://www.califep.org/statute_and guidelines.php .
Most significantly:
- It is too long. The CEQA guidelines stipulate that the document for a project should be no
more than 300 pages.
- It is not "rapidly understood" as required by the CEQA guidelines, again due in part to its
length, but particularly due to redundancy and repetition.
We respectfully request that this DRAFT EIR be retracted and reissued in compliance with
the CEQA 2021 Guidelines. Additionally, the consultants and report preparers should be
required to provide clear and verifiable supporting data for every issue of concern.
Thank you for your consideration of our request.
Dave Wiezel
Bruce Tersiner
58540 Aracena, La Quinta, CA 92253
hnldjw@yahoo.com, tersiner@yahoo.com
Reply Reply all Forward
1 of 1 7/12/21,12:36 PM
Diane Rebryna, B.Sc.,D.D.S.
60149 Honeysuckle Street,
La Quinta, CA
92253
Attention: Ms. Nicole Sauviat Criste
Consulting Planner
BY EMAIL:
Good day Ms. Sauviat Criste,
Thank you for your email of this morning, July 13, 2021 with your explanation as to why the
current DEIR (also "the Document") will not be retracted and reissued, and advising us that
accordingly there would be NO extension beyond the August 6, 2021 date for comments.
Perhaps the City has "carefully and thoroughly reviewed the proposed Project", but I believe that
you are missing the point of my request.
Please understand that while a complex Project such as this requires analysis from the City's
perspective, it must also be presented in such a manner to allow for a detailed analysis by
the public and also allow for "rapid understanding".
I would again like to state that the document in its present format does not provide for this,
mostly due to its length, repetitiveness and redundancy. I will not repeat again the reasoning
behind our initial request of July 2, 2021.
I gather from your email that you feel that the document is "not unduly scientific or complex".
For reasons that I will not go into, I respectfully disagree; however the purpose of my response
herein is not to argue.
do propose a compromise please, particularly with respect to the Sections in Chapter 4.
Environmental Impact Analysis. I would like to see the 5 following items considered :
1. An expanded Table of Contents for Chapter 4.
***These 15 Sections are essentially the "meat and potatoes" of the DRAFT EIR
As the document stands, the Table of Contents for a 700 plus page Document is not at all
helpful.
By way of example, in the Section regarding Aesthetics (4.1) which comprises 73 pages (4.1.1-
4.1.72), I note 6 Subsections. These are:
4.1.1 Introduction,
4.1.2 Existing Conditions,
4.1.3 Regulatory Setting,
4.1.4 Project Impact Analysis
4.1.5 Cumulative Impacts, and
4.1.6 Mitigation Measures
However, when I go to the Table of Contents, I see ONLY "4.1 Aesthetics" referencing the
entire 73 page.
I ask please - why would the Sections relevant to each Chapter not be included ? - please see
2. below
2. Inclusion of the Subsections and Tables in the Table of Contents - with numbers,
letters and bullets as appropriate and appropriately cross referenced to pages in the
Document.
It is the subsections that pose an issue for the average reader such as myself.
For instance, when I proceed to go through Section 4.1.4 Project Impact Analysis, I note
the following "Subsections"
Thresholds of Significance
Methodology
Proposed Project
Character and Development Standards
PAI
PA II
PA Ill
PA IV
Circulation
Design Guidelines
Planning Area I - Neighborhood Commercial
Materials
Planning Area II - Low Density Residential
Materials
Massing and Scale
Architecture
Planning Area Ill - Tourist Commercial
Materials
Massing and Scale
Architecture
Planning Area III - Tourist Commercial
Offsite Infrastructure
Project Impacts
a. Have a substantial adverse effect on a scenic vista ?
Location "A"
Location "B"
all in different fonts, different sizes, some italics, some not, non indented,
etc. ; and these are in only the first 25 pages of the 73 for this Section !
I believe that you can see where I am going with this "illustration" above. This is not an easily
readable document, but in particular it is not an easy document to reference and therefore
understand.
My example refers to just Section 4.1.4 - the layout therein is the same throughout the
entire Document.
From my particular perspective as I conduct my review. I found that I am required create
my own "table of contents" for my ability to cross reference to allow for my
understanding.
Additionally, an expanded Table of Contents might allow me to gather data on a particular item -
for instance, the lighting. In one sub - section, its says that towers are 80 feet high, in another it
says that they will be lit from 7 AM - 10 PM, in another it says that there will be 17 - 80 foot
towers. etc. If this data is NOT provided in one sub- section, then at least a Table of Contents as
requested might be of help going forward.
I can assure you that this is no easy task to begin to gather and assimilate this data - as I
attempt to provide an intelligent response to the Draft EIR. An expanded table of Contents with
corresponding "lists" within the document itself would go a long way to helping me do this.
3. If it is possible, I would like to see this Document re -issued as a "searchable" PDF, with
hyperlinks as required to the Appendices. Modern technology easily allows for this.
4. I would like to see the entire Document proof read with respect to page numbers please.
For instance, I see that Section 4.1 has pages marked 4.1 ... whereas 4.2 has pages also
marked 4.1, ... - instead of 4.2.X.... Simple proof reading would have caught this error - I'm
asking please that you have someone do this. That way, when I make my own notes to refer to,
I am not going back through the document and unable able to find what I am looking for
because I am dealing with errors in the page numbering system.
5. I would like to see sub -sections entitled CONCLUSIONS limited to ONE per Section,
please. Too many of these have lead to my confusion on the topics therein.
In closing, I wish to say that this Project is very complex and potentially impactful to the
residents around it on so many levels.
There are many aging residents who reside in retirement communities near this proposed
Project. Many have invested their life savings in their forever homes and feel very afraid
because they cannot fully understand what this Project entails. Many can no longer concentrate
to the extent that they once could and are easily overwhelmed. Many are not computer savvy.
Some have told me that they feel inadequate and even "stupid" when they admit that they
cannot "understand" the DEIR when they try to read it.
My reply to them as been that "I feel inadequate as well " when faced with such a lengthy and
redundant document. You have indicated in your email today that redundancy "is required" for
the completeness of the document. Thank you for this explanation as I now understand and
accept that.
However, and to that I would say ... there should be extra attention on the City's part then to
ensure that as much detail is provided for the benefit of all readers in such a manner as to
allow for complete understanding. The acknowledgement and implementation of my 5
comments above would go a long way to providing for this.
Thank you for your kind consideration of my request.
I look forward to hearing back from you.
Regards,
Dr. Diane Rebryna
GEORGE H. KOENIG. M.D.
79-963 Rancho La Quinta Dr.
La Quinta, CA 92253
July 10, 2011
Nicole Sauviat Criste, Consulting Planner
City of La Quinta
78-495 Calle T ampico
La Quinta, CA 92253
Re: "Wave" at Coral Mountain
Dear Ms. Criste,
Tel: (760) 771-4141
Fax: (760) 771-4443
email: ghkmd@mac.com
18 years ago my wife and I moved to La Quinta and have been delighted over these years for
the move. During this time La Quinta has developed its commercial base in a logical and
geographic manner and has maintained a wonderful residential environment. I was surprised
at the proposed project of a water park at Coral Mountain, as discussed nicely in a recent
article in the Desert Sun.
I read the article, perused the project on-line, obtained a bigger printout at City Hall, and drove
to the site to view it. I was left with a number of questions:
I believe the site was once part of the initial plans for Andalusia but was spun off as
economically unfeasible. In fact I understand the developer -Drummond, a corporation with
enormous financial reserves - has subsequently sold Andalusia as well. The site is roughly six
miles from Citrus Plaza (Jefferson and 50) at the very end of Madison, a long way if one has
forgotten a grocery item. If Andalusia failed to flourish one must wonder about the new
proposal. The rationale for a new development of expensive homes is puzzling.
The entire length of Madison Avenue is full of high-end residential developments. A major
resort would be in sharp contrast to the environment surrounding it. Independent of the wave
a hotel of any viable size would be completely out of place; issues to include building height
and traffic.
The plans call for a golf course. I think a number of golf courses are experiencing a decrease
in use. The area is also surrounded by a number of courses - PGA, Silver Rock, and others.
Who would be the market target for a new distant course is unclear.
Although the proposal for WAVE phenomenon's sound abatement is discussed, it seems likely
that such a feature is likely to be noisy - whatever good intentions of the builder.
Since it is unlikely that the immediate neighborhood would use the structure one must assume
that the users would not be local, more likely a youthful and loud group. How this would sit
with the owners of expensive homes immediately adjacent would surely affect their sales
prospects.
The Desert Sun noted 3 other water park developments underway or about to begin
development. All three would not only compete for a limited market but would be located in far
more convenient locations for prospective customers - remembering the really isolated site
under consideration. How the Coral Mountain wave would attract customers is surely unclear.
If one considers all the headaches and frustration with Silver Rock, certainly a better conceived
and eventually successful undertaking I would understand if the City would approve what
looks like an even less viable undertaking with profound concern. If it were to proceed and
then fail who would be left holding the bag? The City? Who would want to acquire an isolated
development with a water park?
The "Wrong Project in the Wrong Place" certainly seems an appropriate comment. Personally I
would not invest my money in it.
Thank you for the opportunity to comment.
Yours very truly,
r r�
G rge H. Koenig, MD
CC: The Desert Sun
750 N. Gene Autry Trail
Palm Springs, CA 92262
Tuesday, July 27, 2021 at 15:30:09 Pacific Daylight Time
Subject: "Coral Mountain Resort DEIR"
Date: Thursday, July 15, 2021 at 10:51:34 AM Pacific Daylight Time
From: SSTRATTON@dc.rr.com
To:'Consultingplanner@laquintaca.gov'
CC: 'levans@laquintaca.gov', 'rradi@laquintaca.gov', 'kfitzpatrick@laquintaca.gov',
'jpena@laquintaca.gov', 'ssanchez@laquintaca.gov'
WATER SUPPLIES:
Please take into serious consideration the Mega Drought that the Western US is experiencing. I do not believe that
the reports on water available from our aquifer accurately address the water sources to replenish our aquifer to keep
it at safe levels for the foreseeable future.
I am a resident of Trilogy La Quinta and a California native. The drought is severely impacting farmers and ranchers
here and the western US. One newspaper article in Oregon highlights forward thinking errors.
"It was predicted that Prineville Reservoir would fill. It was predicted there would be natural flow for us with our
water right in the Crooked River. It was predicted there would be natural flow for us in the Deschutes (river). NONE
OF THOSE THINGS HAPPENED." - Marty Richards, board chair for North Unit, said the drought conditions this spring
and summer forced the irrigation district to reevaluate its water supplies." Farmers/ranchers are losing their water
supplies. The Wickiup Reservoir will be empty by August 18.
My point being, why are we relying on the Colorado River without question for our precious water supply here in the
desert. "The Colorado River is drying up faster than federal officials can keep tract. Mandatory water cuts are
looming. Plummeting reservoir levels at Mead and Powell solidify Arizona cutbacks next year and near -future threats
to all Compact states from Colorado to California" (source: The Colorado Sun)
LIGHT POLUTION:
Every morning and evening I sit outside and enjoy the beautiful Coral Mountain and it's changing colors at sunrise
and sunset. Seventeen 80 foot tall light towers will permanently ruin everyone's views of the Coral Mountain.
STVR's:
The city of La Quinta has suspended permits for STVR's in residential zones. The impact of 600 STVR's will impact the
surrounding communities far more that allowing them in residential zones.
ZONING CHANGE:
This area is not appropriate for Tourist Zoning. Having special events will cause more traffic, noise, rowdy parties at
the STVR's. This will turn 58th and 60th and Madison into major traffic arteries. We already have car races on 60th
and cars doing doughnuts at the corner of Madison and 60th. Look at the tire marks! Was this in a report? This will
only encourage more traffic problems.
To call this project a PRIVATE COMMUNITY is a joke. Only a small amount of lots, roughly 24, are private. 24 private
homes vs 600 STVR's? That proportion makes absolutely no sense. The few private lots are just a way to make the
whole project look private. It's a PUBLIC VENUE!!
This entire project is totally irresponsible. This is California with 700+ miles of coastline. A surfing venue does not
belong in the desert! This would be a permanent disruption to our quiet life in the desert, ruin our views, destroy
our quiet evenings, just so promoters and surfers can make money on Special Events.
Page 1 of 2
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Wave park please no attached photos are a big horn crossing 58 where would he go if
not killed by a car coming to a wave park where he lives
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CG
Connie Glavin <cjglavin@yahoo.com>
Fri 7/16/2021 6:43 AM
To: Consulting Planner
IMG_1281.HEIC
1 MB
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Sent from my iPhone
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1 of 1 7/16/21, 9:27 AM
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Water Park
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DG
Dan Rendino Gmail <danrendino@gmail.com>
Sun 7/18/2021 2:32 PM
To: Consulting Planner
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Who came up with this insane idea to turn our town into a Disneyland in the middle of a
drought. The traffic and noise will be an Eyesore in the desert. Send this proposal down.
Dan Rendino
80390 Weiskopf
La Quinta CA 92253
danrendino@gmail.com
760.880.3275
Reply Forward
1 of 1 7/19/21, 7:56 AM
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La Quinta Wave Park
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JT
JoAnne Thompson <joswabt555@aol.com>
Sun 7/18/2021 5:33 PM
To: Consulting Planner
** EXTERNAL: This message originated outside of the City of La Quinta. Please use proper
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Ms. Nicole Sauviat Criste,
We will make this short and sweet. Please do the right thing about the proposed Wave Park
in La Quinta. We are in the worst drought in 1000 years. Do you think this Wave Park makes
sense on any level?
We strongly oppose this development and hope you will hear our voices.
JoAnne Thompson
Bob Ruehl
Sent from my iPhone
Reply Forward
1 of 1 7/19/21, 7:55 AM
CAROL L. STROP CPA
A PROFESSIONAL CORPORATION
60499 JUNIPER LANE • LA QUINTA, CALIFORNIA 92253 • (760) 445-9911 • FAX (760) 619-3372
July 10, 2021
To the City of La Quinta
Attn: Nicole Sauviat Criste, Consulting Planner
78-495 Calle Tampico
La Quinta, CA 92253
Re: Coral Mountain Resort DEIR
Let me start by saying my husband, Richard, and I love everything about La Quinta, how it was designed
and how it is managed. Of course we know that additional growth leading to increased revenue is
important for any city. When the builder first introduced this Coral Mountain project to the homeowners
at Trilogy La Quinta last February I thought, as presented, that it sounded reasonable. The La Quinta city
planners obviously thought so, too. Videos were shown to the residents of the Wave in Lemoore, CA and
each was conveniently orchestrated with music overlays as are all videos on the Surf Ranch website.
There are various resident complaints and concerns on many fronts in all the surrounding communities. 1
would like to focus mine on the Wave, its level of noise, water usage and proposed popularity. I think the
most important things I learned in my internet research are these:
l . Kelly Slater's Wave in Lemoore (now owned by WLS Holdings) is in the middle of nowhere, set
in wide open farmland of cows and agricultural fields in Central California. And that is where is
belongs, not in an upscale residential community where the residents who moved to this end of
the Coachella valley came for a quiet, peaceful lifestyle. Many are retired and home all day, with
no escape from the sounds of the wave.
2. The wave is pulled by a locomotive engine. This will not be the sound of an occasional train
passing through, but a constant sound throughout the day and evening. My husband and I have
lived in the mountains and know firsthand how the sound bounces off them. Months ago I read
reviews by surfers related to the noise of the Wave but those reviews have magically disappeared
from the Internet.
3. The Wave Pools require an enormous amount of water to pump out artificial waves. According to
Wired, the Surf Ranch in Lemoore is filled with 15 million gallons of UV -and -chlorine -treated
water — 250,000 of which can evaporate from the lagoon on an extremely hot day. Really, here
in the desert? And on June 21, 2021 a major water tank exploded in Lemoore - just mentioning
it...
4. Last year the quarantine'prevented me finding many surfer reviews but just today I found that
there had been a Jeep Surf Ranch contest in Lemoore in June, 2021. The Wave may not be the
economic boom the city hopes for. Here is an excerpt regarding that contest-
https://beachgrit.com/2021/06/why-did-surf-ranch-fail-as-wave-pool-tech-and-as-a-contest-so-
The gap between the rhetoric, that tubs were going to loose a tsunami of radical
innovative surfing, and the reality, conservative surfing, is becoming clearer every
day. It's become what Orwell termed the "inadmissible fact." It's put us in upside down
world, where Chris Cote, when he hears the train says, "This never gets old" means
"there's something deeply wrong here but I can't dare acknowledge it".spectacularly-a-
dull-ache-of-unrealised-desire-at-the-deathless-sight-of-that-impossibly-perfect-wave/
On a recent post featuring the seven -time world champion Stephanie Gilmore at the
tank, World Surf League fans wrote,
Snooze. Throw in the air section.
Most uninteresting event on tour. Every time I see this wave I keep scrolling.
Good for training, horrible for contest. RIP WSL.
S00000000 b0000ring.
Same commentary on every wave... stick to mother ocean.
And so on.
5. Attendance at the Wave is costly. Who is really the market for it and how large can it be to
support this? From https://wavepoolmag.cornikelly-slater-wave-pool-versus-bsr-surf resort/
December 27, 2018
This autumn Big Dog got an invite from a group of friends pitching in to buy a day at the Kelly
Slater Surf Ranch. For $32,000 off-season rate (peak season is $50K), surfers get 15 waves per
hour during an 8 -hour day to share. This means the glorious locomotive wave -maker will run
along the tracks 120 times during your session. So for example, if you bring 16 surfers for an off-
season day, that works out to $2,000 a surfer. Each one will get 7 -to -8 priority waves.
The La Quinta draft Environmental Impact Report for the Coral Mountain Resort considered noise to be
"less than significant with mitigation measures". Below is an excerpt from the operational noise impact
report prepared by Urban Crossroads.
Quoted from section recreational pool (wave basin) EIR Urban crossroads
OPERATIONAL NOISE ANALYSIS Using reference noise levels to represent the expected noise sources
from the Coral Mountain Specific Plan site, this analysis estimates the Project -related stationary -source
noise levels at nearby sensitive receiver locations. The normal activities associated with the proposed
Coral Mountain Specific Plan are anticipated to include wave basin/wave machine activity, outdoor
pool/spa activity, outdoor activity, and neighborhood commercial land use activity. The operational
noise analysis shows that the Project -related stationary -source noise levels at the nearby sensitive
receiver locations will satisfy the City of La Quinta daytime exterior noise level standards, with no
planned nighttime activities. Therefore, the operational noise impacts are considered less than
significant at all existing off-site receiver locations. Further, this analysis demonstrates that the Project
will contribute a less than significant long-term unmitigated operational noise level increase to the
existing daytime ambient noise environment at all existing off-site receiver locations.
What are the mitigation procedures to which you refer in the EIR? And what about nighttime noise? The
advertising includes evening hours. Has someone from the City of La Quinta actually visited Lemoore to
assess the level of noise? Maybe this is a big deal about nothing! But the utilization of energy and water
resources needed to run this Wave is not.
We hope you and the builder will consider one of the other scenarios that exclude the Wave as shown in
the Urban Crossroads appendix SCH# 2021020310 for trip generation comparison. I have to say, the
traffic analysis report, in itself, is mind-boggling. Hotel revenues are great for the City, but there two
exclusive hotels already being built just up the road across from PGA West.
Please take care of your year round residents; there are more and more of us. And in an economic
downturn, we are your revenue base. The builder will be long gone, along with the hotel guests.
Thank you,
Carol Strop
„Stze-4.
Richard Strop
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT ALENA CALLIMANIS
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
From: Alena Callimanis
Sent: Tuesday, July 20, 2021 1:28 PM
To: City Clerk Mail
Cc: Monika Radeva
Subject: Monika, my presentation without the videos that can be distributed to the Council and staff
Attachments: CallimanisLaQuintaPresentation7202021withoutvideoB.pdf
Follow Up Flag: Follow up
Flag Status: Flagged
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opening attachments, clicking links or responding to requests for information. **
Monika, I created this file "without video" so it is very small. This way I respectfully request that it can be now
distributed to the Council and staff. I still hope we can show my version with the videos.
Alena Callimanis
1
Impact of Coral Mountain
Surf Resort
Alena Callimanis
La Quinta CA 92253
Right after Sunset Looking at Coral Mountain
from Lisa Castro's house on 60th
Night sky panorama on 60th from Guillermo's house
across Coral Mountain to Lisa's House July 19 at 8:38pm
Video of Night Sky and sound: Coral Mountain from Guillermo's
house to Lisa's house
Video removed due to size.
This video shows the dark
Coral Mountain and
features only the sound of
crickets. Request copy of
video from
acallimanis@gmail.com
Hearing just crickets
Video removed due to size.
This video shows the dark Coral
Mountain area and and the sound
of a car on Madison. Madison is
further from this point than from
this point to the Wave Basin.
Request copy of video from
acallimanis@gmail.com
Hearing a car on Madison which is further away than the Basin
is from this point
Picture from the 58th St near Madison —what is that
Iight?
Bagdouma Park in Coachella —Light is always
diffused and visible due to particulates in our air
(the light on the right is 60 feet)
Please don't let the developer insult us by
saying there will be no light and noise impact
to the surrounding developments
This will be physically impossible considering
the location with quiet nights in this area of
the desert, plus the proximity to Coral
Mountain with sound echoing and
reverberation off the mountain and light
reflection and dispersion
11I1111 11111
IIlulu111 l
duuauu1
;I III IM Mil
..d (• .4..O.m uo..rr11m, eaw.anx
LAnissaiteaL
❑lay of La quad Gianni Plan
L1M Lw MM
Li Wolk GMeanra
203
Excerpts from La Quinta General Plan 2035 —Land Use
Policy LU-3.1
Encourage the preservation of neighborhood character and assure a
consistent and compatible land use pattern.
GOAL LU-4
Maintenance and protection of existing neighborhoods.
Policy LU-4.1
Encourage compatible development adjacent to existing neighborhoods and
infrastructure.
GOAL SC-1: A community that provides the best possible quality of life for all
its residents.
GOAL OS-3: Preservation of scenic resources as vital contributors to the City's
economic health and overall quality of life.
We want Low Density Residential
at this Site and NOT 100% STVRs
and a Wave
Preserve this beauty and serenity for the
five developments around Coral Mountain
and for the new 100% low density
residential development that should be
on this magnificent this property
Please no Zoning Change!
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT LISA CASTRO
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
From: Alena Callimanis
Sent: Tuesday, July 20, 2021 12:37 PM
To: City Clerk Mail
Cc: Monika Radeva; Lisa Castro
Subject: Presentation by Lisa Castro for public comment session for July 20 City Council Meeting
Attachments: Lisa Castro City Council Presentation.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. **
Here is the document that Lisa Castro will be using while speaking during the public comment
period at today's City Council meeting at 4pm.
Lisa will be in person.
Thank you very much.
Alena Callimanis
1
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT LISA CASTRO
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
Good Afternoon Honorable Mayor Evan, Council Members and Staff. My
name is Lisa Castro and I am a resident at First I would
like to thank Alena for the pictures and videos she showed you from my
house. The videos just record the lack of noise from my house and that
you can slightly hear a car on Madison. Think of HOW many cars will come
and go through the night in a rezoned area.
The point is that the wave basin is closer to me than Madison so if I can
hear the car, just think of the noise every night - not just the waves
crashing as the promo for the developer says and the noise of the wave
machinery, but the people noise - surfing, jet skis, music etc, etc....
the "people noise" that a rezoning change will allow. And the people
noise at night will increase exponentially in the summer because it will be
too hot for them to "surf" during the day!!
Also, water will be so hot during the summer months because it is only six
feet deep at its maximum on a concrete pool. And the evaporation alone is
enormous.
am a little more than halfway up the unpaved Avenue 60 toward Coral
Mountain. I have lived there for 30 years.
Guillermo and I are the closest houses to this development. It is fair to say
the driveway into the development as well as parking areas are right next to
my house.
have spoken to Garrett Simon the developer many times at my house.
During the latest meeting he told me that I will not be impacted by light and
noise.
asked Garrett to please sign a document to that effect and he said no.
told him that I would be severely impacted by the dust and dirt during
construction, that I have asthma, and that my pool and air conditioners
would get clogged with dust and dirt.
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT LISA CASTRO
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
His colleague with him told me to move away during construction.
How insulting is that! Garrett told me that the grading on the property
would be done in six weeks. I know that it is closer to six months. My
family was in the grading business. Is he thinking he can push me
around because I am alone?
am also concerned about the constant vibrations caused by the waves due
to the tremendous weight and force of 18 million gallons of water. I am only
around 600 feet from the wave pool. All the seismic records were done at
the wave pool at Lemoore California which has totally different soil
composition. We are above the aquifer on sandy soil. So the developer has
no idea of the impact of the wave motion to our area.
can attest to the fact that I am in a wind tunnel. The wind whips around
from the Quarry and I have clocked the wind at 60 mph. When
mentioned this to Garrett he acted like he didn't believe me.
That will also add to extreme evaporation.
Maintenance and construction trucks will be lined up outside my house
because of the restrictions that they can't start working until 7AM. Since
the wave is operating from 7AM to 10PM every day, 365 days a year, they
will probably need to do maintenance during the night. And what about the
heavy chlorination they will need to do during the heat? I will
be exposed to chlorine in the air everyday.
This project is a disaster for me as well as for our neighbors.
Please do not approve the zoning change that will allow all of this to happen.
Thank you very much.
Mail - Consulting Planner - Outlook https://outlook.office.com/mail/deeplink?popoutv2=1 &version=202107...
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Coral Mountain Resort DEIR
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C
cathy <cagiles100@gmail.com>
Tue 7/20/2021 7:17 AM
To: Consulting Planner
** 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. **
As a resident of Andelusia, next to the proposed wave park, I am concerned about the noise
and light that the proposed development would bring to our community. I don't think it
should be tourist zoned and really don't want the disruption that a wave park will bring to
our peaceful community.
Sincerely,
Catherine Giles
81692 Rhonda
La Quinta
Reply Forward
1 of 1 7/20/21, 12:48 PM
Tuesday, July 20, 2021 at 12:52:36 Pacific Daylight Time
Subject: FW: The proposed Coral Mountain Resort
Date: Tuesday, July 20, 2021 at 11:44:01 AM Pacific Daylight Time
From: Cheri Flores
To: Nicole Criste, Danny Castro
Priority: High
Attachments: image001.png
FYI
Another comment letter.
UALIFORNIA
Cheri L. Flores 1 Planning Manager
City of La Quinta
78495 Calle Tampico La Quinta, CA 92253
Ph. 760-777-7067
www.laquintaca.gov
PLEASE NOTE: City Hall is now open to the public during normal business hours:
Monday through Thursday from 7:30 a.m. to 5:30 p.m. and Friday from 8:00 a.m. to
5:00 p.m. (Counter closes at 4:30 p.m. daily), with the exception of nationally
observed holidays. Please follow all CDC and State recommended guidelines as they
pertain to COVID-19 safety and awareness. All public services continue to be available
via phone, email or online web portal and the public is encouraged to utilize these
services when possible. Thank you.
From: Holub, Richard D. <rdh@rdholub.com>
Sent: Tuesday, July 20, 2021 11:14 AM
To: Linda Evans <Levans@laquintaca.gov>
Cc: Robert Radi <Rradi@laquintaca.gov>; Kathleen Fitzpatrick <kfitzpatrick@laquintaca.gov>; John Pena
<jpena@laquintaca.gov>; Steve Sanchez <ssanchez@laquintaca.gov>; Cheri Flores <clflores@laquintaca.gov>
Subject: The proposed Coral Mountain Resort
Importance: High
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.
Dear Mayor, Council Members and Planning Manager,
I have been a LQ resident for over 15 years. My letter to you regarding the proposed Coral Mountain Resort
development is based upon over 20 years of successful real estate development experience in the Temecula
Page 1 of 2
Valley - an area very similar to the economic and social environment found in La Quinta.
The proposed Coral Mountain Resort with its massive wave feature and disruptive presence (lighting, overall
use, traffic impacts, etc.) are ill-suited for that specific area and this community. Not to mention the grossly
abusive water use. The mere appearance of that issue alone should be off-putting and give Counsel pause in
the re -zoning of that area.
Considering all those factors, and in my professional opinion, this proposed development is not in the best
interest of the La Quinta community — in fact, it is "irresponsible development" personified. Please, listen to
your continuants from the LQRRD and acquiesce to their demands.
Thank you for reading and for your consideration of my opinion.
Sincerely yours,
Richard D. Holub
C: 760.464.46431 Skype: 760.459.45451E: rdh@rdholub.com
This email and any files transmitted with it are confidential and intended solely for the use of the individual or entity to whom they are addressed. If
you have received this email in error please notify us immediately by return email to this address, or call 760.464.4643 then delete this email. If you
are not the named addressee you should not disseminate, distribute or copy this e-mail. If you are not the intended recipient you are notified that
disclosing, copying, distributing or taking any action in reliance on the contents of this information is strictly prohibited. Thank you.
Page 2 of 2
Wednesday, July 21, 2021 at 09:25:32 Pacific Daylight Time
Subject: FW: Attention Cherri Flores, Planning Manager
Date: Tuesday, July 20, 2021 at 4:56:10 PM Pacific Daylight Time
From: Cheri Flores
To: Nicole Criste
CC: Danny Castro
Attachments: image001.png
Nicole,
Another comment for the Wave.
hiatintai
CALIFORNIA
Cheri L. Flores 1 Planning Manager
City of La Quinta
78495 Calle Tampico La Quinta, CA 92253
Ph. 760-777-7067
www.laquintaca.gov
PLEASE NOTE: City Hall is now open to the public during normal business hours:
Monday through Thursday from 7:30 a.m. to 5:30 p.m. and Friday from 8:00 a.m. to
5:00 p.m. (Counter closes at 4:30 p.m. daily), with the exception of nationally
observed holidays. Please follow all CDC and State recommended guidelines as they
pertain to COVID-19 safety and awareness. All public services continue to be available
via phone, email or online web portal and the public is encouraged to utilize these
services when possible. Thank you.
From: Rob Michiels<rmichiels@consiliumassociates.net>
Sent: Tuesday, July 20, 2021 4:55 PM
To: Cheri Flores <clflores@laquintaca.gov>
Cc: Ria Michiels <michiels.ria@gmail.com>; mike charles <mgacharles@yahoo.com>; RFBAEZ7@gmail.com
Subject: Attention Cherri Flores, Planning Manager
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.
Good afternoon Ms Flores,
I would like to voice my strong opposition to the wave park project at Coral Mountain.
My wife and I have been homeowners at Andalusia for the past 11 years. I believe I am
also speaking on behalf of many of my neighbors.
We joined this beautiful Andalusia community because:
We love the peace and quiet;
We love the immaculately dark and clear night skies;
We were told the patch of wild and untamed desertscape across from us would
eventually be developed into a similarly quiet and uncrowded golf/low density residential
community.
Page 1 of 2
So, imagine our dismay when that property was sold to another developer, who has
quickly, and under the radar, moved to change the zoning from low density residential to
high impact commercial.
We do not understand why the city of La Quinta would have given the initial permission
for that zoning change so this ill-conceived project could move forward to this stage of
planning?
Do our city leaders really want to tie their political legacy to the desecration of one of the
last truly unique and peaceful tracts of La Quinta land by unscrupulous developers who
want to change it into a circus like attraction every day all year round? Why go forward
and spend untold dollars on investigations when any person with common sense knows
this can and should be stopped right now by the city simply holding fast to the original
zoning?
Why waste millions of gallons of drinking water when we are in the midst of a drought?
The so-called expert reports submitted in support of this project are at best theoretical
re -do's of earlier reports (from other projects). No real science or experiments are
behind these reports. They should be refused and refuted.
Is the only underlying agenda that wants to allow this permitting process change the
pursuit of a few extra dollars promised for your city coffers? As my grandmother rightly
said: beware of promises!
If you go forward, I believe future generations will not look kindly on your legacy.
Thank you for your consideration.
Rob & Ria Michiels-Denayer
81301 Andalusia
La Quinta, CA 92253
Rob Michiels
Founding Partner
CONSILIUM Associates LLC
Cell +1 949 677 4165 (No Texting)
Email RMichiels@consiliumassociates.net
This message is intended only for the use of the individual or entity to which it is addressed, and may contain
information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this
message is not the intended recipient, or the employee or agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or
return e-mail. Thank you, CONSILIUM.
Page 2 of 2
Mail - Consulting Planner - Outlook https://outlook.office.com/mail/deeplink?popoutv2=1 &version=202107...
<5 Reply all "/ ® Delete 0 Junk Block ••
In opposition of a Wave park a Coral Mountain
0 Label: 60 Days Delete (60 days) Expires: Sat 9/18/2021 4:24 PM
RM
Rob Michiels<rmichiels@consiliumassociates.n < <5
et>
Tue 7/20/2021 4:24 PM
To: Consulting Planner
Cc: Ria Michiels <michiels.ria@gmail.com>; Mike Charles <mgacharles@yahoo.com>; Ramon Ba(
** 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. **
Good afternoon and thank you for allowing me to voice my strong opposition
to this project.
My wife and I have been homeowners at Andalusia for the past 11 years. I
believe I am also speaking on behalf of many of my neighbors.
We joined this beautiful Andalusia community because:
Ne love the peace and quiet;
Ne love the immaculately dark and clear night skies;
Ne were told the patch of wild and untamed desertscape across from us
would eventually be developed into a similarly quiet and uncrowded golf/low
density residential community.
So, imagine our dismay when that property was sold to another developer,
who has quickly, and under the radar, moved to change the zoning from low
density residential to high impact commercial.
We do not understand why the city of La Quinta would have given the initial
permission for that zoning change so this ill-conceived project could move
forward to this stage of planning?
Do our city leaders really want to tie their political legacy to the desecration of
one of the last truly unique and peaceful tracts of La Quinta land by
unscrupulous developers who want to change it into a circus like attraction
every day all year round? Why go forward and spend untold dollars on
investigations when any person with common sense knows this can and
should be stopped right now by the city simply holding fast to the original
zoning?
Why waste millions of gallons of drinking water when we are in the midst of a
drought?
1 of 1 7/21/21, 9:22 AM
Mail - Consulting Planner - Outlook https://outlook.office.com/mail/deeplink?popoutv2=1 &version=202107...
<5 Reply all "/ ® Delete 0 Junk Block ••
Coral Mountain Resort DEIR"
0 Label: 60 Days Delete (60 days) Expires: Sat 9/18/2021 7:05 AM
EP
Eva Parker <geneva456@hotmail.com>
Tue 7/20/2021 7:05 AM
To: Consulting Planner
** 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. **
We want to express our strong opposition to the planned Coral Mountain
Development and Wave Park. My husband and I moved to La Quinta and
purchased our retirement home here in a 55 and over community so we
could enjoy our final years in peace and quiet. We specifically purchased
in Trilogy La Quinta as it was far away from the hustle and bustle and
traffic of the downtown area. We anticipated other housing
developments and hotels would eventually be built in the surrounding
open spaces, but we never imagined a Tourist/Commercially-zoned mega
resort with a Wave Machine, professional competitions, and
entertainment stages would be built a few blocks from our quiet
retirement community. This is so unfair to the surrounding homeowners
who moved here expecting a quiet and peaceful environment.
We ask that you please put yourself in our place and recommend against
this project.
Thank you for your consideration.
Eva Parker
Reply Forward
1 of 1 7/20/21, 12:46 PM
Tuesday, July 27, 2021 at 15:28:58 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR (Revised/ Corrected )
Date: Tuesday, July 20, 2021 at 1:24:51 PM Pacific Daylight Time
From: rstowe@farmersagent.com
To: 'Consulting Planner'
Attachments: image001.png, Waterline.JPG
To whom it mat concern,
I built a home directly across the street from this proposed project in 2004 and have lived in the desert full
time for 28 years. I have 5 Surfboards hanging in my garage right across the street waiting for me to pull one
down to make the 6 hour round trip to San Onofre just to surf for 2 hours. One might think I would be the
greatest proponent of the surf park, but no I am not. I must admit I was super excited when I heard the news
about the surf park. Kelly Slater is one of my hero's and I actually had the chance to meet him in Hawaii not
to long ago. I will probably become a member of one of the surf parks in the desert for sure. But This is
definitely not the area for one. The impact on the beautiful environment nestled up against the BLM Santa
Rosa Range is much more important than an Amusement Park aka Surf Park.
Whenever I get a chance, I tell all my friends and visitors about the Ancient Lake Cahuilla and the Waterline. I
show them proof with all the tiny sea shells I have collected that I found in my yard. I tell them about the
story of the misnomer of Conchilla Valley vs Coachella Valley (www.coachella.org/about-us/history). I
remember when there was talk about a nature park slated next to Lake Cahuilla, I was so excited. I am sorry
that never transpired. People from all over come up here to hike and camp at Lake Cahuilla to enjoy the
serenity we offer. Clients, Visitors and Residents all tell me how nice it is to come here and actually see the
stars, something they do not see anymore where they come from.
Some local homeowners speculate it will increase property values other think it will decrease. I believe the
values will increase either way with or with out the amusement park. I didn't build here, raise my family, and
stay here because of property values. I bought and built here because of the beauty and serenity. So did
everyone else.
La Quinta does not need the money that bad. We (The City, Business Owners, and Residents) do not need this
development bad enough to destroy such a historic and serene area. Another country club, resort home
community with minor commercial at this location would be ideal, not an Amusement Park aka Surf Park.
I raised two children in La Quinta, right across the street. I have owned a business in the desert for 31 years.
I know there is not much for young people to do here other than Golf or Tennis. A surf park is a great idea,
just not next to the waterline and Multi Million Dollar Homes, really? There is plenty of vacant land around
the desert. Just because they got a good deal on the land doesn't make it right. They do not have the right to
destroy our scenic night skies and bring thousands of daily visitors to a quiet neighborhood. You at the city
are our last defense. You must make a difficult decision I know. You cannot let these developers snowball
you to think this is a good idea, it's not! Let them move over to the other side of Monroe and let Indio have
this one. Indio needs this more than La Quinta. It will be just like the Festivals, they will visit the Amusement
Park then dine and stay in all of our nice restaurants, hotels and rentals. We do not need this in La Quinta. It
is not good for La Quinta. It will change the neighborhood in a very negative way. After the excitement of the
new project wears off it would go down as one of the worst decisions the City La Quinta has ever made.
Attached you will see a painting I have hanging in my foyer right across the street from the proposed project.
Feel free to zoom and take a close look at it. I had this commissioned back in 2004. I asked the painter to
paint that land/ waterline like it looked years ago so my grandchildren would know what it looked like
knowing it would be developed someday. Let it be a responsible development please. I never thought it
would end up being a surf park! Really? Please do not let this happen. Thank you!
From: rstowe@farmersagent.com <rstowe@farmersagent.com>
Sent: Tuesday, July 20, 2021 12:30 PM
To: consultingplanner@laquintaca.gov
Page 1 of 3
Subject: Coral Mountain Resort DEIR
To whom it mat concern,
I built a home directly across the street in 2004 and have lived in the desert year around for 28 years. I have 5
Surfboards hanging in my garage waiting for me to pull one down to make the 6 hour round trip to San
Onofre just to surf for 2 hours. One might think I would be the greatest proponent of the surf park, but no I
am not. I must admit I was super excited when I heard the news about the surf park. Kelly Slater is one of my
hero's and I actually had the chance to meet him in Hawaii not to long ago. I will probably become a member
of one of the surf parks in the desert for sure. But This is definitely not the area for one. The impact on the
beautiful environment nestled up against the BLM Santa Rosa Range is much more important than an
Amusement Park aka Surf Park.
Whenever I get a chance, I tell all my visitors about the Ancient Lake Cahuilla and the Waterline. I show them
proof with all the tiny sea shells I collected that I found in my yard. I tell them about the story of the
misnomer of Conchilla Valley vs Coachella Valley (www.coachella.org/about-us/history). I remember when
there was talk about a nature park slated next to Lake Cahuilla. I am sorry that never transpired. People from
all over come up here to hike and camp at Lake Cahuilla to enjoy the serenity we offer. Clients, Visitors and
Residents all tell me how nice it is to come here and actually see the stars, something they do not see
anymore where the come from.
Some local homeowners speculate it will increase property values other think it will decrease. I believe the
values will increase either way with or with out the amusement park. I didn't build here, raise my family, and
stay here because of property values. I bought and built here because of the beauty and serenity. So did
everyone else.
La Quinta does not need the money that bad. We (The City, Business Owners, and Residents) do not need this
development bad enough to destroy such a historic and serene area. Another country club, resort home
community with minor commercial at this location would be ideal, not an Amusement Park aka Surf Park.
I raised two children in La Quinta, right across the street. I have owned a business in the desert for 31 years.
I know there is not much for young people to do here other than Golf or Tennis. A surf park is a great idea,
just not next to the waterline and Multi Million Dollar Homes, really? There is plenty of vacant land around
the desert. Just because they got a good deal on the land doesn't make it right. They do not have the right to
destroy or scenic night skies and bring thousands of daily visitors to a quiet neighborhood. You at the city are
our last defense. You must make a difficult decision I know. You cannot let these developers snowball you to
think this is a good idea, it's not! Let them move over to the other side of Monroe and let Indio have this
one. Indio needs this more than La Quinta. It will be just like the Festivals, they will visit the Amusement
Park then dine and stay in all of our nice restaurants, hotels and rentals. We do not need this in La Quinta. It
is not good for La Quinta. It will change the neighborhood in a very negative way. After the excitement of the
new project wears off it would go down as one of the worst decisions the City La Quinta has ever made.
Attached you will see a painting I have hanging in my foyer right across the street from the proposed project.
Feel free to zoom and take a close look at it. I had this commissioned back in 2004. I asked the painter to
paint that land/ waterline like it looked years ago so my grandchildren would know what it looked like. We
know it would be developed someday. But let it be a responsible development. I never thought it would end
up being a surf park! Really? Please do not let this happen. Thank you!
Robert Stowe 760-578-9089
Insurance Agent
rstowe@farmersagent.com
"We take pride in the customer service we provide...give us a try!"
Page 2 of 3
FARMERS
INSURANCE
Robert Stowe Insurance Agency, Inc.
79710 Hwy 111, Ste 100
La Quinta, CA 92253-6516
(760) 342-2786 office
(760) 342-6803 fax
CA License #0E20458
NOTICE: PRIVILEGED AND/OR CONFIDENTIAL INFORMATION. This e-mail and any files transmitted with it
are the property of the Robert Stowe Insurance Agency, Inc. and/or the Farmers Insurance Group of
Companies. This email message and any attached documents may contain information that is privileged,
confidential and exempt from disclosure under applicable law. This email message and any attachments
are for the use of the named recipient, employee or agent it is addressed to and can only be used for its
intended purpose; any other use is prohibited. Any recipient of this email is notified that dissemination,
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this communication in error, please notify the sender immediately.
We value your privacy. The law requires that we disclose the categories
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interactions with you to provide service, or for other purposes as explained on
the Farmers website.
The categories of information that may be collected include financial,
historical, internal, external, social and tracking.
If you would like additional information about our privacy practices, please
see the following website:
www.farmers.com/privacy-center.
Page 3 of 3
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT SHEILA WARREN
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
From: Alena Callimanis
Sent: Tuesday, July 20, 2021 12:40 PM
To: City Clerk Mail
Cc: Monika Radeva; Sheila Warren
Subject: Presentation today by Sheila Warren at the public comments section of today's City Council meeting
Attachments: Sheila Warren City Council Presentation.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. **
Here is the document that Sheila Warren will be using during today's City Council meeting.
Sheila will be at City Hall in person.
Thank you very much.
Alena Callimanis
1
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT SHEILA WARREN
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
Good day Honorable Mayor Evans, Council Members and Staff. My name is
Sheila Warren and I am a Trilogy Resident. I have two quick things to cover with
you today.
The first is that we are getting tired of the developer justifying his water use for the
wave basin by saying that he will use only 25% of the water used by a golf course.
What he fails to mention is that golf courses can use gray or recycled water and that he must
used potable water from our aquifer. If you haven't read it, there was an excellent article
in the July 18 Desert Sun, Golf Courses prepare for water shortages. I would like to
highlight just a few of the key points of that article:
There is a 15% voluntary request in reduction of water use across the state,
New level of drought emergency declaration will be coming by 2022.
Unlike many golf courses elsewhere in the State which rely heavily on groundwater,
Coachella Valley golf courses have sought to reduce reliance on the local aquifer.
Protecting that groundwater, the main source of water for households and businesses
in the desert is a focus of the Golf and Water Task Force.
"Because the aquifer is literally the lifeblood of everything that happens in the desert, as
important as it is reducing the overall water usage footprint over time, we do put more
emphasis on the health of the aquifer. Desert courses have been moving away from
aquifer water in the last decade.
Desert courses have been removing turf.
"We have to recognize that we are in a desert and the aquifer isn't endless."
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT SHEILA WARREN
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
So how will the wave pool move away from use of the aquifer? It can't.
How can a wave pool cut water use by 15%? It can't because it will not be able to operate.
And what about evaporation? When we asked the developer, they tried to compare
evaporation at the Kelly Slater pool in Lemoore California with this one. Once we reminded
them that Lemoore had 40 days over 100 in 2020 and we have 143 days over 100,
that their high was 107 and our high was 124, that their lows were mostly in the 60s
with a few 70s during those hot days, and our nights were always in the 100s, or high 90s
and 80s, they stopped comparing evaporations.
And finally, I would just like to mention about the 7AM to 10PM operation of
the wave basin, 365 days of the year. Up to and including our face to face
meeting with the developer on June 16, when asked, the developer always told
us that it would be 12 hours of operation, 7AM to 7PM so we had nothing to worry
about with noise or light at night. Two days later on June 18, the draft of
environmental impact report that had the hours of 7AM to 10PM,
365 days of the year.
Seems awfully strange they did not know that two days earlier...
But who is going to be surfing during the day in this heat? With water
temperatures in the 90s and air temperatures in the 100s, that is a recipe for heat stroke.
This project is in the wrong place at the wrong time.
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT CAROLYN WINNOR
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
From:
Sent:
To:
Cc:
Subject:
Attachments:
Follow Up Flag:
Flag Status:
Alena Callimanis
Tuesday, July 20, 2021 10:50 AM
City Clerk Mail
Carolyn Winnor; Monika Radeva
Carolyn Winnor will do Zoom public comments today at 4pm
Carolyn Winnor City Council Meeting.pdf
Follow up
Flagged
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.
Carolyn Winnor, Trilogy resident at 81134 Barrel Cactus Road, LQ will be speaking over Zoom about Coral Mountain
Resort during the public comment session.
This is Carolyn's document.
Thank you very much.
Alena Callimanis
1
CITY COUNCIL MEETING - JULY 20, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT CAROLYN WINNOR
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
Good Afternoon Honorable Mayor Evans, Council Members & Staff
My name is Carolyn Winnor, I live in Trilogy La Quinta moved here in
August 2005.
am opposed to the Coral Mountain Wave Project and the Re Zoning of
this property for many reasons:
Water Usage — Couple of weeks ago on the news I heard a
representative from Coachella Valley Water District, speak regarding
the water they currently have in reserve. I believe it was 6 billion
gallons. How did CVW get this large reserve? From homeowners and
businesses, conserving water since last drought that affected the
Coachella Valley. Also due to water efficient toilets, faucets &
appliances. The residents of the Coachella Valley is the reason CVWD
has a large reserve and I am against using the reserve to fill a Wave
Pool with 18 Million Gallons of Drinking Water, for People to surf on.
We changed our habits to be assured the residents of the Coachella
Valley would have water for the future.
Lights/Lighting —17 80' Poles with 70 fixtures on each Pole. Be like
living next to LQ High School football field or the Indian Wells Tennis
Garden, the lights will be on until 10 pm, 365 days a year.
Noise, Traffic - If La Quinta City Council approves the Coral Mountain
Wave Project, the residents of South East L Q will be living near or next
door to an amusement park.
My biggest fear: in 3 to 5 years no one is interested in surfing in a Wave
Pool and the Wave will close down. What will the City of La Quinta and
the neighbors near Coral Mountain be left with a BIG HOLE, measuring
in length over 12 football fields?
Thank You.
La Quinta City Council Meeting July 20, 2021
Public Comment on Matters Not on the Agenda
https://laquinta.l2milesout.com/video/meeting/b8db2190-d39c-4f0d-b9ad-cd3b449dc821
Speakers discussing the Coral Mountain Resort Project and time of appearance in video linked
above.
In -Person Comments
Alena Callimanis (Transcribed); 0:45 — 6:25 minutes
Lisa Castro (Transcribed); 6:40 — 9:00 minutes
Sheila Warren (Transcribed); 9:00 — 13:36 minutes
Francine Roy (Transcribed); 13:40 — 15:00 minutes
Verbal Comments via Teleconference
Carolyn Winnor (Transcribed); 19:50 — 22:10 minutes
City Council Meeting 7-20-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/b8db2190-d39c-4f0d-b9ad-cd3b449dc821
Located at: 0:45 — 6:25 minutes
Speaker: Alena Callimanis
Callimanis: Honorable Mayor Evans I am vaccinated may I take this [indicating mask] off?
Mayor: You may.
Callimanis: Thank you. So um, Mayor Evans, Council members. I especially want to, and staff, I especially
want to thank Monica and Nicole who helped me get my presentation up and going because I have
videos in this presentation. So, I'm very excited. And of course, I am speaking about the Coral Mountain
surf resort if you haven't figured that out yet. So, the first —
Mayor: You should have your own clicker there, right?
Callimanis: Yes, yes. Hopefully I will do it better this time. So, this is a picture that is right after sunset
last night, I took these pictures from Lisa Castro's house which is on 60th, on the um, on the single lane,
dirt, 60th road. So um, with beautiful dark sky. This is hard to see [indicating new slide with photo], but
what I tried to do here is do a panorama on my iPhone from the left is Guillermo's house, I went across
Coral Mountain and the right side where the light is back to Lisa's house. So just to show you what the
night sky and what it looks like at night. So um, this and, will you folks get this going? Great. So um, be
very quiet. [Plays video]. You hear the crickets? Okay, that's Lisa's house, so it started from Guillermo's
to Lisa's house again. And this second one is after I heard a car going on Madison. So, this might be more
difficult to hear. [Plays second video].
So, the significance of that video is, there was the car on Madison and that's what we heard. Madison is
further from where I took this than the surf pool. So that was the sound that we heard. So um, and I
guess you can hear, you can see that it really was very, very quiet there. Uh this next one was as I was at
So right by Coral Mountain, I saw that light, and I said oh what is that light? So, I followed the light. I
went in and out of tra- you know the roads, and this is what I came to, Bagdouma Park in Coachella,
those were the lights I saw from 58th from Coral Mountain. And the light pole on the right is 60 feet. The
light pole that are going to be at this development will be, excuse me, 80 feet. So, they will be 20 feet
higher than the one on the right. Like, I can't even imagine lights being held up on a pole that high. So
that's what going to be surrounding that. And if I go back to the prior picture, oops, oh I'm not going
backwards. Oh, this way, sorry. If I go back to this picture here, the reason we see that is because the
particles in our air, there's dust and sand, all these small particles diffusing the light and they will be
doing the same thing by Coral Mountain. So that light will be seen. So, what I wanted to say is please
don't let the developer keep insulting us, and you, by saying there will be no light and no noise impact to
the surrounding developments. This will be physically impossible considering the fact that the location
has quiet nights in this area, the proximity to Coral Mountain, sound echoing and reverberation off the
mountain, and the light reflection and dispersion. I think these prior charts show that very clearly.
Now this is your City of La Quinta General map, and I circled the land use areas where we are and it's
very compatible to the developments that are around. And on the next page, I wanted to say these are
excerpts from the La Quinta General Plan 2035 Land Use. Policy LU -3.1, encourage the preservation of
neighborhood character and assure a consistent and compatible land use pattern. Next one,
maintenance and protection of existing neighborhoods. Next one, encourage compatible development
adjacent to existing neighborhoods and infrastructure. A community that provides the best possible
quality of life for all its residents. And preservation of scenic resources as vital contributors to the City's
economic health and overall quality of life. So that's from the master plan.
We want Low Density Residential at this site. We want development. We're not saying no development.
And we're - but we're saying not 100% STVRs and a Wave. Preserve the beauty and serenity for the five
developments around Coral Mountain, and for the new 100% low density residential development that
should be on this magnificent property. Please do not approve, when it comes up, a zoning change that
will take away all of that. Thank you very much.
City Council Meeting 7-20-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/b8db2190-d39c-4f0d-b9ad-cd3b449dc821
Located at: 6:40 - 9:00
Speaker: Lisa Castro
Yes, I am the neighbor; I am closer to this wave park than anybody. I've been there 30 years, um, first of
all, thank you for hearing this, thank you for the video and everything that Alena did.
Mr. Garrett and I have met several times in my home, and he's a wonderful gentleman, but I'm just not
sure that, um, things he tells me, every time he tells me something, things change. But um, I'm worried
about the water evaporation, I'm worried about our aquifer, you know, every day on the news all we
hear about is the drought. I'm worried about the light and the noise. I'm worried about traffic. I am
going to be right next door to the secondary entrance, and I don't believe they are even aware of the 7
am entrance that most of our country clubs have. People are going to be lining up down the street even
after development, after its completed to get in. I don't think they're going to allow me to get in and out
of my own home. So um, I'm worried about, like I said, the light, and the noise and the wave impact, the
motion of that water. Is that going to have - create cracks in my foundation? I'm east to it. I'm going to
be closest to the end. Is that going to affect my home? My pool? Um, I'm concerned, very concerned.
I've been there forever, before anything else was out there, and I know the quality of life that I have
now will be destroyed. That quiet is why we built out there. And with a surf park, a private community
that no one else can access to, is going to destroy that. So please consider, reconsider, or consider not
changing the zoning.
City Council Meeting 7-20-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/b8db2190-d39c-4f0d-b9ad-cd3b449dc821
Located at: 9:00 — 13:36
Speaker: Sheila Warren
Good afternoon Mayor Evans, City Council Members and Staff. My name is Sheila Warren and I'm a
resident of Trilogy in La Quinta. I have two things to cover with you today.
The first is, we're getting tired of the developer justifying the water use for the wave basin by saying
that he -it will use only 25% of the water used by golf courses. What he fails to mention is that golf
courses use gray water or recycled water, and that the wave basin must use potable water from our
aquifer. If you haven't read it, there was an excellent article in the July 18th Desert Sun, stating that golf
courses are preparing for water shortages. I would like to highlight just a few of the points:
• There is a 15% voluntary request in reduction of water use across the state;
• A new level of drought emergency declaration will be coming in 2022.
Unlike many golf courses elsewhere in the State which rely heavily on groundwater, Coachella Valley
golf courses have sought to reduce reliance on the local aquifer.
Protecting that groundwater, the main source of water for households and businesses in the desert is a
focus of the Golf and Water Task Force.
Quote: "Because the aquifer is literally the lifeblood of everything that happens in the desert, as
important as it is reducing the overall water usage footprint over time, we do put more emphasis on the
health of the aquifer. Desert courses have been moving away from aquifer water in the last decade."
Desert courses have been removing turf.
We have to recognize that we are in a desert and the aquifer is not endless.
So how will the wave pool move away from use of the aquifer? It can't.
How can a wave pool cut water usage by 15%? It can't because it will not be able to operate.
And what about evaporation? When we asked the developer, they tried to compare evaporation at the
Kelly Slater pool in Lemoore California with this one. Once we reminded them that Lemoore had 40 days
over 100 degrees in 2020 and we had 143 days over 100; that their high was 107 and our high was 124;
that their lows were mostly in the 60s with a few 70s during those hot days, and our nights were always
in the 100s, or high 90s and 80s, they stopped comparing evaporation.
And finally, I would just like to mention about the 7AM to 10PM operation of the wave basin, 365 days
of the year. Up to and including our face-to-face meeting with the developer on June 16, when asked,
the developer always told us that it would be 12 hours of operation, 7AM to 7PM so we had nothing to
worry about with noise at night or light at night. Two days later on June 18, the draft of environmental
impact report listed hours of operation as 7AM to 10PM, 365 days of the year.
Seems awfully strange they did not know that two days earlier...
But who is going to be surfing during the day in this heat? With water temperatures in the 90s and air
temperatures in the 100s, that is a recipe for heat stroke.
This project is the wrong place and the wrong time. Thank you very much.
City Council Meeting 7-20-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/b8db2190-d39c-4f0d-b9ad-cd3b449dc821
Located at: 13:40 — 15:00
Speaker: Francine Roy
Hello, I just had some general questions. I am kind of new to this project and I just moved here a year
ago. One question is when was the current zoning established for this parcel?
Mayor: So, this is the part of public comment where you are able to address, but we will not respond
per se to every question. So, you can rattle off your questions, you're welcome to do that and probably
a lot of that is covered in the EIR or it could be in the General Plan that's available on our website. But
feel free. I would like to hear your questions, so we have an understanding.
Roy: And exactly what she was talking about was what I was going to mention. And thirdly, I was curious
that with all the climate change and drought conditions that are going on and the future I think we can
expect this to continue. There's a lot of emphasis on the aquifer as already discussed. Wouldn't it be a
good time to maybe reconsider a change in the zoning that might not allow a golf course even? Which is
taking water. Something to think about. So that's it.
City Council Meeting 7-20-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/b8db2190-d39c-4f0d-b9ad-cd3b449dc821
Located at: 19:50 — 22:10
Speaker: Carolyn Winnor
I am unmuted. Can you hear me? Good afternoon Mayor Evans, Council Members & Staff. My name is
Carolyn Winnor, I live in Trilogy La Quinta. My husband and I moved here in August 2005.
I am opposed to the Coral Mountain Wave Project and the Re Zoning of this property for many reasons:
Water Usage — which you've heard multiple times this afternoon. A couple of weeks ago on the news I
heard a representative from Coachella Valley Water District, speak regarding the water they currently
have in reserve. I believe it was 6 billion gallons. How did Coachella Valley Water get this large reserve?
From homeowners and businesses, conserving water since last drought that affected the Coachella
Valley. Also due to water efficient toilets, faucets and appliances. The residents of the Coachella Valley is
the reason the Coachella Valley Water District has a large reserve and I am against using the reserve to
fill a Wave Pool with 18 million gallons of drinking water, for people to surf on. We changed our habits
to be assured the residents of the Coachella Valley would have water for the future.
Another one of my concerns is the lighting. The project is proposing 17, 80 -foot light poles with 70
fixtures on each pole. Be like living next to La Quinta High School football field or the Indian Wells Tennis
Garden, the lights will be on at the Coral Mountain Wave until 10 pm, 7 days a week, 365 days a year.
Noise and Traffic - If La Quinta City Council approves the Coral Mountain Wave Project, the residents of
southeast La Quinta will be living near or next door to an amusement park.
And what happens in 3 to 5 years that no one is interested in surfing in a Wave Pool in the desert and
the Wave would close down. What will the City of La Quinta and the neighbors near Coral Mountain be
left with? A big hole, measuring in length over 12 football fields?
Thank You.
Tuesday, July 27, 2021 at 15:27:36 Pacific Daylight Time
Subject: MORE RE: In opposition of a Wave park a Coral Mountain
Date: Wednesday, July 21, 2021 at 3:46:48 PM Pacific Daylight Time
From: Rob Michiels
To: Consulting Planner
CC: Ria Michiels, Mike Charles, Ramon Baez, Igresidentsstopthewave@gmail.com,
drebryna@telusplanet.net
Dear Ms Sauviat Criste,
I would like to remind the City leaders that the 2035 La Quinta General Plan is the (long) existing plan for our
communities. This plan was supposed to be legally binding and now it appears that the City mayor and council are
going to use loopholes to invalidate it?
I would also like to add to my previous comments (email dated 07/20/21) by adding the following specific questions
that need to be addressed by the review process:
1. First, the legal record should clearly reflect that this proposed development is not in compliance with the
existing 2035 zoning plan for La Quinta.
a. Why does the City even consider this project?
b. To clarify the process, the city should provide its residents with a written and public justification of its
intent, so that there can be no misunderstanding of facts, history and responsibilities if the future
brings lawsuits.
c. The rezoning process requires a rigorous investigation of all factors and a specific justification of
communal benefits. The current reports submitted by the developer are anything but that.
d. Neutrality of reporting is paramount. So why are these not 3rd party studies, instead of experts hired
by the developer?
e. DEIR documents are meant to be read and understood by the average person and are supposed to
follow a specific format and size requirement. The currently submitted documents are anything but
that and are full of vague and subjective language, which of course is not inconsistent with having
been written by people being paid by the developer. Why can the City not commission new studies
and reports from non -conflicted independent experts?
2. The City is being asked to rezone based on grounds of (doubtful) benefits and (undefined) developer
promises to local government officials (DEIR 3-18).
a. This proposed amusement park is private. How does that benefit La Quinta residents?
b. This proposed development is focused on short term rentals and also features fractional ownership
formulas. How does that reconcile with the nature of the surrounding residential developments?
c. Most cities are fighting against short term rentals nuisances. Why would La Quinta be intent on
promoting such activities, instead of focusing on the needs of long-term residents?
d. This proposed development aims to operate 365 days a year from 7AM to 10PM with corresponding
traffic noise, operating noise (wave equipment noise, wave noise (roar), announcement/alarm noise,
music noise, etc...) (DEIR 1-29, 4.11-15, 4.11-47, 4.11-49)
i. Why are the reports not investigating each one of these noise categories individually?
ii. Why are the reports not investigating all of these noise categories combined?
iii. Why are the reports relying solely on theoretical noise models?
iv. Why are the reports allowed to use and extrapolate data from other non -identical facilities?
v. Why are the developers not asked to execute real-time and real-life noise experiments (for all
noise sources individually and cumulatively) within the affected communities?
vi. Why is everyone studiously ignoring the impact during construction over a number of years,
especially since the developer is projecting and requesting "open timing" for completion?
vii. How can the City accept the unrealistic and unscientific argument that a "mountain absorbs
noise"?
e. This proposed development aims to operate 365 days a year from 7AM to 10PM with corresponding
Page 1 of 5
light pollution from a number of proposed new light sources (DEIR 4.1-41, 4.1-39, 4.1-57, 4.10-28)
i. Why are the reports not investigating each one of the possible light sources individually?
ii. Why are the reports relying solely on theoretical light pollution models?
iii. How can a report that states "insignificant" impact from 80ft light poles be considered bona
fide? No refereed technical explanation or justification is provided in the report. Please
justify why such a glaring oversight should not be rectified and a new independent report
commissioned?
iv. How can the City accept the unrealistic and unscientific argument that "light will not
significantly reflect off water"?
v. Why would the developers be allowed an exemption (for 80ft) from the current municipal code
which allows only 8 ft pole heights for this type of use?
vi. Why are the developers not asked to execute real-time light impact experiments (for all light
sources individually and cumulatively — especially the two third mile long 80 ft poles every
20 ft along the basin) within the affected communities?
vii. Why should there not be an independent study of project light impacts on the surrounding
communities?
f. This proposed development aims to exceed the current permissible height specs of the municipal
code for various structures (DEIR 4.1-57, 4.1-12, 4.1-13).
i. Why do the current reports not address such structures individually and specifically?
ii. How can loss of mountain view by numerous surrounding residential developments not be
considered a substantial objection to this proposed project?
iii. How serious can you take a report that states that "vegetation is not permanent as it can
change form or be removed" as part of the argumentation that view loss is not an
applicable argument in this case? How can the City possibly accept this type of rationale
without further thought or question? Why should there not be an independent study of
impacts on the surrounding communities?
iv. At some point the report states: "However, impacts associated with scenic vistas cannot be
reduced to less than significant levels and will remain significant and unavoidable." (DEIR
4.1-45). How can this be deemed acceptable as an argument to support a zoning
change?
g. This proposed development will create potentially significant environmental impacts due to wasteful,
inefficient or unnecessary consumption of energy resources (DEIR 1-22) and will increase demand for
energy in the service areas of IID and SoCal Gas Co (DEIR 4.5-34). The developer admits that project
specific impacts to greenhouse gas emissions will be significant and unavoidable (DEIR 1-13).
i. How can the City justify a zoning change given these negative environmental facts?
ii. La Quinta residents are already being asked on a regular basis to conserve energy during
heat waves. How will the energy consumption of this project specifically impact the
surrounding communities?
iii. The EIR small print states that the developer will purchase vast amounts of carbon credits.
How can the City possibly believe, or prove, that this is a beneficially "green" project?
h. This proposed development will require massive amounts of hazardous chemicals that will be used
and stored on site (DEIR 4.8-18).
i. Nowhere in the reports is there any substantial or specific explanation of usage, storage or
safety measures. Local residents demand to know all risks as detailed in an independent
study.
ii. Available chemical treatments will not be sufficient during very hot summer months to provide
adequate protection from microscopic amoeba in the over -warm water. The developer has
stated the water will not be cooled during summer, hence this health risk is currently not be
mitigated:
• Who will be liable if/when brain (amebic meningoencephalitis) infections occur?
• Will the City (and thus ultimately residents) end up footing the bill after being sued by a
dead surfer's family?
• How will the developer specifically mitigate this issue?
2. Local community home values are likely to be negatively impacted by this development if it proceeds. Will
Riverside County reduce the property tax basis for the affected homeowners when that happens?
3. The developer is going to request separate permissions for mass events (DEIR 1-7).
a. How will noise violations during Special Events be enforced by the City and what process will be
Page 2 of 5
used?
b. How will illegal behavior during Special Events be monitored and mitigated?
c. Substantial additional traffic impact (including local gridlock for Trilogy and Andalusia) will be felt by
local residents. Why will the City not commission an independent study?
d. How will unavoidable large crowd litter/trash generation immediately outside the park boundaries be
monitored and mitigated?
e. Will the developer be asked to cover all additional City service expenses (law enforcement, medical
response, fire, road repair, traffic signalization)?
f. If events are allowed to occur, will the City limit such individual event permits to maximum 2 per year?
4. California is experiencing a severe drought. For years (and continuing) we are all trying to conserve water.
This project will require millions of gallons of potable water every year. Looking at DEIR 4.10-19, 1-27, 1-36,
4.10.20, 4.15-29, 4.15-34 (and I am probably missing a few) a number of questions arise.
a. The developer's own estimates project water usage within a "4% or so" margin. What happens when
they go over the contract allotted numbers? Can they just buy unlimited additional gallons?
b. The developer reports having a contract already for potable water from our local aquifer. How can the
local water company be allowed to execute such a wasteful contract when public water reserves are
already under tremendous pressure.
c. The argument that this project uses less water than a golf is invalid because golf course operations
now mostly use recycled (gray) water. Why can the developer not be required to use recycled water?
d. Is the City conscious of the fact that with rising population numbers the water wasted on this project
are going to be needed in the very near future?
e. The developer's reports on water usage are incomplete and rather less than scientifically justified.
Why does the City not request very detailed and scientifically/technically justified and independently
generated information regarding evaporation, specific water usage patterns for individual elements of
the project facilities, detailed wave pool maintenance requirements?
5. The traffic analysis submitted reflects middle of the COVID pandemic activity between November 2019 and
October 2020. This analysis mis-represents the actual anticipated traffic reality. (DEIR 4.13-42)
a. The impact on local residents will be large. Why will the City not commission an independent study at
the developer's expense?
b. What considerations are in place for possible (new) public or private bus transportation to the
development? Has a detailed study been submitted?
c. What considerations are in place for queue locations for taxi, Uber, Lyft, etc? Has a detailed study
been submitted?
Respectfully submitted,
Rob & Ria Michiels-Denayer
81301 Andalusia
La Quinta, CA 92253
Rob Michiels
Founding Partner
CONSILIUM Associates LLC
Cell +1 949 677 4165 (No Texting)
Email RMichiels@consiliumassociates.net
This message is intended only for the use of the individual or entity to which it is addressed, and may contain
information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this
message is not the intended recipient, or the employee or agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or
return e-mail. Thank you, CONSILIUM.
Page 3 of 5
From: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Sent: Wednesday, July 21, 2021 9:24 AM
To: Rob Michiels <rmichiels@consiliumassociates.net>
Cc: Ria Michiels <michiels.ria@gmail.com>; Mike Charles <mgacharles@yahoo.com>; Ramon Baez
<rfbaez7@gmail.com>
Subject: Re: In opposition of a Wave park a Coral Mountain
Mr, Michiels,
Thank you for your comments.
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
From: Rob Michiels <rmichiels@consiliumassociates.net>
Sent: Tuesday, July 20, 2021 4:24 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Cc: Ria Michiels <michiels.ria@gmail.com>; Mike Charles <mgacharles@yahoo.com>; Ramon Baez
<rfbaez7@gmail.com>
Subject: In opposition of a Wave park a Coral Mountain
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.
Good afternoon and thank you for allowing me to voice my strong opposition to this
project.
My wife and I have been homeowners at Andalusia for the past 11 years. I believe I am
also speaking on behalf of many of my neighbors.
We joined this beautiful Andalusia community because:
We love the peace and quiet;
We love the immaculately dark and clear night skies;
We were told the patch of wild and untamed desertscape across from us would
eventually be developed into a similarly quiet and uncrowded golf/low density residential
community.
So, imagine our dismay when that property was sold to another developer, who has
quickly, and under the radar, moved to change the zoning from low density residential to
high impact commercial.
We do not understand why the city of La Quinta would have given the initial permission
for that zoning change so this ill-conceived project could move forward to this stage of
planning?
Do our city leaders really want to tie their political legacy to the desecration of one of the
Page 4 of 5
last truly unique and peaceful tracts of La Quinta land by unscrupulous developers who
want to change it into a circus like attraction every day all year round? Why go forward
and spend untold dollars on investigations when any person with common sense knows
this can and should be stopped right now by the city simply holding fast to the original
zoning?
Why waste millions of gallons of drinking water when we are in the midst of a drought?
The so-called expert reports submitted in support of this project are at best theoretical
re -do's of earlier reports (from other projects). No real science or experiments are
behind these reports.
Is the only underlying agenda that wants to allow this permitting process change the
pursuit of a few extra dollars promised for city coffers?
If you go forward, I believe future generations will not look kindly on your legacy.
Thank you for your consideration.
Rob & Ria Michiels-Denayer
81301 Andalusia
La Quinta, CA 92253
Rob Michiels
Founding Partner
CONSILIUM Associates LLC
Cell +1 949 677 4165 (No Texting)
Email RMichiels@consiliumassociates.net
This message is intended only for the use of the individual or entity to which it is addressed, and may contain
information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this
message is not the intended recipient, or the employee or agent responsible for delivering the message to the
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return e-mail. Thank you, CONSILIUM.
Page 5 of 5
Wednesday, July 21, 2021 at 12:45:07 Pacific Daylight Time
Subject: RE: Coral Mountain Resort
Date: Wednesday, July 21, 2021 at 11:46:25 AM Pacific Daylight Time
From: Cheri Flores
To: Dan Rendino Gmail
CC: Danny Castro, Nicole Criste, Jon McMillen
Attachments: image001.png
Mr. Rendino,
Thank you for your comments. Have a lovely day.
CALIFORNIA
Cheri L. Flores 1 Planning Manager
City of La Quinta
78495 Calle Tampico La Quinta, CA 92253
Ph. 760-777-7067
www.laquintaca.gov
PLEASE NOTE: City Hall is now open to the public during normal business hours:
Monday through Thursday from 7:30 a.m. to 5:30 p.m. and Friday from 8:00 a.m. to
5:00 p.m. (Counter closes at 4:30 p.m. daily), with the exception of nationally
observed holidays. Please follow all CDC and State recommended guidelines as they
pertain to COVID-19 safety and awareness. All public services continue to be available
via phone, email or online web portal and the public is encouraged to utilize these
services when possible. Thank you.
From: Dan Rendino Gmail <danrendino@gmail.com>
Sent: Wednesday, July 21, 2021 11:18 AM
To: Linda Evans <Levans@laquintaca.gov>; Robert Radi <Rradi@laquintaca.gov>; Kathleen Fitzpatrick
<kfitzpatrick@laquintaca.gov>; John Pena <jpena@laquintaca.gov>; Steve Sanchez
<ssanchez@laquintaca.gov>; Cheri Flores <clflores@laquintaca.gov>
Subject: Coral Mountain Resort
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.
City Officials,
I attended by a zoom meeting last night a presentation by the developers on the proposed development of
the Coral Mountain Resort. My first impression is how in the world did this circus proposal advance to the city
council for purposes of trying to get a variance. It is an embarrassment to admit to friends and neighbors that
this is even being considered. We moved here because La Quinta was a place that afforded us the
opportunity to retire from the hectic city life that we were brought up in. Had this project been known to us
when we moved here, we would be living somewhere else. This is exactly what we were trying to get away
from when we bought here. These are some of the reasons that this project should be deep - sixed.
1. La Quinta does not need to be a haven for an additional STRV units (600 additional units with an
average of 3 bedrooms) at a time the town and its developments (PGA West where we live), are trying
to remedy the existing problems that already exist. La Quinta unlike some other valley towns has
allowed widespread STRV units to be permitted with the problems associated with them. I do do
appreciate the effort the town has put in to remedy the situation. Now is not the time to reverse the
work done to correct the issues. I personally know people who have not bought property in our town
Page 1 of 3
because of the widespread STVR's. They have chosen other towns that are more strict in this area.
2. Traffic is already a problem in La Quinta. There are only 3 entry points into La Quinta (Washington,
Jefferson and Madison). Traffic on these streets are already bad in the season. 600 three bedroom
apartments means 1800 additional vehicles on our streets 365 days a year. They claim this issue will be
remedied by the town. Putting up additional stop lights does not fix the traffic problem but makes it
worse by increasing delays. This is not something that we need.
3. The proposed plan does not include facts and data but are really just hopes, wishes and suppositions.
They only presented "goals". What happens when these goals are not met. Does the town propose to
shut them down? These hopes and dreams are applicable to noise, lighting, traffic, water consumption,
electrical overload etc. Pie in the sky! Anyone could see through what they were trying to do, it doesn't
pass the smell test. Throw out a bunch of hopes and wishes with nothing to back it up, and hope that it
sticks.
4. Do the city officials and these developers realize that all of California is being stressed by a terrible
drought which predictions say will only get worse. We are being asked to limit the use of water for
household use, golf courses are being forced to find different means of irrigation and these people
want to fill a pool with 18 million gallons of precious drinking water so that someone could go surfing
150 miles away from the ocean. Who comes up with these ideas? What city would approve this. The
water in this pool in the summer will be almost 100 degrees. In this climate how much evaporation
takes place? What happens when the pool repairs are needed and the pool has to be drained? Why
should my water rate be raised so that these people can live out their dreams of a Disneyland in the
Desert? They claim Imperial Irrigation says out is possible. Because it is possible does not mean it
should be done! The entire West is under draught conditions and you have a proposal in from of you to
make it worse.
5. They also want to be able to have "special events"! Four times a year! 4 days per event! That is 16
Coachellas a year! One thing about the pandemic that was good was that there was no Coachella.
Enough said. La Quinta does not need to be another Coachella with the disruption it brings.
6. They "think" that noise will not be an issue because their model tells them so. No independent data
just hopes, wishes and dreams. They claim that Coral Mountain will be an absorber of the noise.
Really? Having 80 foot light towers and wave machines going off every 3 minutes from 7AM to 10PM is
just not something we should allow.
7. Homes will start at $2.5 million. Do you know anyone who would buy a home to live in in the middle of
a water park? These homes will never be built and sold and the project will have a 16 million gallon
pool in a hole in the middle of the desert. The tax revenue you hope to get will not ever happen.
am really surprised that this project has risen to the point where it is even being
considered. I would be embarrassed to tell someone that the town of La Quinta is
even considering this project. I am confident that you city officials will put an end to
this madness and get on to serious issues facing the town. I thank you for your
consideration.
Dan Rendino
Page 2 of 3
80390 Weikopf La Quinta 92253
danrendino@gmail.com
760.880.3275
Page 3 of 3
Nicole Sauviot Criste
Consulting Planner
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Dear Ms. Criste:
Carol Welty
Arthur Stephens
81950 Eagle Claw Drive
La Quinta, CA 92253
RECEIVED
JUL 21 2021
CITY OF LA QUINTA
DESIGN AND DEVELOPMENT DEPARTMENT
The drought in the west is well documented one of the worst handful of years since the year
800 A.D. per Park Williams a hydroclimatologist at UCLA. One third of crops in California cannot
be planted due to lack of water. The drought is draining reservoirs by 30% like Lake Mead at an
alarming rate, including our own Salton Sea. To use precious water in the desert for a water
absorbing fun park is beyond measure of lack of insightfulness. Not only the water problem but
to put a commercial project among planned residential communities does not make sense. We
moved to this community in great part because it was a quiet community and area for
residential use only.
We strongly urge the city planning department as well as all involved in approving any
development to please be aware of all of the negatives involved with allowing this project to go
through.
Thank you for your consideration.
Carol Welty
Art Stephens
Email: carolwelt@yahoo.com
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I oppose the wave park proposed for La Quinta
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RR
Rick Roth <ricodoco@gmail.com>
Sat 7/24/2021 11:53 AM
To: Consulting Planner
** 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. **
I have read the proposed plan and EIR. I oppose the project. I bought my house across
Madison from this project in full knowledge that that undeveloped parcel was zoned for golf
and low-density homes. I never would have bought here if I thought that property would
become a higher -density development, with hundreds of short-term renters coming for
events at least four times a year. This project obviously would require rezoning for
commercial, hotel, and amusement facilities. There is absolutely no reason why the City of
La Quinta should approve such a rezoning. We don't need it, we don't want it, and it's a
terrible misuse of a wonderful parcel. That parcel should be developed for low-density
properties as planned and promised.
Frederick Roth
58002 Aracena
760-564-8499
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Coral Mountain
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DW
Derek Wong <derekwong745@yahoo.com> <E)
Tue 7/27/2021 12:19 PM
To: Linda Evans; Robert Radi; Kathleen Fitzpatrick; John Pena; Steve Sanchez; Consulting Planner
** 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. **
July 27, 2021
Linda Evans, Mayor
Robert Radi, Mayor Pro Tem
Kathleen Fitzpatrick, Council Member
John Pena, Council Member
Steve Sanchez, Council Member
Nicole Sauviat Criste, Consultant Planner
RE: Coral Mountain
A fundamental shift in how we live our lives is occurring on a magnitude beyond the headlines...the full import of this
catastrophic drought has yet to take effect as it continues to unfold daily. There is no way to determine its duration but it
is said that a full 10 years of solid seasonal rain will be required before we "return to normal." Repeat: 10 years!
It has been publicized ad nauseam that the reservoirs are at their lowest levels ever, that the Colorado River supply will
cease and that wells throughout the state are being over -pumped, agricultural fields are increasingly fallow, wildlife
decimated, wildfires burning without end and towns left dried and barren...
...and yet, we continue to discuss the building of Wave pools, golf courses, private lagoons and lakes as if there is no
crisis at all. To even consider this project and others like it is irresponsible and borders on deliberate shortsightedness...
with profit as the motivator. Slick marketing that promises an economic paradise with hints of environmental concerns
tossed in for appeasement. I find it foolish and exceedingly hypocritical for the developer to continue touting the benefits
of this playground while ignoring the havoc that encircles us all.
The wealthy can go to any beach in the world for water sports, many La Quinta residents live here full time and to betray
their peace and serenity for this playground is just wrong.
Be responsible citizens, build responsibly, do not rezone Coral Mountain.
Sincerely,
Derek Wong
Trilogy, La Quinta
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Re: Proposal for Surf Park Development at Coral Mountain
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AC
Agnes Collins <ascollinsl @telus.net>
Wed 7/28/2021 2:53 PM
To: Consulting Planner; Council
** 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. **
Dear Nicole Sauviat Criste, Consulting Planner, City of La Quinta
Further to my letter of opposition to the above noted proposal sent to you on March 8, I have reviewed the
environmental report and other pertinent information. I remain strongly opposed to a surf park
development in our area for the same reasons outlined in my March 8 letter as follows:
We have owned our property in Puerta Azul at
57th and Madison for the past 10 years. During that time, we have immensely enjoyed hiking, walking and
cycling in our quiet peaceful community. We chose our home in La Quinta because we loved the beautiful
natural environment.
We have been informed about the proposal to build a surf park just a short distance from us at 58th and
Madison. We are stunned to hear that this could actually happen in our quiet neighborhood. Apart from
our very serious concerns about the environmental impact of this type of development, this is just the
wrong area for a tourist/commercial development of this nature. While some may say it will increase the
value of nearby properties, that is not the reason most of us purchased in this area. The proposed
development will destroy the character of our quiet tranquil community. A Disney -like surf park may be
desirable to developers, provide recreational opportunities for short term visitors and will no doubt
increase the tax base but the increased noise, traffic and pollution will destroy the very reason that we
moved to the area.
Apart from these issues, we are even more concerned about the environmental sustainability of building
such developments in the desert. We have read the developer's publications attempting to address
environmental issues but we are also aware of the dire warnings of experts in the environmental field.
Now is not a time for excess consumption, economic growth -seeking or projects disconnected from the
environmental issues we face today. The reality of climate change should force us to rethink our growth
models to reduce natural resource consumption and reconcile our relationship with nature.
Please protect our community and our environment and do not allow this proposal to proceed.
Respectfully Submitted
Agnes Collins
80921 Calle Azul
La Quinta, 92253
250-738-0545
Sent from my iPhone
1 of 1 7/28/21, 4:43 PM
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EIR: Coral Mountain Surf and Wave Amusement Park Development
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Duncan Woodfin <hawaii4dunc@yahoo.com>
Wed 7/28/2021 4:19 PM
To: Linda Evans
** 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. **
July 28, 2021
To City of La Quinta Government Leaders and Planning Department
It frightens me to think that there may be a zoning change from residential to commercial that would
allow a Wave Machine/Amusement Park Development below the Coral Mountains in La Quinta. This
Surf and Wave ride would use millions of gallons of fresh drinking water to fill and refresh the ride in a
time of catastrophic drought here in California. The massive amounts of treatment chemicals needed
and continual refill of this pool will destroy the ecology of the site.
How could we even be considering such a monster project that would use our precious fresh drinking
water and tax an already overburdened electrical grid that would be needed to operate the wave
action.
If this project is approved, it would send the signal that water conservation is no longer needed.
That the drought is nothing but fake news spewed by a corrupt government. Is this the message
you want to send?
As an aside, his project also shows extreme disrespect for our residential community by blocking the
walking path at the base of the Coral Mountains. The developer representative has emphasized
multiple times that they will block this path from neighbors to use; to be used only by their privileged,
rich guests even though the US Bureau of Land Management currently welcomes hikers by multiple
signs permanently posted on the pathway. So many of us in La Quinta enjoy this quiet, peaceful walk
each day. How can you possibly allow public space to be handed over to private interests. This
shows the out of state Developer just doesn't care about being a good neighbor.
Please Mayor Evans, I beg you, don't turn this quiet neighborhood into a noisy, traffic congested, water
wasting theme park. It is truly the wrong development, in the wrong place and at the wrong time. Do
not support a change of zoning.
Thank you.
Sincerely,
Duncan Woodfin
60482 Desert Shadows Dr
La Quinta, CA 92253
442 400 3524
1 of 1 7/28/21, 4:44 PM
To: Nicole Sauviat Criste, Planning Consultant, City of La Quinta
From: Martin Brewer
Subject: Coral Mountain Resort DEIR
July 29, 2021
I am submitting the following comments/concerns about the contents of this document.
(1) The DEIR correctly describes the effect of the project on aesthetics as "Significant and
Unavoidable" even after mitigation. I agree with this assessment, and as the report notes, there
will be adverse effects on scenic vistas, "degradation of the visual character or quality of the
site," and light and glare. Of particular concern to me are the numerous 80' light poles that will
be on from dusk to 10:00 p.m. There are residential communities very nearby, and this issue
alone should be of great concern to the City.
(2) The report states that there will be a "Less than Significant" impact on energy. With a huge wave
pool making waves on a daily and continuous basis, this conclusion seems ridiculous to me. The
report states that no mitigation is required pursuant to the criterion of "Result in potentially
significant environmental impact due to wasteful, inefficient, or unnecessary consumption of
energy resources, during project construction or operation." In my judgment, the operation of a
wave pool in the middle of the desert is the epitome of wasting energy.
(3) The report states that Greenhouse Gas emissions will be "Significant and Unavoidable." The
mitigation recommended is that the "Project Applicant" purchase a large amount of carbon
credits as an offset. I would suggest that a better and more environmentally sound solution
would be denial of the project.
(4) Under "Hydrology and Water Quality," the report states the project's impact is "Less than
Significant." This section includes, "Deletion of Groundwater Supplies..." I do not understand
how a wave pool that will reportedly use millions of gallons of potable water a year is a "Less
than Significant" issue.
(5) Under noise, the report talks mostly about construction noise, and then states, "The operation
of the Wave Basin and associated machines shall be limited to daytime and evening hours of
7:00 a.m. and 10:00 p.m., compliant with the recreational operational hours allowed by the City
of La Quinta." This is a "non -answer" answer, as it does not address the actual amount the wave
pool, employee jet skis, any loudspeakers, alarms, music, etc., will make.
(6) The report states the impact of the project on "Transportation" will be "Less than Significant."
This is a very large development, so it is difficult for me to accept this assessment, but it
certainly does not appear that will be the case during the minimum of four large "Special Events'
per year. The City should look into this in much more detail.
Last, as I understand it, this project would require a change in zoning of the property essentially from
residential to tourist commercial. Given the heavily STVR orientation of the project, its hotel, and its
commercial components, this is entirely incompatible with the surrounding developments and will
forever change the nature of this community. The City should not allow that to occur.
Respectfully submitted,
Martin Brewer
81625 Rustic Canyon Drive
La Quinta 92253
martincbrewer@comcast.net
(408) 410-9127
Monday, August 2, 2021 at 15:21:23 Pacific Daylight Time
Subject: Wavepark in violation of City's Noise Ordinance
Date: Monday, August 2, 2021 at 12:28:14 PM Pacific Daylight Time
From: bnovak26@comcast.net
To: 'Consulting Planner'
CC: levans@laquintaca.gov, rradi@laquintaca.gov, kfitzpatrick@laquintaca.gov, jpena@laquintaca.gov,
ssanchez@laquintaca.gov, cdd@la-quinta.org, jake.ingrassia@kesq.com, freda.moon@sfgate.com,
'Derek Wong', 'Ramon Baez', 'Diane Rebryna', 'Kathy Weiss', novak@dominican.edu, 'Christina
Gamez'
TO: Ms. Nicole Sauviat Criste & other concerned parties
Please consider this part of the overwhelming opposition to the proposed Wavepark project at Madison
and Avenues 58/60 in La Quinta.
This project is in DIRECT OPPOSITION to the City of La Quinta's current Noise Ordinances. The City
limits construction hours from 6:00 A.M. to 7:00 P.M. Monday thru Friday and 8:00 A.M to 5:00 P.M.
Saturday, and prohibits construction noise entirely on Sundays and Holidays. This means that this
Wavepark/Surfamusement Park project will VIOLATE the current Noise policies from day one!! To
exist as currently planned...it has to be considered a "Special Event"...and not just for the four times a
year they claim they will request...but for every day they operate! Please be serious about this! What
they are proposing is to operate a noisy Amusement feature 7 days a week, from 7:00 AM to 10:00
PM...in TOTAL violation of the City's current regulations. This is another reason why Meriweather's
requested zoning change from residential to commercial should definitely NOT be allowed!
Bridgett Novak
La Quinta homeowner
Bnovak26@comcast.net
Page 1 of 1
Tuesday, August 3, 2021 at 09:34:50 Pacific Daylight Time
Subject: Opposition to DEIR for Coral Mountain Surfamusement Park
Date: Monday, August 2, 2021 at 12:43:29 PM Pacific Daylight Time
From: bnovak26@comcast.net
To: 'Consulting Planner'
CC: levans@laquintaca.gov, rradi@laquintaca.gov, kfitzpatrick@laquintaca.gov,
jpena@laquintaca.gov, ssanchez@laquintaca.gov, cdd@la-quinta.org,
jake.ingrassia@kesq.com, freda.moon@sfgate.com, 'Derek Wong', 'Ramon Baez', 'Diane
Rebryna', 'Kathy Weiss', novak@dominican.edu, 'Christina Gamez'
Attachments: DEIR Opposition (Aug 2 2021).docx
TO: Ms. Nicole Sauviat Criste & other concerned parties
The current Draft EIR for the Coral Mountain Surfamusement Park must be rejected and Meriweather's
request for a zoning change be denied.
Bridgett Novak
La Quinta homeowner
Bnovak26@comcast.net
P.S. Please add the attached to the documents I already submitted via email on 3/31/2021 and 4/2/2021.
All should be considered part of the Public record and Official opposition to this project and any related
zoning change request.
Page 1 of 1
August 2, 2021
Attention: Ms. Nicole Sauviat Criste,
Consulting Planner
City of La Quinta
ConsultingPlanner@laquintaca.gov
RE: The current Draft EIR for the Coral Mountain Surfamusement Park must be rejected
Please add this submission to the documents I already submitted in writing (via email) on
3/31/2021 and 4/2/2021.
I have seen lots of DEIRs and never seen one so devoid of actual measurable data (on which
conclusions are supposed to be drawn). This DEIR instead relies on conjecture and vague
statements like "no significant issue". That is NOT acceptable...and the City Council is NOT
doing its job if it does not toss this document back to Meriweather and its obviously -biased
consultant MSA. PLEASE TAKE THIS PROJECT AND CITIZENS' CONCERNS
SERIOUSLY. In this document, I will address 3 of my primary concerns (though I'm concerned
about many others, too).
LIGHT POLLUTION
For the developers to casually claim that their 80 -foot light towers will have "directional" lights
pointed towards the water is totally insufficient. A study needs to be conducted with actual water
and a backdrop of a rock -wall mountain (like Coral Mountain) to determine how much deflected
light will bounce off the water and the mountains...and from how far away the light towers, their
bulbs, their direct and diffused light, and their poles will be visible. Our home is deep within
Andalusia and we can see the entire face of Coral Mountain from our backyard. Those light
towers and their bulbs will be visible. That is NOT acceptable and not properly addressed in the
DEIR.
What about other lights throughout the development? There are walking paths, outdoor
dining/entertainment areas, bike paths, homes, a hotel, a restaurant, etc. planned for this project.
All will have outdoor lighting that has to be measured and evaluated.
Are there going to be big screens (aka jumbotrons) showing surfers every day the wave basin is
open and broadcasting big images of entertainers for their special events? Those light emissions
will also have to be evaluated.
The ability to see surrounding mountains, palm trees, the sky, and stars at night is a HUGE part
of what makes La Quinta the "gem of the desert". This is a very serious issue and MUST be
carefully studied in the DEIR and EIR process, NOT just surmised by Meriweather and MSA (or
whoever else they hire to issue "expert" opinions). DEIRs and EIRs are not supposed to be based
on opinions...but on measurable facts. Please do your job and demand this be done properly!
NOISE
We also believe the developer is far too cavalier with regard to NOISE concerns. It is really
laughable that the developer points to noise studies that were conducted at Lemoore. As La
Quinta resident Kathy Weiss said during the 3/30/2021 Zoom meeting, "that's apples and
oranges". First of all, Lemoore is surrounded by flat agricultural fields and no residential
developments. They apparently intend to build this wave basin right up against Coral Mountain.
Noises created in that basin will echo off the rock face and reverberate far and wide!!! And what
about the grinding sound of the train -like rail system that moves back and forth or the hydrafoils
that help create the waves? All of this needs to be carefully measured and evaluated for this
particular site!!
And what about the tower where the Public Announcer sits and from where he/she broadcasts
upcoming waves, musical choices, safety warnings, etc.? It will be a public announcement
system with loud speakers!
And what about the jet ski(s)? used to run surfers back to the beginning of the wave experience?
A "Travel & Leisure" article says the basin will accommodate 25 surfers at a time...so there will
have to be multiple jet skis routinely ferrying surfers back & forth. And there will likely be other
jet ski -type devices in the water to rescue people who are injured and to take photographs of the
surfers (since everyone will, no doubt, want a visual memory of their experience...and which will
likely be another way for the developers to make money). The DEIR needs to include
measurements of the PA and jet ski noise...at this particular location.
In addition, this project is in DIRECT OPPOSITION to the City of La Quinta's current Noise
Ordinances. The City limits construction hours from 6:00 A.M. to 7:00 P.M. Monday thru Friday
and 8:00 A.M to 5:00 P.M. Saturday, and prohibits construction noise on Sundays and Holidays.
This means that this Wavepark/Surfamusement Park project will VIOLATE the current Noise
policies from day one!! To exist as currently planned...it has to be considered a "Special
Event"...and not just for the four times a year they claim they will request...but for every day
they operate! Please be serious about this! What they are proposing is to operate a noisy
Amusement feature 7 days a week, from 7:00 AM to 10:00 PM...in TOTAL violation of the
City's current regulations. This is another reason why Meriweather's requested zoning change
from residential to commercial should definitely NOT be allowed!
UTILITY OVERLOAD
Will the project's need for huge amounts of continuous power affect the cost, availability and/or
dependability of electricity, water, gas, Internet and WiFi in surrounding neighborhoods? Will
the current IID facility on Avenue 58 have to be expanded? As local residents, we regularly
receive requests from IID to "restrict usage" and get news about "rolling outages", which occur
regularly throughout the summer. This project is likely to put huge amounts of additional stress
and draw on our current grid. THIS NEEDS TO BE CAREFULLY MEASURED...which is
another reason to REJECT THE CURRENT DEIR and deny the zoning change request.
Monday, August 2, 2021 at 15:20:26 Pacific Daylight Time
Subject: Comment on the DEIR for the proposed La Quinta Wavepark development
Date: Monday, August 2, 2021 at 11:31:09 AM Pacific Daylight Time
From: Novak, Philip
To: ConsultingPlanner@laquintaca.gov, levans@laquintaca.gov, rradi@laquintaca.gov,
kfitzpatrick@laquintaca.gov, jpena@laquintaca.gov, ssanchez@laquintaca.gov, cdd@la-quinta.org,
drebryna@telusplanet.net, Derek Wong, rfbaez7@gmail.com, kathy@crystalspringsranch.co,
Bridgett Home Novak
August 2, 2021
Attention: Ms. Nicole Sauviat Criste,
Consulting Planner
City of La Quinta
ConsultingPlanner@laquintaca.gov
From: Philip Novak, La Quinta Resident
RE: Noise findings in the DEIR
I wish to criticize the defensibility of the DEIR's position that the proposed Wavepark "will not
have any significant noise impacts" (4.11.7).
The DEIR's Noise conclusions (4.11) are based entirely on a Noise study (Appendix K-1)
carried out by Urban Crossroads' William Lawson. Thus my criticisms are directed to
Lawson's study. My first criticisms address two points in his study of traffic noise. They are
relatively minor points but, if valid, deserve to be amended in the final El R. My third and last
criticism is major. It calls into serious question the validity of his study of the Wavepark's
projected operational noise.
Criticism 1: An apparent contradiction.
The DEIR's contention that the project will not have any significant traffic noise impacts
appears to directly contradict something Lawson's Noise Study says on p.1 of its own
Executive Summary. Here is Lawson's statement, verbatim:
Based on the significance criteria in outlined in Section 4, the Project -related noise
level increases are considered potentially significant [emphasis Novak's] under Existing with
Project conditions at the following two roadway segments:
• Madison Street north of Avenue 58 (Segment 8)
• Avenue 60 west of Madison Street (Segment 27)
Criticism 2: A baffling and, to me, incomprehensible paragraph in Lawson's Executive
Summary.
Immediately following the passage just quoted above, Lawson states:
All other roadway segments are shown to experience less than significant noise level
impacts under Existing plus Project conditions. However, this scenario is provided solely for
analytical purposes and will not occur, since the Project will not be full [sic] developed (Phase
Page 1 of 3
1, 2 & 3) and occupied under Existing 2019 conditions. Therefore, no mitigation measures are
considered to reduce the Existing with Project condition traffic noise level increases, and
impacts are considered less than significant since they will not actually occur. The analysis
shows that the unmitigated Project -related traffic noise level increases under all traffic
scenarios will be less than significant. [emphases Novak's].
First, what is it exactly that Lawson is referring to in line 2 as "this scenario"? How
extensive is this supposedly non -occurring scenario?
Second, he says that the "scenario," whatever it is, will not occur. What exactly will not
occur?
Third, in the paragraph's second underlined phrase Lawson tells us again that
something "will not occur," but also that this non -occurring something will carry a measurable
level of significance (i.e., "none"). How can something non-existent be measured?
Fourth, in the last sentence Lawson's use of the word "analysis" seems an
overstatement. I suggest it would be far more accurate to describe his activity here as a
thought experiment or a theoretical consideration.
Criticism 3:
Lawson's crucial assumption in studying the La Quinta Wavepark's projected operational
noise — namely, that his audio recording of the Lemoore Surf Ranch's actual operational noise
during a 53 -minute period on April 13, 2020 is a fully adequate proxy of what the La Quinta
Wavepark's operational noise (15 hours per day, most days of the years) will be -- is
breathtakingly flimsy. He never argues for this assumption, for example, by providing an
appropriately comprehensive account of all the relevant topographical (and many other)
differences and similarities between Lemoore and La Quinta. He just assumes, and implicitly
asks his readers to assume along with him, that Lemoore operational noise is a fully adequate
stand-in for what the La Quinta operational noise is expected to be! Given the depth of local
La Quintan concern over the Project's potential for noise pollution, Lawson's highly
questionable root assumption translates into unacceptably weak grounds for his opinions
about levels of noise. For the LQCC to uncritically embrace Lawson's highly dubious report
about operational noise and thus to overrule La Quintans' noise concerns would be
tantamount to a dereliction of duty.
Further elaboration of Criticism 3. As Lawson begins his report on operational noise he makes
reference to the existence of sensitive noise receivers in La Quinta (ten on-site, ten nearby
off-site) that he used in his study of La Quinta traffic noise. Under the new heading,
"Operational Noise Impacts," he writes:
This section analyzes the potential stationary -source operational noise impacts at the
nearby receiver locations, identified in Section 9, resulting from operation of the proposed
Coral Mountain Specific Plan Project.
What is Lawson talking about here? We all know that no sensitive noise receiver in La Quinta
ever recorded any Wavepark operational noise in La Quinta, for the simple reason that there
is currently no Wavepark operation in La Quinta to make any noise.
In any case, Lawson soon discontinues references to La Quinta receiver locations and, to his
credit, points us to the real source of his operational noise data. He discloses it, mind you, not
in his main text, Appendix K-1, but in his own Appendix to that Appendix, namely Appendix
10.1. (Does this qualify as burying crucial information in fine print?) Appendix 10.1 is entitled
Page 2 of 3
"Reference Noise Levels," a studiously vague but ill -disguised name for "Lemoore Noise
Levels." Lawson finally spells out what his all-important "reference noise levels" for
operational noise are: measurements of the Wave Machine noise (for 53 minutes on April 13,
2020, time -of -day not disclosed) at the "existing Surf Ranch located at 18556 Jackson Avenue
in the City of Lemoore, California."
Lawson tells us that the total noise he is out to measure at Lemoore and then "project" onto
La Quinta is the sum of the Lemoore Wave machine noises plus all other site noises,
characterizing the latter only as "outdoor pool/spa activity, outdoor activity, and neighborhood
commercial land use activity." Neither here nor anywhere else in Lawson's study could I find
any indication that he included measurements of the noise of 4 jet skis and a loudspeaker (15
hours per day, most days of the year) among his "other site noises." If Lawson really did omit
measuring these noises in trying to project what the La Quinta Wavepark would sound like, his
current conclusions suffer a truly fatal blow and should not be accepted into the final EIR.
Finally, a minor point, but perhaps important in its own way. Lawson tells us that in order to
logarithmically combine all simultaneous Lemoore noises into a sum total, he plugged his
Lemoore recordings into a Noise Analysis computer program. Has anyone on the LQCC
critically inquired into the scientific standing of this program, whether it has been peer-
reviewed and deemed reliable, whether it's been adequately field-tested, or whether this was
perhaps the program's maiden voyage? Can we trust its output on such a crucial issue? I
ask because of something I thought I heard G. Simon say at the LQCC meeting of July 20,
2021, namely that Lawson's computer program is the brainchild of his retired rocket -scientist
(and presumably tech -hobbyist) dad. This wouldn't mean it can't be a great program but isn't
some extra due diligence required here?
Philip Novak, Professor Emeritus
Dept. of Philosophy and Religion
Dominican University of California
novak@dominican.edu
cc: Linda Evans, Mayor, levans@laquintaca.gov
Robert Radi, Mayor Pro Tem, rradi@laquintaca.gov.
Kathleen Fitzpatrick, Council Member, kfitzpatrick@laquintaca.gov
John Pena, Council Member, jpena@laquintaca.gov
Steve Sanchez, Council Member, ssanchez@laquintaca.gov
Cherri Flores, Planning Manager, cdd@la-quinta.org
Carlos Flores, Senior Planner, cdd@la-quinta.org
Siji Fernandez, Associate Planner, cdd@la-quinta.org
Diane Rebryna, drebryna@telusplanet.net
Derek Wong, derekwong745@yahoo.com
Ramon Baez, rfbaez7@gmail.com
Kathy Weiss, kathy@crystalspringsranch.co
Bridgett Novak, bnovak26@comcast.net
Page 3 of 3
Page 4 of 3
Dear Ms Sauviat Criste, Planning Consultant
RE: Coral Mountain Resort DEIR
1.2.1 Proposed Project
"Meanwhile, the project area west of Madison Street, is the subject of the General Plan Amendment, Zone Change,
new Specific Plan, Tentative Tract Map, Site Development Permit, and Development Agreement proposed
for the project and discussed in greater detail below."
There are six major changes proposed. Why did this project make it this far through planning and the
City Council? Where is the explanation of when and how this first proposed to amend the City's General
Plan? What was the justification to proceed further?
The city council should provide its residents with a written and public justification of its intent, so there
can be no misunderstanding of facts, history and responsibilities. In addition the city council should
certify that THEY PERSONALLY have studied this report and responses from residents.
"Existing residential communities occur to the north, south, and east. Avenue 58 and residential properties define
the project's northern boundary; Madison Street and the Andalusia community define the eastern boundary;
Coral Mountain defines the property's southwestern boundary; and vacant land and residential properties
define the southern and western boundaries."
The residential properties mentioned are not only Andalusia, but Trilogy to the Southeast, PGA West
Weiskopf to the Northeast, The Quarry to the West, Santerra to the North, Coral Mountain Estates to
the North. These existing communities house a significant population and conform to the current LQ
General Plan. All of the residents of these communities along with the SFR on Avenue 60 should have
been advised by mail in 2019 of their opportunity to comment at that time.
"Development Agreement (DA 2021-0002)
would vest the applicant's right to develop the Coral Mountain Resort Specific Plan area pursuant to the
entitlements described above, address short-term
rentals within all planning areas of the project, ensure that the project has a net positive fiscal impact on the City
despite the lack of property tax revenue to the City through 2035, and ensure the timely completion of
infrastructure to serve the project and surrounding area, and ensure that the project design features and
mitigation measures identified in this EIR are enforceable by the City as project requirements. "
STVR's will increase the traffic, noise and population. The City will not receive tax revenue through
2035! While approving STVR's which are being curtailed in the rest of the City, this is insane that it
would be allowed with NO TAX REVENUE! What exactly is a "net positive fiscal impact" without
revenue? This needs further explanation.
"Zone Change
(ZC 2019-0004)
will revise the existing zoning from Neighborhood Commercial, Low Density Residential, and Golf Course, to
Neighborhood Commercial (CN), Low Density Residential (RL), Parks and Recreation (PR), and Tourist
Commercial (CT). "
La Quinta Zoning Code Section 9.240.010 states the following required findings shall be made by the City
Council prior to approval of any specific plan or specific plan amendment:
1. Consistency with the General Plan — IT IS NOT
2. Public Welfare — The noise, traffic, light pollution is detrimental to the general welfare. "Significant
and Unavoidable" as shown on EIR
3. Land Use Compatibility — IT IS NOT compatible with surrounding low density adjacent communities.
4. Property Sustainability — The existing specific plan for this property is sustainable. It is unknown if a
Wave Basin will survive. All of Kelly Slater's recent Surf Ranch proposals have not come to fruition. He
has not exhibited that his business model will survive, much less open. Why should the City of LQ be the
test case? What will happen to a dry, abandoned wave pool community?
PR and CT zoning is completely inconsistent with the neighborhood. This is nothing more than a
glorified amusement park.
"The Coral Mountain Resort Specific Plan (SP 2020-
0002) will establish a new master plan governing the allowable land uses, design guidelines, and development
standards to allow creation of a boutique resort and master -
planned community. The Specific Plan includes four Planning Areas which are coterminous to the General Plan and
Zoning designation boundaries described above."
This is anything but a BOUTIQUE RESORT AND MASTER -PLANNED COMMUNITY! It is not private! It
cannot be private and generate enough attendance to justify the cost of this wave pool. It is clearly
open to the public who reserve a room at the hotel or rent one or two days at the STVR's. Master
Planned Communities do not invite 2500 people to attend events, four times a year.
"Planning Area I (PA 1) —
Neighborhood Commercial is located on 7.7 acres at the southwest corner of Avenue 58 and Madison Street, and
allows for the construction of 60,000 square feet of publicly accessible neighborhood commercial building
space with affiliated circulation and infrastructure improvements."
The opposite corner of Avenue 58 and Madison has been available for commercial development for the
11 years I have lived in Trilogy. For most of that time it was posted with a sign to attract commercial
tenants. Nothing was ever developed. Meriwether must also find commercial tenants in order to build
commercial space. It seems unlikely.
"PA 1I1 -
G — Back of House: The Back of House subarea contains approximately 26.5 acres that will be graded as level,
largely open land south of the Wave Basin. This subarea will provide unprogrammed gathering and staging
space for temporary equipment such as port -a -
potties, shade structures, tenting for inclement weather, and catering equipment that might be used during
events."
This area will cause significant traffic on Avenue 60. Andalusia and Trilogy have spent and continue to
spend significant funds to landscape and maintain the beauty of this street between our communities.
It will be a direct conduit for trucks hauling everything for these events. That is unacceptable. The
developer is directed to map out a route for all of the construction traffic. Given that Trilogy has not
been considered in any evaluation, the route will likely go along 60th from Monroe to the site.
"PA 111-
B — The Wave: The Wave subarea contains approximately 31.2 acres containing an artificial surf Wave Basin
and associated infrastructure.
PA 111-
C — Wave Club: The Wave Club subarea contains approximately 3.2 acres fronting the Wave Basin and will fu
nction as a private clubhouse with amenities for exclusive use y the Coral Mountain community."
"1.4 Areas of Controversy
; the potential for a significant change in the visual character of the area from a single -
story residential and golf environment to a hotel and Wave Basin facility; and the potential impacts of proposed 80 -
foot light standards surrounding the Wave Basin on the night sky, light and glare. Visual simulations, line -of -
sight analyses and photometric analyses were conducted for the project.
4.1 AESTHETICS
Table 1-3 Summary of Environmental Impacts and Mitigation states the level of Significance and
Mitigation clearly is "Significant and Unavoidable".
Page 136 of 738 includes the line of sight analysis.
LINE OF SIGHT SECTION 'E' FROM AVENUE 60
The viewpoint does not include views from Trilogy. It was taken west of the intersection of 60th and
Madison at street level. Many houses along 60th (Barrel Cactus Rd) are elevated above 60tH
Detail "A" Wave Basin/Light. The line of sight on Exhibit 4.1-12 shows that the tops of the 80 foot light
poles will be above the line of sight from street level. That does not take into consideration any of the
homes in Trilogy which are higher in elevation.
To state they will only be on from dusk to 10 pm is absurd! That is not a mitigation. The poles will be
visible 24 hours a day.
I personally live in Trilogy and my backyard on the golf course faces the southwest corner of this
community where the wave basin and lights are located. Currently I enjoy every morning and evening
looking directly at Coral Mountain and enjoy the change in colors. No six foot fence is going to cure
anything. I already can look over the fences surrounding Andalusia. (Photos attached)
In conclusion the Line of Sight Analysis is inadequate as it does not take into consideration the line of
sight from the northern and western boundaries of Trilogy. The City needs an independent analysis.
Coral Mountain Coral Mountain partially lies within the southwest corner of the project property. Coral Mountain extends over
400 feet above sea level and provides a scenic resource for the surrounding area. The Mountain is currently viewed without
significant obstructions from the public roadways, Avenue 58 to the north, and Madison Street to the east.
This section of the EIR gives no consideration to views from Trilogy. We have over 1200 homes many of
which have excellent views of Coral Mountain. To give our community no consideration is irresponsible.
Views from the streets alone is not a thorough analysis. A drive-by view from the street is inadequate.
Many views are from homes on the golf course inside the community.
The citizens of Trilogy deserve adequate consideration and an accurate analysis of the views and
noise.
4.11 Noise
The sounds from the waves, wave riding vehicles which accompany the surfers, competition
broadcasts/music and the public cheering will all be very disturbing. Viewing platforms on top of the
hotel will be visible and add to the light pollution. The sounds will bounce off Coral Mountain. I can
hear a car drive along 60th, stop at the Madison corner, turn right and continue to a stop at 58th. You
cannot tell me that the sounds created by all of the traffic and venue will not be noise pollution.
LAND USE
• Land use compatibility throughout the City. A WAVE BASIN IS NOT COMPATIBLE.
•Changes and variations from the Zoning Ordinance in a Specific Plan will be offset by high quality design, amenities and mix
of land uses. A WAVE BASIN AMUSEMENT AND STVR'S DOES NOT JUSTIFY THE CHANGE.
• A broad range of housing types and choices for all residents of the City. THE RANGE OF HOUSING TYPES DOES NOT BENEFIT
THE RESIDENTS OF THE CITY. A FEW HIGH PRICED LOTS FOR SFR'S — THERE ARE PLENTY ALREADY IN LA QUINTA.
• Consider changes in market demand in residential product type to meet the needs of current and future residents. THERE IS
NO DEMAND FOR A TOURIST RESORT FOR NON-RESIDENTS.
•A balanced and varied economic base which provides a broad range of goods and services to the City's residents and the regio
n. A SMALL COMMERCIAL DEVELOPMENT AT THE CORNER OF 58 AND MADISON DOES NOT SATISFY THIS POLICY.
•Maintain commercial development standards in the Zoning Ordinance including setbacks, height, pad elevations and other
design and performance standards that assure a high quality of development. 17-80 FOOT LIGHT POLES CREATE LIGHT
POLLUTION AND ARE NOT CONSISTENT WITH THE ZONING ORDINANCE.
• Support and encourage the expansion of the resort industry as a key component of the City's economic base.
SILVERROCK RESORT HAS BEEN IN PLANNING AND CONSTRUCTION FOR MANY YEARS AND IS SUFFICIENT TO SATISFY
"EXPANSION".
LIVABLE COMMUNITY
A community that provides the best possible quality of life for all its residents. THIS DEVELOPMENT WILL NEGATIVELY IMPACT
SEVERAL COMMUNITIES WITH THOUSANDS OF RESIDENTS.
ECONOMIC DEVELOPMENT
The Land Use Element shall maintain a balance of land use designations to address economic needs, meet market demand,
and assure a wide range of development opportunities. WHERE I5 THE MARKET DEMAND FOR A WAVE BASIN FOR SURFERS IN
THE DESERT.
The continued growth of the tourism and resort industries in the City. THIS I5 THE WRONG LOCATION FOR A PUBLIC RESORT.
HOUSING
Provide housing opportunities that meet the diverse needs of the City's existing and projected population. Identify adequate
sites to accommodate a range of product types, densities, and prices to address the housing needs of all household types,
lifestyles, and income levels. Conserve and improve the quality of existing La Quinta neighborhoods and
individual properties. MILLION DOLLAR LOTS FOR SFR'S ARE READILY AVAILABLE IN LQ. STVR'S ARE
ALREADY OPPOSED BY THE CITY. THERE IS NO LOW INCOME HOUSING PROPOSED.
WATER RESOURCES
The project promotes water conservation through the use of drought tolerant plant materials and water efficient irrigatio
n techniques. The project will comply with all City and Coachella Valley Water District (CVWD) regulations and building code
s for water conservation. Additionally, recycled water will be used for common area irrigation for landscaping. The Wave
Basin provides a recreational amenity to support the proposed resort and residential uses, and does so with substantially less
water demand than required for alternatives amenities, such as an 18 -hole golf course.
DROUGHT TOLERANT PLANTS AND IRRIGATION ARE ALREADY USED ALL OVER LA QUINTA. THIS IS NOT
A MOTIVATION TO APPROVE THIS PROJECT. RECYCLED WATER FOR IRRIGATION vs THE FRESH WATER
TO FILL A WAVE BASIN IS NOT A JUSTIFICATION. MOST GOLF COURSES ALREADY USE RECLAIMED
WATER NOT FRESH WATER.
One cannot ignore the daily headlines from e -news, TV reports, newspapers and magazine articles
declaring a state -of -emergency with the reservoirs servicing the western states all reporting historic
lower than normal levels. Drought monitoring maps show most of Riverside County is in the severe
drought category but is edging closer to the extreme drought classification which is thought to be
inevitable. Whether this summer or next spring, a full state drought declaration could be ordered and
restrictions enacted.
How will wave pools or lagoons operate then? How will these wave basins and oasis lagoons be
replenished factoring in the enormous daily evaporation rates and the heavy winds inherent in our
valley? Answer: by drawing ever more potable water from the aquifers of course. Just last year in
2020, the entire Coachella Valley endured 140 confirmed days of 100 degree plus temperatures.
Additionally, IID has recently published warnings that rolling brownouts for this summer are likely to
occur which will affect homes, businesses, and wave pools/lagoons equally. However, downtime for surf
parks and lagoons is lost revenue.
"In order to assure that everyone in the region has sufficient water, it is important that La Quinta, as one
of the stewards of the local water supply, manages and conserves this important resource" (quote from
Water Resources III -57).
"The City's goals, policies and programs relating to water resource management are important to the
District's continued ability to provide domestic water to new and existing
developments in the City and the Sphere of Influence". (quote from Water Resources III -57).
"Continued growth in the City and the region has resulted in an increased demand for domestic water.
As a result, CVWD extracts more water from the Lower Thermal sub -area than is naturally recharged
into it every year — a condition known as overdraft. "(quote from Water Resources III -58)."
An "effective manner to reduce overdraft in the aquifer is through water conservation. The City and
CVWD have implemented a number of conservation programs in recent years which have reduced
consumption of domestic water. It is critical that these programs continue and expand, as possible,
through build out of the General Plan". (quote from Water Resources III -60
Just because a deemed water usage may have been acceptable in the past, it does not mean that
responsible changes need not be made going forward as new environmentally challenging conditions
might dictate.
It's unacceptable that the residents of La Quinta be required to conserve water with respect to their
personal use (which we would willingly comply with in the interest of being good citizens and stewards of
our water resources), while a commercial venture such as this wave/surf park continues to draw
extraordinarily on our aquifers and power supply for an essentially private recreational outlet.
The developer has repeatedly stated that the Coral Mountain Project will use less water than a golf
course. It is common knowledge that golf courses, both existing and new, have many water conservation
options and measures available, wave pools and lagoons have no such alternatives. Wave Pools must
use clean, fresh drinking water from the two sub -basins servicing our valley. These sub -basins rely on
replenishment from the Colorado River but La Quinta cannot count on that source for our aquifers
anymore, especially in a historic drought.
NOISE
Why was there no noise receiver location in Trilogy? Trilogy is closer to the wave basin than those
residents on 58th
In conclusion I firmly believe that the draft EIR is slighted heavily in favor of the developer and has not
considered the residents of Trilogy who are closer to the wave basin are and associated structures than
any of the communities on 58th. The city council should provide its residents with a written and public
justification of its intent, so there can be no misunderstanding of facts, history and responsibilities. In
addition the city council should certify that THEY PERSONALLY have studied this report and responses
from residents.
Unlike many politicians who vote without reading a word of a bill, I trust that our City Council will do
its duty and study the draft EIR and all responses from the citizens of La Quinta before voting.
Regards,
Sandra Stratton
81302 Barrel Cactus Rd.
La Quinta, CA 92253
sstratton@dc.rr.com
Mail - Consulting Planner - Outlook https://outlook.office.com/mail/deeplink9popoutv2=1&version=202107...
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Coral Mountain Resort DEIR
TB
Label: 60 Days Delete (60 days) Expires: Sat 10/2/2021 8:41 AM
Terje Berger <terjeberger@yahoo.com>
Tue 8/3/2021 8:41 AM
To: Consulting Planner
** 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. **
Hi,
La Quinta don't have a lot of recreation space left. It is this space and south of La Quinta Cove.
California suffer from a severe drought which get worse for every year. It doesn't sound well to put a water park
in.
If the contractor want land for a water park, there is plenty over by Classic Club and the the new sports arena that
is planned.
Terje Berger
52705 Avenida Obregon
La Quinta
Reply Forward
1 of 1 8/3/21, 9:13 AM
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT ALENA CALLIMANIS
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
From: Alena Callimanis
Sent: Tuesday, August 3, 2021 11:39 AM
To: Monika Radeva; City Clerk Mail
Subject: Alena Callimanis presentation for 4pm August 3, 2021 City Council presentation Public Comment
Session
Attachments: CallimanisLaQuintaPresentation8032021V4.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. **
I am so sorry this is late. I hope I can still present this during the public comments section today in the City Council
Meeting. I would also like to get the Council at some point a copy of the presentation. Should I bring copies with me?
Thank you for your help.
P.S. I did this without a video I wanted. I was slammed at work and did not have enough time this morning to embed
it. Lucky you!!! ;-)
Alena Callimanis
La Quinta, CA 92253
1
Coral Mountain Surf Resort
The Wrong Location in this Heat
Alena Callimanis
Bachelor of Science, Rensselaer Polytechnic Institute
Masters, Physics SUNY Stony Brook
La Quinta CA 92253
WADI Adventure Park in the United Arab Emirates
• Only other surfing park in a desert environment
• Contacted the operations manager at WADI to get insight into the challenges
• 140 mile pipeline from coast to bring in desalinated water at a rate of 1 million
gallons a week for total use at the Park
• 2.8 Million gallon pool, cooled to 85 degrees in the summer
• Pools in the 90s plus hot temperatures creates potential for heat stroke.
Surfers acknowledge artificial surf wave riding more strenuous due to
amount of time ric ing the waves
• Warmer pools can incubate Protozoa and viruses (brain -eating amoeba)
• Algae buildup increases significantly in hot water; chlorine requirement
increase makes pool use a skin and nasal -passage irritant
• Coral Mountain basing their chlorine needs on their Lemoore Surf Park
• 40,000 USG added daily to the Surf pool May to November and 10,000 USG from
Dec to Apr
Let's look at evaporation numbers
• In the CVWD Water Assessment Coral Mountain surf pool replenishment is
listed at 39 million gallons yearly
• Not based on any knowledge of surf pool requirements. Based on standard factor of
1.2 for moving water and pan evaporation numbers from 2005 when we had only 99
days over 100 degrees
• The World Surf League, which purchased Kelly Slater wave technology, wrote
that on very hot days at Lemoore Surf Ranch, the pool lost 250,000 gallons a
day. They had 27 days over 100 degrees in 2020 with hottest temperature of
107 degrees
• La Quinta had 143 days over 100 degrees in 2020. 250,000 gallons times 143
equals 36 million gallons lost to evaporation in 143 days
• We had 56 days over 110 degrees. So how much above 250,000 gallons is
the evaporation on those days?
• What about the rest of the 222 days of the year? We had 51 days over 90
degrees. Plus our very windy days adding to evaporation
• You see very quickly that the 39 million gallons calculated by CVWD is wrong
Golf Courses vs Surf Pool
• Please stop believing the developer that the Surf Basin will use 25% of the water usage of a golf
course
• Please remember that golf courses can use recycled and grey water; surf pools cannot
• A local golf course decreased their water usage summer 2020 by 17% with no problem
• Surf park can't decrease their water usage or they close
• Golf courses have new designs that are environmentally friendly
• I am not advocating a golf course at this site. Lots of choices for family -friendly amenities
Rock wall climbing Bike Trails
Hiking trails Community pool
Miniature Golf Playgrounds
Tennis Pickleball
etc.
THIS IS THE TYPE OF FAMILY FRIENDLY RESIDENTIAL DEVELOPMENT LA QUINTA NEEDS
How can they say no noise impact
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT WENDY CLARKE
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
From: WcI
Sent: Monday, August 2, 2021 3:33 PM
To: City Clerk Mail
Subject: Request to speak in person/public comment: joint meeting City Council/Planning Commission
Attachments: City Council presentation W.Clarke Final 08_21.docx
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.
Good Afternoon, Monica and Nicole
I respectfully request to speak in person during the joint meeting of City Council and the Planning
Commission's public session tomorrow, Aug 3 @ 7 pm. My written presentation is attached for
distribution.
Thank you for your help. Let me know if there is anything else you need.I look forward to meeting you.
Best regards, Wendy
Wendy Clarke
La Quinta
Public Comment/non agenda item
Opposition to Coral Mountain Wave rezoning - non agenda item
Written presentation attached, request to speak during public session.
Good afternoon Mayor Evans, Council members, Planning Commission,and staff. Thank you
for your service. Mayor, it is good to see you and other familiar faces. My name is Wendy
Clarke; My Family has lived full-time in the desert for 34 yrs.; 16 years ago, I moved to
Trilogy.
I am here to speak to the Coral Mountain Wave rezoning request.
Exempt from pass-through property tax $$ due to the agreement with The Thermal
Redevelopment Project, this undeveloped land provides little revenue. I trust, you, the
current city council, might have negotiated something different. If
rezoned, LQ gains TOT and South LQ residents'quality of life is permanently, negatively
impacted.
John Gamlin, project president, recently shared that he has managed S.LQ, luxury, low-density
residential neighborhoods. The CMWR will not be similar in any way with a massive artificial
surf wave, stadium lighting,broadcast system, music, and STVRenters.
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENT WENDY CLARKE
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
Beyond the 4 proposed annual events, additional temporary -use permits are likely. Kelly
Slater has made public his support of artificial surf waves for The Ultimate
Surfer, for Olympic training and competition. LA is the 2028 Summer Olympic host. What
will one special event look like? Chaos for 1,000s of residents. Our neighborhoods are not
transient or a tourist destination. We intentionally purchased homes away from the
commercial corridor. We relax after a busy workday, exercise, retire, enjoy nature, socialize.
When we drive down Madison nearing home, there is a sense of calm. We deserve protection
of this paradise.
Today, we are environmentally mindful and face a life-threatening drought:
lakes reaching historic lows. Supplying 80% of the world, California's almonds are no longer
being planted due to water shortages. We have beenasked to reduce water consumption by
15%. Any governing body approving any project that uses a significant amount of water,
is irresponsible.
This Surf Wave will deplete drinking water from our Colorado River supplied Aquifer. NPR
reports, "The Colorado River is tapped out.Extremely dry conditions like the region is
experiencing in 2021, make clear that the Colorado River is unable to meet all the demands
communities in the Western U.S. have placed on it, and it's up to its biggest users to decide
who has to rely on it less".
What are our mutual responsibilities?
Everyone reduces water consumption
CVWD transitions remaining golf courses to grey water and denies all
nonessential, requests
requiring water sourced from the Colorado River.
The city supports independent studies that evaluate local evaporation rates, actual
site noise, and traffic studies post pandemic.
The city observes its General Plan 2035 "Livable community" thatspeaks to "long- term
quality of life of its residents".
It is great to think big; change is inevitable. Meriwether has spent
millions, aligning with Kelly Slater and Michael Schwab. It does not
justify their project. Please honor S. La Quinta's established communities and reject The
Wave, rezoning request. It will have permanent, quality -of -
life consequences for many 1000's of residents.
Respectfully,
Wendy Clarke
2
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENTS DIANE REBRYNA, AND ANAST DEMITT
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
From: Diane Rebryna
Sent: Monday, August 2, 2021 4:31 PM
To: City Clerk Mail
Subject: WRITTEN COMMENTS CC MEETING August 3, 2021 re: Coral Mountain Resort - Diane Rebryna and
Anast Demitt wish to verbally address City Council during the open session.
Attachments: PDF FINAL REBRYNA DEMITT August 3 PRESENTATION TO CITY COUNCILand the PLANNING
COMMISSION .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.
Hello again,
Further to my email of earlier today, please find the written version of our comments to be presented in the Open
Session in front of City Council attached.
We wish these to be part of the public record.
Thank you again for your assistance with this; again, please feel free to reach out with any questions or comments.
Kind regards,
Diane
On Aug 2, 2021, at 3:36 PM, Diane Rebryna wrote:
Hello,
My name is Diane Rebryna
My husband's name is Anast Demitt.
We reside at
Our phone number is
, La Quinta CA 92253
We wish to address City Council during the open session re the Coral Mountain Resort - Diane would
like to speak first using her 3 minutes, and to correlate, Anast would like to follow immediately
thereafter with his allotted 3 minutes.
Thank you for accommodating our request.
If there is anything else that you require at this time, please do not hesitate to reach out.
Kind regards,
Diane
1
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENTS DIANE REBRYNA, AND ANAST DEMITT
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
I will be forwarding a written record of these same comments to your attention tomorrow.
2
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENTS DIANE REBRYNA, AND ANAST DEMITT
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
Good afternoon Honorable Mayor and City Council Members,
Thank you for allowing me to speak today regarding Coral Mountain Resort, which I will refer to
going forward as "the Project".
My name is Diane Rebryna, and my husband Anast Demitt and I are very blessed to have our
winter home here at Trilogy in La Quinta. Please know that we truly love this city, particularly its
tranquil and beautiful southeast corner, which is why we chose to settle there.
At the outset, I wish to say that we've spent an inordinate amount of time reviewing the Draft
Environmental Impact Report - which at over 1500 pages was very challenging and intimidating
to the average reader to say the least. There were so many topics, with this and that "study"
and these and those "mitigating factors" that were covered. Some of the DEIR was formulated
with conjectures as evidenced by the statements such as "are not anticipated to"," would not
significantly impact", etc. I certainly felt overwhelmed as I tried to extrapolate all of the potential
impacts of this Project on life as we know it in South La Quinta.
To help me understand the DEIR, I also reviewed the the 2021 CEQA guidelines - a reference
document based on the CA Environmental Quality Act to which is used to develop
Environmental Impact Reports. It was here that I had my "eureka" moment ! This document, as
part of the DEIR checklist speaks to a topic called "Mandatory Findings of Significance"
where the following is asked: "Does the Project have environmental effects which will
cause substantial adverse effects on human beings, either directly or indirectly"?
That is when it hit me ! - this Project, as a result of the request for REZONING to allow for it
definitely has many known and potentially unknown environmental domino type effects on the
"human beings" - those being us - the residents of the communities nearby.
1. First of all, the Developer has asked for Sub - Phase Development based on "market and
consumer demand". I am overwhelmed as I think of how plans for our lives will be totally
predicated on the fact that the waves and phases of construction noise and traffic could go on
for years and years. We may never see the completion of this Project in our time here !
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENTS DIANE REBRYNA, AND ANAST DEMITT
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
2. As a result of the rezoning change, Special Events asked for by the Developer could be
permitted through the use of TUPs. What's to prevent the 4 that are being asked for from turning
into 8, or more, per year ? City noise ordinances will be altered to accommodate these. There
will definitely be access and egress challenges to most of the surrounding communities - this
could impact our safety and well being, should there be traffic tie ups both during as well s
before and after Special Events to allow for prep and take down days.
3. Finally, I am totally perplexed as to how this Project with its enormous water usage with 18
million gallons of water to fill it from our aquifers would even be considered in our desert
environment with its high temperatures, high evaporation rate and winds, especially
during a mega -drought. I know of no other "recreational activity' which would even be
considered if there was an equivalent current and potential future threat to the environment as a
consequence. There is a global movement under way to conserve water, with good reason, and
we must think of our children and grandchildren.
My name is Anast Demitt and Diane is my wife. Thank you for allowing me to continue on with
our presentation. This topic is of such concern to me that I felt I needed to travel here to speak
to Council today and express my concerns on this proposed Development.
1. Traffic - Once the Tourist Commercial aspect of Coral Mountain Resort is "up and running"
there will traffic changes that will significantly impact our day to day lives as we know them.
The traffic study included in the DEIR is flawed in my opinion as it was conducted during COVID
when many seasonal residents chose not to return to the valley. The base traffic volumes used
in the analysis are therefore an underestimation of the actual volumes. The study shows that
levels of service in some of the affected areas will be reduced to level F, the lowest possible
level of service in traffic engineering. That means long delays at intersections and increased
commute times regulating in more GHG emissions. The DEIR recommends that changes be
implemented to reduce the impacts on the level of service. The developer indicates that they
will pay for "their proportional share". The citizens of LQ Quinta are then stuck with the
remainder of the costs. This does not seem to be a fair trade off as we the citizens are
subsidizing a private development that we will not see any benefit from.
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENTS DIANE REBRYNA, AND ANAST DEMITT
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
2. Lighting - The Developer proposes seventeen 80 foot tall light towers and lighting with
variances in parking lots and visitor areas. The effect of this lighting is another unknown
that cannot be quantified at this location. The proposed development will be similar to what I
see when I drive by the Indian Wells Tennis Gardens at night. Furthermore, from the proposed
project site, the illumination from a public park in Coachella is clearly visible in our skies. This
project, with its seventeen light towers and commercial glare, is not the place that I would
choose to observe the beautiful dark skies that our desert is known for. We will say good bye to
that here as well.
3. Short Term Vacation Rentals - One of the biggest concerns that I have relates to the
potential approval of over 700 STVR's for the site, should rezoning occur. Every room in the
hotel and casitas and every house will be approved as an STVR. The proposed $2.5M dollar
homes - AND UP - will have multiple bedrooms with multiple people sharing a house. Add in a
full hotel for one of the Special Events or even for Coachella or Stagecoach, and this
development rapidly becomes nothing more than a large scale B&B with a rotating door. That
could mean literally 5 to 6 thousand additional transient visitors in and out of the Project each
day.
Is this the type of intrusive commercial development that we want "inserted" amongst the
established communities of the Quarry, Trilogy, PGA West, Andalusia and Santerra, to name a
few residential districts close by ?
All for the sake of the TOTS that will be collected on the STVRs? What happened to the highly
touted goals for quality of life in the LA Quinta 2035 plan? Is this development and all that it
brings along with it really worth the adverse impact it creates on the residents and citizens of
South La Quinta?
I'm respectfully asking you today to to please "stick to the plan", that is, the 2035 La Quinta
General Plan - particularly the component that speaks to the "livable community" which
addresses the "long- term quality of life of its residents."
CITY COUNCIL MEETING - AUGUST 3, 2021 - WRITTEN PUBLIC COMMENTS BY RESIDENTS DIANE REBRYNA, AND ANAST DEMITT
PUBLIC COMMENTS ON MATTERS NOT ON THE AGENDA - OPPOSING THE WAVE PROJECT
This PROJECT is a square peg in a round hole! I encourage you to do as we did and
please read the entire 1500 plus page DEIR. You will see that there is not enough certainty
from the information presented to allow for rezoning with confidence, and to ensure that there
will not be long term life impacting consequences for we, those residents - `those human
beings" - who live nearby.
Thank you for allowing us to provide our perspective today to you. Please say no to the
rezoning of this Parcel of land to Tourist Commercial.
Respectfully submitted on August 2, 2021 by:
Diane Rebryna & Anast Demitt
La Quinta, CA
92253
Tuesday, August 3, 2021 at 09:18:32 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR
Date: Tuesday, August 3, 2021 at 4:57:21 AM Pacific Daylight Time
From: ancalawest@yahoo.com
To: consultingplanner@laquintaca.gov
As a full-time resident of La Quinta - and as someone who does not surf and has absolutely
no ties or economic interests in this proposed project - I wanted to express my support for
the Coral Mountain Resort, the proposed luxury, private, residential community, including its
surfable wave pool.
My support comes from these perspectives - but mostly from making numerous visits to
similar surfable pools across the U.S. I made these visits as a marketing executive on behalf
of my employer to evaluate potential sponsorship participation in events taking place at
these surfable wave pools.
My observations from these visits gives me confidence in lending my support for the
proposed La Quinta project as one that is consistent with the type of community La Quinta
aspires to be - a resort town that offers an exceptional level of high quality amenities.
• My personal experiences visiting surfable wave pools across Texas and California
taught me that these facilities attract serious athletes and avid surfing enthusiasts of
every age and gender who are every bit as similar to the kinds of people you'll see
golfing, playing tennis, or enjoying polo on any given day across the communities of La
Quinta and across the Coachella Valley.
• I would consider the atmosphere of these surf parks to be akin to any golf range -
participants were quiet, cerebral, and focused on improving their game - passionate
about the sport. I never once saw rowdy, party, or raucous behavior. I even saw diverse
groups of local kids taking surf lessons on several occasions. A surfable wave pool can
only hold a relatively small number of participants at any given time - not unlike a golf
course.
• Just like golf, it's not a cheap sport - for example, at Kelly Slater's Surf Ranch 2021, a
day of private activities and lessons begins at
$3,100.00: https://fulcrumsurf.com/shop/surf-ranch/
• La Quinta has an opportunity to continue to diversify its "quality" outdoor recreational
amenities and appeal for continued economic prosperity and relevancy, including
outdoor activities that drive economic activities during "off season" periods when it's
too hot for traditional La Quinta diversions such as tennis, golf, even hiking. Surfing is
one such high-quality amenity, especially when combined with the resort itself.
• Competitive surfing events are every bit as serious as a polo or golf tournament. Should
competitive events take place, expect the audiences to be as well behaved as those
who attend one of the numerous pro and amateur golf, polo and tennis events in our
communities.
would encourage anyone with serious reservations about to make a visit to a surfable wave
park. If you can't make it, check Kelly Slater's Surf Ranch online: Kelly Slater Wave Company
Page 1 of 2
Kelly Slater Wave Company
The Kelly Slater Wave Company combines cutting edge science,
engineering and design to create the longest, ridea...
Dan Stiel
PO Box 437
La Quinta, CA 92247
Page 2 of 2
Wednesday, August 4, 2021 at 12:47:01 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR
Date: Tuesday, August 3, 2021 at 5:25:23 PM Pacific Daylight Time
From: Thomas E Swope Jr
To: consultingplanner@laquintaca.gov
Hello, My name is Thomas Swope Jr, and I live in Cathedral city CA.
I do realize that I am not a La Quinta resident, but I wanted to write
to you, or someone and express my concerns about building a wave
park in our desert.
Our desert is always in a constant state of drought, and that
situation is most likely never going to change. We all are dependent
on our aquifer for our drinking water, and or other water needs, and
I really think that filling a wave pool with my, and everyone else's
DRINKING WATER!! Is a really bad and stupid idea.
How exactly do you justify asking everyone to conserve as much
water as possible, and then you allow a wave pool to be built that
will consume millions of gallons of water to full, and to keep full. I
honestly can't believe that this project is being entertained by your
city council. The answer should be elementary to each and every
one of you. WE DON'T HAVE THE WATER FOR SUCH A PROJECT, so
the answer should be NO!!
Please, for every residents sake in our or valley, do the right thing
and DO NOT allow this project to move forward. It's a form of waste
that we all cannot afford.
Thank you for taking the time to read my letter.
Page 1 of 1
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Coral Mountain Resort DEIR
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Jan Talbott <talbott58@sbcglobal.net>
Tue 8/3/2021 4:12 PM
To: Consulting Planner
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As a year -around resident at Trilogy and close to the corner of Madison and 60 were quite
concerned about this project in terms of noise,traffic, night light pollution, water usage, etc.
Perhaps even more, we're worried as to what could happen if this thing goes belly up in a
couple years. That would be an albatross hard to dispose.
Please do not authorize the zoning changes necessary to locate this project in our
residential area. There are many, many available parcels throughout the Valley where such a
project would have little to no negative impact on the residential community.
Jan Wm. Talbott
Terry Ann Hoist
Sent from my iPhone
Reply Forward
1 of 1 8/3/21, 4:46 PM
Kathy Weiss comments to LQ City Council Meeting Aug 3,2021
Honorable Mayor Evans, Members of the Council, staff. Thank you for the
opportunity to speak on the Coral Mountain project. My name is Kathy Weiss.
am a homeowner /resident at the Quarry.
#1. Location
Many of you might think The Quarry won't be impacted because the DIR said
there was nothing to The West of the project.
For the record, The Quarry is to The West of the proposed Wave Basin at Coral
Mountain.
#2. Noise
Everyone who lives near Coral Mountain knows that sound reverberates
throughout this area. I can hear the murmur of simple conversations
between the hikers in Coral Mountain Park, and at Lake Cahuilla Camper Park.
From my home at The Quarry, I can hear the music, the bass beat, and the roar
of the crowds during Coachella and StageCoach. In fact, from inside my home,
can tell you if the vehicle rumbling down west of 58th & Madison has a gasoline
or diesel engine.
Just like my neighbors, I hear the sounds of coyotes and hoot owls every
evening.
ask any sound engineer, that has NOT been hired by the Developer, to
demonstrate sound trajectory to La Quinta Mayor & City Council members. The
finding of "no significant" noise impact in the DIR illustrates what a one-sided
publication this is.
#3 Side effects of Tourist/Commercial Zoning
Louder noise allowances, longer business hours, overnight stays, special
events, bigger and taller buildings, and public safety commercial lighting are
permitted, and sometimes required under Tourist/Commercial zoning.
Here is just one example- the Wave Basin requires an audible (not visual) 30 -
second alarm if there is an emergency, followed by another 30 -second audible
alarm to signal the emergency has ended. California State mandated Alarm can
be as loud as it needs to be in order to be heard over "The Tub and The Train,"
(nickname given to the Wave Basin by Kelly Slater's peers), the screaming and
cheering crowds, the crashing of waves onto concrete flooring, and the jet skis
zipping up and down the Basin. As the Tub is geared for the Novice Surfer
Tourist, the alarms could be going off several times a day.
If I had wanted to live in a noisy, tourist/commercial neighborhood, I certainly
wouldn't have built a home at The Quarry.
#4 STVR's
As La Quinta City Council and its residents know, STVR's are a big nuisance,
not only here in La Quinta, but elsewhere in Coachella Valley, and wherever
people want to Vacation. The vast majority of people who propose short term
vacation rentals do not live in this town. Most are out of towners or Commercial
investors.
If City Council choses 750 more STVRs over our tranquil South La Quinta
Community, you are voting against your own Community. Are we a community
or a Commodity to you?
To remind everyone, the Development Agreement proposes:
"Short term vacation rentals will be an allowable use in all planning areas
within the Project ".
In "Developer Speak"- That means 100% of the 600 "Dwelling Units" (per the
Developer's words) built on this property can be STVR's. In essence an
overnight Hotel Room with a shared kitchen. The developer states "Dwelling
Unit" prices will start at $2.5 million and go to $5 million. That tells me the
Dwelling Units are going to be McMansions w/ 3 to 10 bedrooms each. Add the
massive 150 room key hotel and we have "Surf City Party- land" with (a potential
overnight) population of 4-5,000 lodgers at our doorsteps. Simply put, 750
STVR dwellings and 4-5,000 lodgers will be throbbing in the middle of
Andalusia, Trilogy, The Quarry, Santerra, Puerta Azul and PGA West (which has
a section on 58th), plus the other resident communities lining 581" Street West of
Madison. This Meriwether project goes against every single zoning statement in
the La Quinta General Plan 2035.
The developer, when asked about the noise and light pollution, has been very
careful to always reply, "we don't want the noise to impact our residents." From
reading the DIR and the DA, this project is not catering to have many residents.
want to emphasize the developer plans to build the Wave Basin, Hotel and
Casitas first. After completion in 2-5 years down the road, only then will
developer construct dwelling units on the sold Lots. A "Dwelling Unit "- per the
developer's own words, in the DIR, has an Owner(s), but not necessarily a
Resident. A Rental has an "Owner", a Home has a "Resident." Keep in mind,
The "Dwelling Unit" owners that chose to buy and build at Coral Mountain
Wave Park, plus the tourists booking a stay, do so knowing that the "Tub
and Train", announcer, jet skis, crowds, entertainment venues, etc. will be
going non-stop 15 hours daily with 1,000's of tourist/lodgers milling
around outside all over the place.
It's easy for the Wave Park lodgers to leave and go back home when tired of the
noise, crowds, and commotion. For the neighboring homeowners, it is not so
easy. WE will have to soundproof our lives, unable to hear the birds, bees and
other native wildlife. We will be stuck in a nightmare that never ends.
The surrounding neighborhood property owners and I bought &/or built homes in
South La Quinta because we wanted a peaceful, low-key residential
atmosphere. We enjoy the light traffic, no hustle -bustle, being outside listening to
the sounds of nature. Our homes and daily life will be impacted negatively in
which way.
Before I chose the location of where I live in La Quinta, I asked my realtor what
the West Andalusia parcel was zoned for. The realtor told me "Low -Density
Residential w/18 -hole golf course. It is planned to be Andalusia's higher -end
homes with their own golf -course." I did more due diligence by visiting the
Andalusia Sales site, looked at their Master Plan 3-D model and confirmed the
zoning with the Developer's representative. Finally, after studying the LQ City
zoning map, I felt confident to purchase my lot and commence building a home
at The Quarry.
If any of us wanted to live next door to a "Surf City Mega- Event Complex" we
would have done so. The majority of the homeowners in South La Quinta moved
here by choice, (as we were not born and raised in La Quinta.)
Permitting this Zone change is slap in the Face to every single person that
chose to live, buy, and/or build in South La Quinta.
LQ City Council would be showing us that we, your South La Quinta residents,
just don't matter.
thought City Governments were designed to protect its residents and their
properties, and make its Residents pleased to be living there.
You can call me naive, because I never thought our local government would
cater to an out of state rookie -developer, that has only been in business for 8
years. For the record- This developer has already pulled the plug on one La
Quinta based, City owned development: SilverRock.
La Quinta Government should stand by their thousands of residents. Not the
Out -of -Town developer that has a dubious history w/ La Quinta.
#5. Developer Agreement
For the record, the developer's proposed time frame, as proposed in the DA, is 40 years.
Thatis4-0. FORTY.
quote this 6- year old article from the Desert Sun dated
October 21, 2015, regarding the SilverRock project.
"Robert Green Jr., of Robert Green Co., and John Gamlin,
of Sofia Investments, will keep SilverRock moving forward after Meriwether Co.
withdrew to pursue other interests, city Economist McMillen said."
(For the record, this is the same John Gamlin we heard speak on Meriwether's
behalf at the last open City Council Meeting)
In other words, Meriwether, the same developer that dropped Silver Rock to
pursue "Other interests", wants a 40- year time frame in the Development
Agreement.
That is alarming. What if Meriwether drops this one too?
Yes, I am well aware that Developers, City, State & Public entities, Planning
Business, Consultants, Realtors, etc. have interacted, networked & fraternized
with each other on a daily basis for many, many years. In fact, most of LQ City
Council members are involved in these types of pursuits. When it comes to
assembling DIRs for City Review, it is definitely a stacked deck in favor of the
Developer. The "no significant impact" stated over and over in the DIR clearly
illustrated this bias. LQ Government's easy acceptance of the more than 1,000 -
page DIR cemented the fact. The repetitive "No significant Effect" would be
laughable if the thousand pages+ plus DIR wasn't so blatant in its lack of
transparency, readability, and comprehension.
Having personally met and known many Developers, a good, responsible,
and successful Developer looks to invest and "develop" where there is a
real need, the timing is right, and there is an overwhelming neighborhood
desire for the "Development" to happen. That is certainly not the case
here. All which makes me ask why the Developer and their financial
backers bought a parcel that did not have the desired Zoning already in
place for their Project?
Who, in LQ government, gave them the "greenlight"?
Why would La Quinta government even think this is "in character" of the existing
neighborhood zoning?
In summation, I beg of you, Mayor Evans, and La Quinta City Council Members
to vote NO on granting the Property Commercial/Tourist zoning. A zone change
permit would be absolute disaster in the making for the many thousands of
residents close to this proposed Tourist/Commercial Mega -development.
Sincerely,
Kathy Weiss
La Quinta City Council Meeting August 3, 2021
Public Comment on Matters Not on the Agenda
https://laquinta.l2milesout.com/video/meeting/81158bc2-9a14-47c8-9a20-7c4e88cea5e6
Speakers discussing the Coral Mountain Resort Project and time of appearance in video linked
above.
In -Person Comments
Alena Callimanis (Transcribed); 0:45 — 7:35 minutes
Kelly Welton (Transcribed); 7:46 — 9:15 minutes
Wendy Clarke (Transcribed); 9:20 — 14:06 minutes
Diane Rebryna and Anast Demitt (Transcribed); 14:15 — 23:49 minutes
Verbal Comments via Teleconference
Kathy Weiss (Transcribed); 27:35 — 38:45 minutes
City Council Meeting 8-03-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/81158bc2-9a14-47c8-9a20-7c4e88cea5e6
Located at: 0:45 — 7:30 minutes
Speaker: Alena Callimanis
Hello. My name is Alena Callimanis. What should I do about this [indicating mask]?
Mayor: Your choice.
Callimanis: I can? Alright, that way I can make sure you hear me. Okay, they are bringing up my
presentation, and uh. It's only going to be up there? [indicating one screen] Okay. There we go, great.
Uh, so the first thing I want to do, and I'm not saying this to brag, or anything like that, but, I mean, I do
have a bachelors in physics, I have a masters in physics. So, I take my research in whatever I do very
seriously. So, when I put my name on something, that means I really looked into it and feel 100 percent
confident that I am giving the correct information. So, I wanted to make sure that I covered that upfront.
Alright, um. This is the WADI Adventure Park in the U.A.E. It's the only other surfing park in a desert
environment that maps to what we have. And I think I talked about it before. But what I did was, I
contacted the operations manager at that pool so that I could understand the challenges they have by
having a surf pool in the heat like we do. Uh, the first thing of course is that, you know, they had a 140 -
mile pipeline from the coast that brings desalinated water to the, um, to them because they don't have
an aquifer where they are. Um, but, one of the things that's really important is that they told me they
cool the pool to 85 degrees for a number of reasons are listed here.
• Pools in the 90s, plus hot temperatures like we're having in the 110s and so on, uh create
potential for heat stroke. And that has happened.
• Uh, warmer pools can incubate Protozoa and viruses. So, this is what they actually told me is
that one of the key reasons they want to cool their water to 85 because they want to keep it
safe for their, um, surfers.
• Um, the other thing I did miss was that surfers acknowledge that by riding on the artificial
waves, they really exerting a lot more energy than regular wave because it goes on for a much
longer extended period of time. So that raises the chance, if you're doing, during the day in a
hot water pool for heat stroke.
• Algae buildup significantly increases in hot water, with hot water and hot weather. So, chlorine
requirement increase the pool, to make it safe away from chlorine away from this protozoas and
everything, um, it just increases to the point where it may be unusable for swimmers in it. The
Coral Mountain base, uh, people, developers base their chlorine needs on Lemoore Surf Park,
and I will in the Draft Environmental Impact Report, and I'll go over that in the next page real
quick.
When I left the house, my pool was 95 degrees today. So that's really hot. Um, on the next page
[indicating PowerPoint]. Uh, very quickly, the CVWD water assessment said that they would need 39
million gallons yearly to replenish the evaporation from the surf pool. Um, unfortunately that was not
based on any knowledge of surf pools, we didn't have that kind of data. So they did it based on a
standard factor of 1.2 for moving waters and pan evaporation numbers 2005 when we only had 99 days
over 100. So that's that the calculations are based on. However, luckily, the World Surf League, which
purchased Kelly Slater wave technology, that's going to make up our pool here in La Quinta, wrote that
on very hot days, the Lemoore Surf Ranch, the pool lost 250,000 gallons a day. Okay now, they had — I
went through and calculated how many days over 100 they had — they had 27 days over 100 degrees in
2020, with the hottest temperature last year of only 107. We had 143 days over 100. Um, so I used that
as a number from basing my calculations for evaporation. So, 250,000 gallons times 143 days equals 36
million gallons lost to evaporation in 143 days. If you look at line number one, CVWD has in their water
assessment they only need to replenish 39 million for a whole year. I calculated based on the Kelly
Ranch evaporation, 100-uh, 36 million gallons only in 143 days. That leaves us with — oh we also had 56
days over 110 degrees. What does that now mean for the 250,000 gallons? How much of a factor is it
above that for more evaporation right? We don't know that. uh, could it be 300,000 dollars on the days
over — 300,000 gallons on the days over um, 110 degrees? Uh, what about the rest of the 222 days of
the year where we have evaporation due to wind? Due to heat? We had 51 days last year over 90.
That's another large amount of, of days over it. You'll quickly see that the 39 million gallons calculation
by CVWD is wrong. I hate to say that, but.
Uh, again, so golf courses versus surf pools. I gave you those numbers so that you see, you stop
believing the developer that a surf basin will use 25 percent of what a golf course will do. These
evaporation figures show that we don't even know how much more it's going to be. Um, and golf
courses use recycled and grey water; surf pools can't. Uh, last year local golf course decrease their water
usage by 17 percent over the summer without a law being in place to say please reduce it. They're able
to do that. You know, you can't — surf park can't decrease their water or they close. Golf courses have
new designs that are environmentally friendly. I'm not advocating another golf course here. I want to
have a family -friendly development here. You could have rock wall climbing, bike trails, hiking trails,
community pools, miniature golf, playgrounds, tennis, pickleball, all that, I think are, in lines of what you
want for residential community. So um, and finally, I just wanted to show you a picture of the
conception. Uh, how can they say no noise impact? Look where that pool is in relation to Coral
Mountain. So, thank you very much.
City Council Meeting 8-03-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/81158bc2-9a14-47c8-9a20-7c4e88cea5e6
Located at: 7:46 — 9:15
Speaker: Kelly Welton
Welton: Good afternoon my name is Kelly Welton, I live in Trilogy, and I just wanted to raise some
concerns that we weren't really satisfied by the answers given to us by Merriwether and Garrett Simon
on, I believe the first call that we had. One question asked was - what about the noise factor, if they are
going to be in operation until 10 o'clock in the evening? If we have noise concerns at 10 o'clock in the
evening, who can we call? And his answer was "oh the hotel staff will take care of that." So, I'm not
exactly sure what that meant or how that will happen, but I would like to then ask — if we don't get any
satisfactory problem solving by the hotel staff for noise 5 pm, when no one is here, who do we call?
What is the plan B? Will La Quinta Police come? Will Riverside County sheriff come?
And my second one kind of tags on Alenas picture, and I didn't know I could send a PowerPoint, but I'II
pass this around so you can see it, but the proposed wave pool that they have in proportion to.
Mayor: You can start over here, actually with City Clerk.
Welton: If you look at the size of that Wave pool, in proportion to the size of the about 8 blocks of
Trilogy, you can't tell me that whatever contraption they're going to use to make a wave in that pool,
won't be heard. That's a huge pool. It's 8 blocks of Trilogy. Thank you.
City Council Meeting 8-03-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/81158bc2-9a14-47c8-9a20-7c4e88cea5e6
Located at: 9:20 — 14:06
Speaker: Wendy Clarke
Hi Mayor Evans, Council members, Penya Fitzpatrick, Randy Sanchez and staff. I really appreciate your
service. Good to see everybody. My name is Wendy Clarke, and my Family has lived in the Valley here
for 34 years.; 16 years ago, I moved to Trilogy.
And I am here to speak today about the request for Coral Mountain to rezone land adjacent to many of
the communities surrounding where I live. Currently, we all know the land provides little revenue for the
City, basically due to the Thermal Redevelopment Project. And I trust maybe City Council would have
negotiated something different years ago, but it is what it is. And if it's rezoned, the City realizes
Transient Occupancy Taxes, what happens to the residents? Our quality of life is negatively and
permanently impacted.
I had an opportunity to hear John Gamlin on a Zoom call recently and he shared that he's managed
some south La Quinta luxury properties, uh, in residential neighborhoods. This project is in no way like
any of those neighborhoods. With a huge amounts of surf waves, broadcast system, music, short term
rentals.
Beyond the 4 annual events that they propose, there is additional temporary -use permits I believe it can
be requested. Kelly Slater has made public that he supports the artificial surf waves for Olympic training
and competition. LA is hosting the 2028 Olympics. What will one special event look like? Chaos for
1,000s of residents. Our neighborhoods are not transient, and they are not a tourist destination. We
intentionally purchased homes away from the commercial corridor. And to relax after a busy workday,
some of us have retired, we like to exercise, enjoy nature, socialize with our neighbors. It's funny when I
drive down Madison on the way home from errands, there is a calm that comes over me. Um, this
paradise deserves to be protected.
Today, environmentally mindful we face a life-threatening drought, and I won't go into all the details
because we've talked about this a lot, but lakes are at historic lows. California supplies 80% of the
world's almonds, and trees aren't being planted because there is no water. We have been asked to
reduce water by 15%. Any governing body approving any project that uses a significant amount of
water, is irresponsible.
This Surf Wave will deplete water from our aquifer supplied by the Colorado River. NPR reports, "The
Colorado River is tapped out. Extremely dry conditions like the region is experiencing in 2021, make
clear that the Colorado River is unable to meet all the demands the Western U.S. have placed on it. It's
up to its biggest users to decide who has to rely on it less."
In closing, what are our mutual responsibilities?
• Everyone reduces water consumption.
• CVWD transitions remaining golf courses to grey water and denies all nonessential, requests
requiring water sourced from the Colorado River.
• The city requires studies that evaluate local evaporation rates, the actual noise of the site, and
traffic studies that are post pandemic.
• The City observes its General Plan 2035 "Livable community" that speaks to "long- term quality
of life of its residents."
It is great to think big; change is great and inevitable. Having lived in La Quinta is wonderful. It's real
exciting to see young people moving here. Meriwether has spent millions. They've aligning with Kelly
Slater and Michael Schwab. Their project is beyond unreasonable. Please honor south La Quinta's
established communities and reject The Wave, rezoning request. It will have permanent, quality -of -life
consequences for many 1000's of residents.
Thank you.
City Council Meeting 8-03-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/81158bc2-9a14-47c8-9a20-7c4e88cea5e6
Located at: 14:15 — 23:49
Speaker: Diane Rebryna and Anast Demitt
Good afternoon Honorable Mayor and City Council Members, staff, and fellow attendees.
Thank you for allowing me to speak today regarding Coral Mountain Resort, which I will refer to going
forward as "the Project". My name is Diane Rebryna, and my husband Anast Demitt and I are truly
blessed to have our winter home here in Trilogy in La Quinta. Please know that we truly love this city,
particularly its tranquil and beautiful southeast corner, which is why we chose to settle there.
At the outset, I wish to say that we've spent an enormous amount of time reviewing the Draft
Environmental Impact Report - which at over 1,500 pages was very challenging and intimidating to the
average reader, to say the least. There were so many topics, with this study and that "study" and these
and those "mitigating factors" that were covered. Some of the DEIR was formulated with conjectures;
there were statements like "are not anticipated to", "would not significantly impact", and I felt
overwhelmed as I tried to extrapolate all of the potential impacts of this Project on life as we know it in
South La Quinta.
To help me understand the DEIR, I also reviewed the 2021 CEQA guidelines — this is a reference
document that's based on the CA Environmental Quality Act to which is used to develop Environmental
Impact Reports. And it was here that I had my "eureka" moment! This document, as part of the DEIR
checklist speaks to a topic called "Mandatory Findings of Significance" where the following is asked:
"Does the Project have environmental effects which will cause substantial adverse effects on human
beings, either directly or indirectly"?
That is when it hit me, yes we are the human beings that will be impacted. So this Project, as a result of
the request for rezoning to allow for it, will have many known and potentially unknown environmental
domino type effects on the "human beings" - those being us - the residents of the communities nearby.
1. First of all, the Developer has asked for Sub -Phase Development based on "market and
consumer demand". I am overwhelmed as I think of how plans for our lives will be totally
predicated on the fact that the waves and phases of construction noise and traffic could go on
for years and years. We may never see the completion of this Project in our time here.
2. As a result of the rezoning change, Special Events asked for by the Developer could be permitted
through the use of TUPs. What's to prevent the 4 that are being asked for from turning into 8, or
more for the City? City noise ordinances can be altered to accommodate these special events.
There could definitely be access and egress challenges to most of the surrounding communities,
and this could impact our safety and wellbeing, should there be traffic tie ups both during as
well as before and after Special Events to allow for prep and take down days.
3. And finally, I am totally perplexed as to how this Project with its enormous water usage with 18
million gallons of water to fill it from our aquifers would even be considered in our desert
environment with its high temperatures, high evaporation rate and winds, and especially during
a mega -drought. I know of no other "recreational activity' which would even be considered if
there was an equivalent current and potential future threat to the environment as a
consequence. There is a global movement under way to conserve water, with good reason, and
we must think of our children and grandchildren.
Thank you very much.
Mayor: And Anast Demitt.
Demitt: Mayor Evans, Mayor Pro Tem Radi, Council members, City staff, fellow La Quintans. My name is
Anast Demitt and I am a semi -retired forensic structural engineer. My 45 years of engineering training
has allowed me to learn how to read technical documents. That Draft EIR that I read was one of the
worst technical documents I've ever read. It is not to the point, it is full of conjecture, tends to cloud the
issues, and what's very disappointing - everything has little to no impact. there's no cumulative analysis
as to what happens. One of the areas that concerns me on this proposed element is the section of the
DEIR related to traffic.
1. Once the Tourist Commercial aspect of Coral Mountain Resort is "up and running" there will
traffic changes that will significantly impact the day to day lives of many La Quintans and affect
their lives as we know them today. The traffic study included in the DEIR is flawed, because in
my opinion, it was conducted during COVID when many seasonal residents chose not to return
to the Valley. The base traffic volumes used in the analysis are therefore an underestimation of
the actual number of vehicle trips on those roads. The study shows that levels of service in some
of the affected areas will be reduced to level F. Now in engineer speak — A is good level of
service and F is absolutely the worst. As a consequence, that means there will be long delays at
intersections and increased commute times regulating in more GHG emissions, and longer
delays in getting to our homes. The Report recommends that changes be implemented to
reduce the impacts on the level of service. The Report recommends widening the roads, adding
signalization to 8 intersections. When I asked the developer how this is - who is going to bare
this cost, their comment is that they are going to pay "their proportional share". What is their
proportionate share? I would submit the citizens of La Quinta will be paying a significant portion
of these costs. This does not seem to be a fair trade off as we the citizens are subsidizing a
private development that we will not see any benefit from.
2. I would also like to talk about the lighting - The Developer proposes to use seventeen 80 foot tall
light towers with lighting with variances in parking lots and visitor areas. The effect of this
lighting is another unknown that cannot be quantified. The developer had a light study done,
and that is low and behold from the company that sells them lights. Not much of a conflict in my
opinion. The proposed development will be similar to what I see when I drive by the Tennis
Gardens in Indian Wells. Furthermore, from the proposed project site, the illumination from a
public park in Coachella is visible. So even though the light may not directly reflect off the water
surface, into the adjacent communities, the glow above the park will certainly be visible. I think
we can kiss our dark La Quinta skies good-bye, if that is the case.
3. And finally, I want to talk about the Short Term Vacation Rentals [STVR]. Potentially we can have
700, over 700 STVRs on that site. The DEIR asks that every room in the hotel, casitas, and every
house will be approved as a STVR. The proposed $2.5M dollar homes will have multiple
bedrooms with multiple people sharing a home. Add in a full hotel for one of the Special Events
or even for Coachella or for Stagecoach, and this development rapidly becomes nothing more
than a large scale B&B with a rotating door. That could mean literally 5 to 6 thousand additional
transient visitors in and out of the project each day.
Is this the type of intrusive commercial development that we want inserted among the established
communities of the Quarry, Trilogy, PGA West, Andalusia, Santerra, just to name a few.
All for the sake of the TOTs that will be collected on the STVRs? What happened to the highly touted
goals for quality of life in the La Quinta 2035 Plan? Is this development and all that it brings along with it
really worth the adverse impact it creates on the residents and citizens of South La Quinta?
I'm respectfully asking you today to please "stick to the plan", that is, the 2035 Plan - particularly the
component that speaks to the "livable community" which addresses the "long- term quality of life for its
residents."
This project is a square peg in a round hole. I encourage you to do as we did and please read the entire
1,500 plus page DEIR, it cures insomnia. You will see that there is not enough certainty from the
information presented to allow for rezoning with confidence, and to ensure that there will not be long
term life impacting consequences for we, those residents -'those little human beings' - who live nearby.
Thank you for allowing us to provide our perspective today. Please say no to the rezoning of this parcel
to Tourist Commercial.
City Council Meeting 8-03-2021
Public Comment on Matters Not on the Agenda.
Available at: https://laquinta.l2milesout.com/video/meeting/81158bc2-9a14-47c8-9a20-7c4e88cea5e6
Located at: 27:35 — 38:45
Speaker: Kathy Weiss
Honorable Mayor Evans, Members of the Council, and staff. Thank you for the opportunity to speak on
the Coral Mountain project. My name is Kathy Weiss, and I am a homeowner and resident at the Quarry.
#1. Location
Many of you might think The Quarry won't be impacted because the DIR said there was nothing to the
West of the project. For the record, The Quarry is to the west of the proposed Wave Basin at Coral
Mountain.
#2. Noise
Everyone who lives near Coral Mountain knows that sound reverberates throughout this area. I can hear
the murmur of simple conversations between the hikers in Coral Mountain Park, and at Lake Cahuilla
Camper Park. From my home at The Quarry, I can hear the music, the bass beat, and the roar of the
crowds during Coachella and StageCoach. In fact, from inside my home, I can tell you if the vehicle
rumbling down west of 58th & Madison has a gasoline or diesel engine. Just like my neighbors, I hear
the sounds of coyotes and hoot owls every evening. I ask any sound engineer, that has NOT been hired
by the Developer, to demonstrate sound trajectory to La Quinta Mayor & City Council members. The
finding of "no significant" noise impact in the DIR illustrates what a one-sided publication this is.
#3 Side effects of Tourist/Commercial Zoning
Louder noise allowances, longer business hours, overnight stays, special events, bigger and taller
buildings, and public safety commercial lighting are permitted, and sometimes required under Tourist
Commercial zoning. Here is just one example - the Wave Basin requires an audible (not visual) 30 -second
alarm if there is an emergency, followed by another 30 -second audible alarm to signal the emergency
has ended. California State mandated Alarm can be as loud as it needs to be in order to be heard over
"The Tub and The Train," by the way the tub and the train is a nickname given to the Wave Basin by all
of Kelly Slater's peers, the screaming and cheering crowds, the crashing of waves onto concrete flooring,
and the jet skis zipping up and down the Basin. As the Wave Basin is geared for the Novice Surfer
Tourist, the alarms could be going off several times a day. On, off, on, off. If I had wanted to live in a
noisy, tourist commercial neighborhood, I certainly wouldn't have built a home at The Quarry.
#4 STVR's
As La Quinta City Council and its residents know, STVR's are a big nuisance, not only here in La Quinta,
but elsewhere in Coachella Valley, and wherever people want to vacation. The vast majority of people
who propose short term rentals do not live in this town. Most are out of towners or Commercial
investors.
If City Council choses 750 more STVRs over our tranquil South La Quinta Community, you are voting
against your own community. Are we a community or a commodity to you? To remind everyone, the
Development Agreement states: "Short term vacation rentals will be an allowable use in all planning
areas within the Project ". In "Developer Speak"- That means 100% of the 600 "Dwelling Units" — those
are the Developer's words not mine - built on this property can be STVR's. In essence an overnight Hotel
Room with a shared kitchen. The developer states "Dwelling Unit" prices will start at $2.5 million and go
to $5 million. That tells me the Dwelling Units are going to be McMansions with 3 to 10 bedrooms each.
Add the massive 150 room key hotel and we have "Surf City Party -land" with a potential overnight
population of 4- to 6,000 lodgers at our doorsteps coming and going on a daily basis. Simply put, 750
STVR dwellings and 4,000 to 500 lodgers will be throbbing in the middle of Andalusia, Trilogy, The
Quarry, Santerra, Puerta Azul and PGA West (which does have a section on 58th), plus the other
resident communities lining 58th Street West of Madison. This project goes against every single zoning
statement in the La Quinta General Plan for 2035.
The developer, when asked about the noise and light pollution, has been very careful to always reply,
"we don't want the noise to impact our residents." From reading the DIR and the DA, this project is not
catering to have many residents. I want to emphasize the developer plans to build the Wave Basin, Hotel
and Casitas first. After those are completed in 2 to 5 years down the road, then will developer will start
to construct dwelling units on the sold lots. A "Dwelling Unit "- per the developer's own words again, not
mine, in the DIR, has an Owner, but not necessarily a Resident. A Rental has an "Owner", a Home has a
"Residence." There is a big difference between an owner and resident. All the communities I mentioned
to you are residential communities. Now, keep in mind, The "Dwelling Unit" owners that chose to buy
and build at Coral Mountain Wave Park, plus the tourists booking a stay, do so knowing that the "Tub
and Train", the announcer, the jet skis, the crowds, the entertainment venues, etc. will be going non-
stop 15 hours a day, that's why they want to be there. And there will be all those 4- to 5,000's of
tourist/lodgers milling around outside everywhere. The Wave Park lodgers can leave and go back home
when tired of the noise, the crowds, and the commotion. We, the neighboring homeowners, cannot. We
will be stuck in a nightmare that never ends.
The surrounding neighborhood property owners and I bought and/or built homes in South La Quinta
because we wanted the peaceful, low-key residential atmosphere currently there. Before I chose the
location of where I live in La Quinta, I asked my realtor what the West Andalusia parcel was zoned for.
The realtor told me "Low -Density Residential with 18 -hole golf course. It is planned to be Andalusia's
higher -end homes with their own course." I did more due diligence by visiting the Andalusia Sales site,
looked at their Master Plan 3-D model and confirmed the zoning with the Developer's representative.
Finally, after studying the LQ City zoning map, I felt confident enough to purchase my lot and commence
building a home at The Quarry.
If any of us wanted to live next door to a "Surf City Mega -Event Complex" we would have done so, we
didn't. The majority of the homeowners in South La Quinta moved here by choice; meaning that we
were not born and raised here. Permitting this Zone change is slap in the face to every single person that
chose to live, bought, and build in South La Quinta. LQ City Council would be showing us that we, your
South La Quinta residents, just don't matter. I always thought City Governments were designed to
protect its residents and their properties, and make its residents happy to be living there. You can call
me naive, because I never thought our local government would cater to an out of state rookie -
developer, that has only been in business for 8 years. For the record - this developer has already pulled
the plug on one La Quinta based, City owned development: SilverRock. La Quinta Government should
stand by their thousands of residents in south La Quinta. Not the Out -of -Town rookie developer that has
a dubious history with La Quinta.
#5. Developer Agreement
For the record, the developer's proposed time frame, as written in the DA, is 40 years. That is 40. F. O. R.
T. Y. I quote this account from the Desert Sun — uh, this 6 -year-old account from the Desert Sun dated
October 21, 2015, regarding the SilverRock project. "Robert Green Jr., of Robert Green Co., and John
Gamlin, of Sofia Investments, will keep SilverRock moving forward after Meriwether Co. withdrew to
pursue other interests, city Economist McMillen said." For the record, this is the same John Gamlin we
heard speak on Meriwether's behalf at the last open City Council Meeting. In other words, Meriwether,
the same developer that dropped Silver Rock to pursue "Other interests", wants a 40- year time frame in
the Development Agreement. That is alarming. What if Meriwether decides to drop this one too? Yes, I
am well aware that Developers, City and Public entities, Planning Business, Consultants, Realtors, etc.
have interacted, and networked, and fraternized with each other on a daily basis for many, many, many
years. In fact, most of LQ City Council members are involved in these types of pursuits. When it comes to
assembling DIRs for City Review, it is definitely a stacked deck in favor of the Developer. The "no
significant impact" stated over and over in the DIR clearly illustrated this bias. The repetitive "No
significant effect" would be laughable if the thousand pages plus DIR wasn't so blatant in its lack of
transparency, readability, and comprehension.
Having personally met and known many Developers, a good, responsible, and successful Developer
looks to invest and "develop" where there is a real need, the timing is right, and there is an
overwhelming neighborhood desire for the "Development" to happen. That is certainly not the case
here. All which makes me ask why the Developer and their financial backers bought a parcel that did not
have the desired Zoning already in place for their Project?
Who, in LQ government, gave them the "greenlight"? Why would La Quinta government even think this
is "in character" of the existing neighborhood zoning?
In summation, I beg of you, Mayor Evans, and La Quinta City Council Members to vote "no" on granting
the Property Commercial/Tourist zoning. A zone change permit would be absolute disaster in the
making for the many thousands of residents close to this proposed Tourist/Commercial Mega -
development. Sincerely, Kathy Weiss.
Wednesday, August 4, 2021 at 13:01:12 Pacific Daylight Time
Subject: Coral Mountain Resort
Date: Wednesday, August 4, 2021 at 12:07:53 PM Pacific Daylight Time
From: Jeffrey Lisa
To: consultingplanner@laquintaca.gov
Hi Nicole,
My husband and I moved into The Citrus as permanent (year round) residents in May 2021. As we were considering
moving to La Quinta one of my biggest concerns is the availability of water for the future. We moved here from the
Bay Area and have gone through a few years of severe drought. It is very scary to have to limit your use of water and
a sobering reminder of how precious a resource water is. We must use it wisely!
I recently learned of Coral Mountain Resort and I'm shocked that this would even be a consideration here. California
is in a drought now and we need to conserve water.
Please don't build a water park!
I personally would like to see Silver Rock development finished and eliminate the water features in the landscape.
La Quinta has beautiful desert landscape. Let's emphasize that.
We must change our attitude toward our natural resources or we won't have a planet to live on.
Thank you.
Lisa Jeffrey
79375 Mandarina
La Quinta
925-872-7796
Page 1 of 1
Wednesday, August 4, 2021 at 12:51:31 Pacific Daylight Time
Subject: Wave Park
Date: Wednesday, August 4, 2021 at 6:50:12 AM Pacific Daylight Time
From: Rosette
To: Consulting Planner
Hello
I am informing you once again to my opposition to the Wave Park. The dire water drought is a major priority.
We will run out of water for our agriculture as well as our personal use.
The other problem is the impact on our tranquility at Trilogy. That would be traffic congestion as well as noise
pollution.
Do not all allow this Water Park to open.
Sincerely
Rosette Kivel
61345 Fire Barrel Dr
La Quinta, Ca 92253
Sent from my iPhone
Page 1 of 1
Wednesday, August 4, 2021 at 12:58:29 Pacific Daylight Time
Subject: Coral Mountain wave pool - water concern
Date: Wednesday, August 4, 2021 at 11:49:00 AM Pacific Daylight Time
From: Natalie Maupin
To: consultingplanner@laquintaca.gov
CC: julia.wick@latimes.com
Hello,
I am a resident of Palm Desert and have been watching the news publications about the wave pool tentatively
approved for the Coral Mountain area in La Quinta. I find it ironic that the LA Times published an article, "As drought
worsens, regulators impose unprecedented water restrictions on California farms" while there are multiple
recreational water parks under planning and/or construction in the Coachella Valley.
I don't understand the logic in using hundreds of thousands of gallons of our precious table water in a wave pool. This
project should be placed on an indefinite hold until water levels are back to where we are not "robbing Peter to pay
Paul". Personally I think our farmers have a right to this water before we build a wave pool.
I can find multiple articles about farmers who have basically let their farms go because they can't maintain the crops
with the amount of water they are allocated. Not all of these farms are located in the Coachella Valley, but we are
home to a variety of farms that provide food and jobs to our residents. Can you explain and justify how a recreational
venue warrants water over our farmers?
For reference, here is the article from the LA Times.
https://apple.news/AN29YMVO6R8mVx1 nHigsyOA
Sincerely,
Natalie Maupin
Palm Desert, Ca 92211
760-668-6690
Address can be provided however I do not want it published.
Page 1 of 1
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La Quinta surf park
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L E <Iizervin05@gmail.com>
Thu 8/5/2021 9:44 AM
To: Consulting Planner
** 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. **
Dear La Quinta Planning Commision,
I am writing to you as a citizen of La Quinta. I moved to south La Quinta after extensive
research seeking a crime free and quiet neighborhood.
The location for the misguided "surf park" is presently zoned for low-mid density housing,
not a tourist and AIRBNB destination that would be NO benefit for the local community.
It is inconceivable that this "surf park" is being considered with the drought conditions. We
have been asked to limit our water consumption and every day on the news this is an
important topic. In addition we often get alerts from IID to reduce our electric consumption.
Please do not allow this to happen. It is up to you and would be very disappointed if this
were to come to fruition.
I was on a ZOOM call with the developers recently who addressed the EIR reports that
were so biased and incomplete. The developer was rude and not very interested in
listening to the valid concerns of local experts.
Please do not change the zoning for this property. I read on some of the city council bios
that they were here for the citizens of La Quinta so here is a chance to prove it.
I appreciate your time,
Best,
Liz Ervin
Liz Ervin
949. 280-7695 mobile
lizervin05@gmail.com
1 of 1 8/5/21, 10:20 AM
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August 5, 2021
Ms. Nicole Sauviat Criste
Consulting Planner,
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
BY EMAIL: ConsultingPlanner@laquintaca.gov
SUBJECT LINE: Coral Mountain Resort DEIR
RE: Comments re: DRAFT EIR for Coral Mountain Resort
Applicant Meriwether Developments request for zoning change in South La Quinta from
"Low Density Residential w/golf course"(LDRw/G) to "Tourist Commercial" (T/C)
Ms. Sauviat Criste,
I am writing today as a concerned Trilogy resident to respond to the Draft Environmental
Report as well as to voice my opposition to the rezoning application above which would allow
for the Coral Mountain Resort development ( "the Project") in South La Quinta.
PREAMBLE:
The key to the color coding within this response to the DEIR is here:
1. My comments, as the writer, are in BLACK
2. The reader will see comments in RED: These are supportive documentation for that section
and are excerpts from CA Environmental Quality Legislation (w/ writer's emboldening/
underlining). This legislation drives the CEQA Guidelines which in turn provide the framework
for the Draft Environmental Impact Report.
PUBLIC RESOURCES CODE - Public Resources Code
DIVISION 13. ENVIRONMENTAL QUALITY [21000 - 21189.70.10] ( Division 13 added by
Stats. 1970, Ch. 1433. )
CHAPTER 1. Policy [21000 - 21006] ( Chapter 1 added by Stats. 1970, Ch. 1433. )
3. The reader will see comments in PURPLE: These are excerpts from the 2021 CEQA
Guidelines. https://www.califaep.org/docs CEQA_Handbook_2021.pdf
4. The reader will see comments in BLUE: These are excerpts from the 2035 La Quinta
General Plan ("the Plan") (w/ writer's emboldening/underlining)...
https://www.laquintaca.gov/business/design-and-development/planning-division/2035-Ia-
quinta-general-plan
which is the "...plan ...crafted as the guiding policy document for the City per the vision
expressed by its citizens and established by the City Council." I-1...The General Plan
includes ..."Goals, polices, and programs (that) are all supported by factual data, community
opinion, background information, and detailed maps. Together, these constituent parts paint a
picture of the community's future development"
Page 2 of 11
My comments with respect to the DEIR for the Project will be laid out in 3 parts:
A. Those regarding the DRAFT Environmental Impact Report Document
B. Those regarding the Project relevant to the DEIR, and
C. Conclusion
A. My comments regarding the Draft Environmental Impact Report Document for
Coral Mountain Resort - issued June 22, 2021:
Section 21003 of the Legislation addresses the preparation of Environmental Impact
Reports.
The Legislature finds and declares that it is a policy of the state that...
...(b) Documents prepared pursuant to this division be organized and written in a manner
that will be meaningful and useful to decision makers and to the public.
...(c) Environmental impact reports omit unnecessary descriptions of projects and
emphasize feasible mitigation measures and feasible alternatives to projects.
My concerns with the DEIR document itself are as follow:
I, and many other concerned residents, are of the opinion that this document was not
organized and written in a manner that was meaningful and useful to the public. Whether it will
be useful to the decision makers remains to be seen.
1. In short, the document was not succinct. The sections in the DEIR with respect to the
"technical studies" contained complex language that would have been better placed in
appendices, to allow for "a flow" in the main document and encourage a "rapid
understanding" of the DEIR by the average reader as required by the CEQA guidelines.
2. I have strong objections to the multiple vague statements that appear throughout the
DEIR ( regarding identified factors)..." are not anticipated to", "would not significantly
impact"," would not substantially change", "would not be significant" , "minimally
impacted", "would be imperceptible", "are not fully compliant", etc. These are
SUBJECTIVE comments that are not scientific and neutral. As a reader, comments like
this do not inspire my confidence in the findings.
3. I also have concerns with "elaborate and ornate descriptive language" used in what
should be presented as a neutral "for information" document. Often times such language
was used to describe the Project.
For example, on page 7-57 of the DEIR, the following statement is made: "Develop a high-
quality private wave basin (The Wave) that provides unique recreational opportunities
Page 3 of 11
for future residents of the project, and that attracts resort guests and creates a
landmark facility that will enhance the City's reputation as the "Gem of the Desert".
Only PLAIN SIMPLE LANGUAGE should be allowed, regardless of the context. Language
like this belongs in a promotional brochure for the Project - not in a DEIR. I compared other
DEIRs for other Projects in the Coachella Valleyand and could n of see examples of this
type of language in the others.
4. Many of the tables were redundant and confusing in their layout; they should have
been placed in the appendices for easy reference, and not allowed to clutter the document.
5. At 1500 plus pages including appendices, the document was too long as per the CEQA
guidelines ( 300 pages is recommended for a complex project), and filled with redundant
and repetitive sections that were repeatedly "cut and pasted" throughout the entire
document. In fact, entire sections were literally repeated several times throughout the
document.
6. Then document did not include an organized and detailed Table of Contents to allow for
easy reference by the reader and some of the numbering on the pages was not in
sequence. There were too many sections entitled "Conclusion(s)" throughout the
document, contributing to further confusion for the average reader. There were page
numbering errors in some sections; some intended citations were not cited.
would like it on record that I, and others, communicated the above concerns to the
Consulting Planner, and her response on July 13, 2021 was the following:
"Although the CEQA Guidelines suggest page limits, the complexity of this project requires that it be analyzed
thoroughly, resulting in a longer document. The language in the document, although technical, is not unduly
scientific or complex. CEQA documents usually are highly detailed and cover many variables. Likewise, the various
environmental impact areas may have some redundancy of analysis, all in an effort to make the document as
complete as possible. The City has completed the EIR to address all currently known aspects of the project, and to
provide decision makers and the public with a comprehensive analysis of the potential direct, indirect and
cumulative impacts associated with its implementation. The City will not be retracting the document or reissuing it."
Why this DEIR as presented is of concern:
This Project is very complex and its completion would be impactful to the residents around it
on many levels.
There are aged residents who reside near this proposed Project in retirement communities.
Many can no longer can concentrate to the extent that they once could and are easily
overwhelmed. Some said they were intimidated by the DEIR and wondered how to respond
when they could not understand it.
Could a document like this discourage the average reader to persevere and provide a public
response that is meaningful, organized and to the point ? ... again, that remains to be seen. It
will be interesting for the city officials to compare the number and nature of responses to the
DEIR to those regarding the Notice of Preparation.
Page 4 of 11
B. My comments and concerns regarding the Project relative to its presentation in
the DEIR
In order to fully understand the intent and ramifications of a DEIR, I went to the Legislation and
the CEQA 2021 Guidelines, as referred to above.
sought the definition of the "Environment"... which was defined as follows in 15360 of the
CEQA guidelines:
15360. ENVIRONMENT (NOTE: emboldening is writer's)
"Environment" means the physical conditions which exist within the area which will be affected by a proposed
project including land, air, water, minerals, flora, fauna, ambient noise, and objects of historical or aesthetic
significance. The area involved shall be the area in which significant effects would occur either directly or
indirectly as a result of the project. The "environment" includes both natural and man-made conditions.
Note: Authority cited: Section 21083, Public Resources Code; Reference: Section 21060.5, Public Resources Code.
(NOTE: emboldening is writer's)
I find it interesting that the "environment" includes reference to both natural and man-made
conditions. This definition of ENVIRONMENT will form the basis for my comments going
forward.
The legislative background for the following section of my comments provided as an
Overview, is important:
The Legislature finds and declares as follows in Environmental Quality Section 21000:
(a) The maintenance of a quality environment for the people of this state now and in the future
is a matter of statewide concern.
...(b) It is necessary to provide a high-quality environment that at all times is healthful and
pleasing to the senses and intellect of man
...d) The capacity of the environment is limited, and it is the intent of the Legislature that the
government of the state take immediate steps to identify any critical thresholds for the
health and safety of the people of the state and take all coordinated actions necessary to
prevent such thresholds being reached
The key words in the legislation are "high" and "quality" environment, and "threshold for the
health and safety" of the people.
These statements are similar in concept to the 2035 La Quinta General Plan.
"The long term Quality of Life" for La Quinta residents is emphasized repeatedly, particularly in
the Livable Community Element and Land Use Element of the 2035 La Quinta General
Plan.
Also, I refer the reader specifically to the following goals and policies that are laid out in the
Plan:
Page 5of11
GOAL SC -1:
A community that provides the best possible quality of life for all its residents.
GOAL LU -3 (11-26)
Safe and identifiable neighborhoods that provide a sense of place.
Policy LU -3.1...11-26 Encourage the preservation of neighborhood character and assure
a consistent and compatible land use pattern.
Program LU -3.1.b: Apply the City's discretionary powers and site development review
process consistently to assure that subdivision and development plans are
compatible with existing residential areas.
GOAL LU -4... (11-26)
Maintenance and protection of existing neighborhoods.
Policy LU -4.1... (11-26) Encourage compatible development adjacent to existing
neighborhoods and infrastructure.
How do I see this Project?
Rezoning from Low Density Residential w/ golf ("LDR w/G") to Tourist Commercial ("TC") is
NOT consistent with the City of La Quinta's own plan and will lead to a "domino effect" that will
negatively and forever impact the existing surrounding residential communities and their
residents.
TC zoning now will open the door to future TC development in SE La Quinta. An entire
quadrant of the City could change forever. Would the possibility of collection of Transient
Occupancy Taxes supersede the City's responsibility to ensure that "subdivision and
development plans are compatible with the existing residential areas, as per the 2035
Plan?
The salient points follow:
1. The Developers, as stated in the DEIR, are asking for Sub Phase Development based on
"consumer and market demand". This in itself is one of the most disconcerting aspects of
this whole proposal.
I am overwhelmed as I think of how plans for our lives will be totally predicated on the
fact that the "waves and phases" of construction noise and traffic could go on for years
and years. Residents of the surrounding residential communities may never see the
completion of this Project in our time here. How does this ensure that we the
residents will continue to enjoy the best possible quality of life - particularly with
the uncertainty with respect to the timing of completion of the Project that we
would be facing ? (GOAL SC -1)
2. Rezoning to TC, as stated in the DEIR, will essentially permit the majority (at 600 with a
minimum of one night's stay) of La Quinta's Short Term Vacation Rentals allowed for to
be concentrated at THIS Resort.
Page 6 of 11
As per the City Ordinance No. 591, "no new STVR permits will be issued until further
notice unless the property is located within TC zones"...https://www.laquintaca.gov/
connect/short-term-vacation-rentals.
The large number of STVRs will allow for a constant revolving door of strangers and we,
the residents nearby, will not know our neighbors as we do now. Further, this resort will
be open 24 hours per day, again with strangers entering and exiting and milling about.
We will think twice about those recreational runs, walks, hikes or bike rides outside of our
gated communities, particularly earlier in the morning or later in the day. Also, it is a
known fact that crime increases in communities where there is a significant transient
population.
What will happen to our "safe and identifiable neighbourhoods that provide a sense
of place"? (see GOAL LU -3 {II -26} above). Will these be "sacrificed" for the sake of
TOTS for the City of La Quinta ?
3. Rezoning from LDRw/G to T/C will allow the Developers to apply for Special Events via
Temporary Use Permits.
PAGE 3-35 of DEIR states the following..."Temporary Use Permits are required by the
City accommodate special, unique or limited duration activities that might otherwise be
outside of the provisions of normal zoning ... are reviewed administratively by the Design
and Development Director and do not require a public hearing"
What's to prevent "the 4" that mentioned in the DEIR from turning into 8, or even more,
per year ? One the rezoning takes place, the residents nearby will never have further say
on this matter.
There will likely be major access and egress challenges to emergency management
vehicles around most of the limited roadways of the surrounding communities during
these Special Events ( think of the La Q Festivals). This could impact our safety and well
being, should there be traffic tie ups both during and before and after Special Events for
the "prep and take down days" that will "bookend" the Special Events themselves . The
community of Trilogy, for example, has ONLY two access and egress roads - Madison
and Monroe. That will never change - whether or not this Project proceeds. Why
compromise the "safety" of the local residents with this Project ? We are entitled to
safe neighborhoods and all that this entails.
If one is to stand back and consider the entire concept of Rezoning in this location, it is
easy to see that this Project makes no sense. This is definitely not in keeping very
important component of the 2035 La Quinta General plan - that which speaks to the
"maintenance and protection of existing neighborhoods" and a "consistent and
compatible land use pattern " (see GOAL LU -3 {II -26} above and policies) (see GOAL LU -4
above{II-26}).
Further, and from a practical perspective, this Project does not and will never benefit the
average La Quinta resident. It is essentially for the rich and it is a private destination for its
residents and guests. An hour of private surfing at Lemoore CA for celebrities runs $10,000.00.
In other words, this recreational outlet is NOT available to and NOT affordable by the average
La Quinta resident, is it?
Page 7 of 11
We, the residents of the communities around it, would be required to absorb the negative
aspects of this destination resort without any of the benefits. If I lived in Anaheim near
Disneyland, at least I could plan an outing there with my kids and grandkids. Not so here.
Coral Mountain Resort does NOT fit - it is an entirely different concept of life - it will not be
residentially focused - which will basically be "injected" amongst the quiet residential
communities that surround it. This Project will be a "square peg in a round hole" !
Additional Legislative background for the following section is important when considering the
CEQA categories of Noise, Aesthetics (lights) and Hydrology:
The Legislature finds and declares as follows in Environmental Quality Sections ...
21000 (b) ...it is necessary to provide a high-quality environment that at all times is
healthful and pleasing to the senses and intellect of man.
21001(b) ...all action necessary to provide the people of this state with clean air and water,
enjoyment of aesthetic, natural, scenic, and historic environmental qualities, and freedom
from excessive noise.
I would like to provide comments on some of the DEIR categories and the related issues that
present as follow:
1. NOISE
Section 21000(b) of the Legislation speaks to "...freedom from excessive noise".
From a practical perspective, we the residents of the surrounding communities are faced
with some very tangible aspects of surrounding aberrant noise, despite what the DEIR says.
In Trilogy, we can hear the music, thumping and beats of the festivals Coachella and
Stagecoach. We can hear the racing cars at Thermal. Coral Mountain Resort will be close
by and what we will hear will be much different from ambient noise of quiet residential
communities.
First of all, many of the DEIR studies, such as the operational noise are based on unknown
local conditions. WE know that there is noise from reverberation at Coral Mountain. What
truly will the operational noise of the Project be ?... with its train and tracks, that is the
wave making apparatus, as well as the noise generated by the greatly increased number of
people in attendance ? What about the noise that will occur during operational hours from 7
AM - 10 PM every day, 365 days per year?
What about increased noise from traffic during the regular operation of the Project?
There will be increased noise when Special Events are held. What would a Special Event
be without music and more people in attendance ? More people equates to more traffic.
Additionally, noise ordinances are always lifted for Special Events. These will definitely
impact the quiet residential communities around the Project.
Page 8 of 11
I should also point out that the construction of a 1/2 mile long concrete wave basin could
take many many months with its use of larger, heavier and ultimately noisier construction
equipment than would be required for Low Density Residential construction. Commercial
development is also included in this category; again, this would be subject to Sub Phase
Development considerations being asked for by the Developer.
Finally, from its own 2035 Plan ..."The City's ongoing efforts to preserve the quality of life for
all its residents, present and future, must include the protection of a quiet noise
environment" (NOISE IV -15)
Regardless of the Developer's "studies", there is NO good reason to allow for this kind of
noise in a quiet residential community. There are too many unknowns. The noise issues
raised would only come about as a result of rezoning.
2. LIGHTS
Sections 21000(b) and 21001(b) of the Legislation speak to "healthful and pleasing to the
senses" and "enjoyment of the aesthetic and scenic qualities"
17 (seventeen) 80 foot light towers on until 10 PM and the nighttime glare from the
commercial development - both as a result of the rezoning - are other unknowns that
cannot be studied at this location. Think of the Indian Wells Tennis Gardens at night; then,
please compare to the Cove in La Quinta.
A T/C zoning change, along with the Developer's request for variances, will also allow for
many other types and heights of lights.
Commercial glare in La Quinta is appropriately saved for Hwy 111 and it muted there due to
lighting ordinances. Again, please compare Hwy 111 and the Cove.
Additionally, there is the matter of light diffusion in the nighttime skies in the presence
of particulate matter. This was not accounted for in the "studies" presented in the DEIR.
We, as residents close by have the beautiful dark desert skies now and we will forever be
deprived of this... and all of the variances being asked for as mitigation measures, including
walls and setbacks, will not change this in any way.
3. HYDROLOGY / WATER
Section 21000(d) of the Legislation states..."The capacity of the environment is limited, and
it is the intent of the Legislature that the government of the state take immediate steps to
identify any critical thresholds for the health and safety of the people of the state and
take all coordinated actions necessary to prevent such thresholds being reached".
Section 21000 (g) of the Legislation states ..."It is the intent of the Legislature that all
agencies of the state government which regulate activities of private individuals,
corporations, and public agencies which are found to affect the quality of the environment,
shall regulate such activities so that major consideration is given to preventing
Page 9 of 11
environmental damage, while providing a decent home and satisfying living environment
for every Californian"
I am totally perplexed as to how this Project with its enormous water usage with 18
million gallons of water to fill it from our aquifers would even be considered in our
desert environment with its high temperatures, evaporation rate and winds, especially
during a mega -drought.
Additionally, there is the issue of the Reasonable Use of Water - in CA law:
From Professor Gray's paper entitled The Reasonable Use Doctrine in California Law and Policy (2015 Brian E.
Gray , UC Hastings College of the Law) https://repository.uchastings.edu/faculty scholarship/987/ ... , comes
the following (note: italics and underlining are writer's)
..."the cardinal principle of California water law is that all water rights, and all uses of water, must be
reasonable"... and that the Doctrine of "reasonable use" is both a policy mandate AND a limitation on water
rights, which applies to
All branches of government,
All levels of government administration of state's water resources, and
Public and private users of the State's waters.
..."because all uses of water must be consistent with this interdependent and variable definition of reasonable
use, the law renders all water rights fragile. A water right that was reasonable when first recognized, and
which may have been exercised reasonably for many years, may become unreasonable as hydrologic
conditions change, as California's economy evolves, as population grows and new demands for water
arise, as ecological needs are better understood, and as the environmental laws that protect the state's
aquatic ecosystems and native species are applied in ways that limit the impoundment and diversion of
water for consumptive uses"
Further, the City of La Quinta lays out the following in the 2035 Plan, where water
conservation is stressed to protect future resources ; to wit, the following...
Conservation of Natural Resources 11-136 ...The conservation of natural resources is a
major component of a livable community...
Imported water from the Colorado River and new replenishment programs implemented
by the CVWD have helped alleviate declines, but both rely on outside sources of water.
In 2010, approximately 300,000 acre-feet of water per year have been allocated from the Colorado
River to the eastern Coachella Valley, primarily for agricultural irrigation. Although continued
importation of water will help to replenish the aquifer. a more resourceful alternative is to reduce the
amount of water pumped by the CVWD, which will have a direct impact on overdraft. Conservation
techniques have already been implemented, and new measures are being developed to lower the
amount of water used by each household and business in the City. 11-137
Water conservation in La Quinta is essential to reduce the overdraft of local groundwater, and
protect future resources. 11-138
Water conservation must include all types of water use - from landscaping to indoor fixtures, and
must include new and existing development. The programs described above provide the foundation
for reducing water demand. This Element can allow the City to expand programs that promote water
conservation now and into the future 11-138
Page 10 of 11
Policy UTL-1.2
The City should encourage the conservation of water. (V-15)
GOAL WR -1: The efficient use and conservation of the City's water resources. (V-16)
Two additional concerns with respect to Hydrology of this Project must be addressed:
1. As an aside, but still on the topic of water usage for a Project like this in the desert, I
would like the reader to compare this Project to another responsibly developed and
sustainable desert surf park in the world that is located in the United Arab Emerites (WADI).
It has a dedicated 124 mile pipeline built to pipe ocean water to the area which is then
cooled to address high water temperature concerns for humans AND the proliferation of
micro-organisms, both which can cause significant human illness and even death.
https://surfparkcentral.com/wadi-adventure-wave-pool-and-surf-park-in-al-ain-uae/
Please see Appendix A attached to this letter which is a copy of my letter dated July 19,
2021 to the Public Health Officer of Riverside County with questions regarding the filtration,
cleaning and disinfecting regimes, including required documentation regarding the
protocols. Please include this letter in the the public comments part of my response to
the DEIR. Hopefully these questions raised in the letter to Dr. Leung will be clearly
addressed in the Final EIR.
and,
2. The Developer repeatedly argues that a golf course uses more water than the wave basin
will use. I say - leave the existing zoning in place and negotiate with a Developer to
construct alternative recreational outlets for the residents who purchase there. Alternatively,
a responsible developer can construct a golf course that observes contemporary
conservation measures such as extensive xeriscaping (as has been accomplished via
conversion in many California golf courses) and recycled water. This is the "wave" of the
future !.
Supportive legislation for 2. above is as follows:
Section 21002 of the Legislation states...
"The Legislature finds and declares that it is the policy of the state that public agencies
should not approve projects as proposed if there are feasible alternatives or feasible
mitigation measures available which would substantially lessen the significant
environmental effects of such projects,
...and that the procedures required by this division are intended to assist public agencies in
systematically identifying both the significant effects of proposed projects and the feasible
alternatives or feasible mitigation measures which will avoid or substantially lessen such
significant effects".
Water is a VITAL component to the health and safety of the people. There is no other
"recreational activity' which would even be considered if there was an equivalent current
and potential future threat to the environment looming in our midst. A development that
uses water in this capacity is an irresponsible development.
Page11 of 11
There is a global movement under way to be respectful of our natural resources and to
conserve water; all with good reason, and we must as the City of La Quinta has stressed in its
own plan, protect future resources as we think of our children, their children and all future
generations.
C. Conclusion:
In closing, I would like to refer to the CEQA Guidelines Section 15064, where it is stated (c) In
determining whether an effect will be adverse or beneficial, the Lead Agency shall consider
the views held by members of the public in all areas affected as expressed in the whole
record before the lead agency, and
CEQA Guidelines Section 15065, Mandatory Findings of Significance, (4) where it is stated
that consideration should be given to "The environmental effects of a project ... ( and
whether they can) cause substantial adverse effects on human beings, either directly or
indirectly"...
We, the residents of the communities nearby, are the "human beings" that will be
impacted by all of the aforementioned effects of the proposed rezoning of this parcel of
land to Tourist Commercial.
With respect to the irresponsible use of water, especially during this unpredictable
MEGA drought, it must be recognized that on a global level all "human beings" are
being impacted.
It is acknowledged that change is necessary and often desirable when considering urban
planning issues. It is also understood that a City that is responsive to its residents needs to
look to additional sources of revenue. Please note that the residents who live by this Parcel of
land are not against development, they are against development that is incongruous and
irresponsible with respect to water usage.
As in all things in life, there must be a balance established - pros and cons must carefully be
weighed. The cons outweigh the pros with respect to this Project.
On the basis of what has been presented in the DEIR, please say NO to the rezoning of this
parcel of land to Tourist Commercial.
Thank you for your consideration.
Respectfully submitted,
Diane Rebryna
60149 Honeysuckle Street,
La Quinta, CA
Attachment; Appendix A
Letter to Dr. Geoffrey Leung, July 19, 2021
Riverside County Public Health Officer
Department of Public Health
July 19, 2021
Dr. Geoffrey Leung M.D.
Riverside County Public Health Officer,
Department of Public Health,
Health Administration
4065 County Circle Drive
Riverside, CA
92503
BY REGISTERED MAIL
Dear Dr. Leung:
RE: Coral Mountain Resort Wave/Surf Basin ( the " Project")
Questions / Concerns re: proposed water treatment for safety
I am writing to you on behalf of a number concerned residents who reside in La Quinta, CA.
There is a proposed Development called Coral Mountain Resort and its "anchor" is a surf wave
basin that is almost 17 acres in size and filled with 18 million gallons of water from the aquifer -
so in other words, potable water.
The DRAFT Environmental Report was recently released for this Project and public comment
in invited until August 6, 2021.
It is here:
https://www.laquintaca.gov/our-city/city-departments/design-and-development/planning-
division/the-wave-at-coral-mountain
We have questions for Riverside County Department of Public regarding the following please:
1. Background Information
Articles abound online regarding the death of a young man who apparently contracted the "brain
eating ameba" also known as Naegleria fowleri from a surfing experience at Waco TX. The
water in this wave basin had apparently been described as a "pathogen soup".
https://www.tracksmag.com.au/news/surfer-dies-from-brain-eating-amoeba-513336
https://raisedwaterresearch.com/bsr-covers-up-evidence-in-surfers-death-lawyer-alleges/
The CDC describes Naegleria fowleri "as a free-living microscopic ameba that can cause a rare
and devastating infection of the brain called primary amebic meningoencephalitis". https://
www.cdc.gov/parasites/naegleria/index.html. The website also goes on to say that this
microorganism usually infects people when contaminated water enters the body through the
nose.
WEB MD says "Naegleria loves very warm water. It can survive in water as hot as 113 degrees
Fahrenheit"... "most cases of N.fowleri disease occur in Southern or Southwestern states..."The
nose is the pathway of the amoeba, so infection occurs most often from diving, water skiing, or
performing water sports in which water is forced into the nose". https://www.webmd.com/brain/
brain -eating -amoeba
Given that this young man's death occurred, ostensibly from an exposure to the parasite while
surfing in an artificial basin, the Developers and operators of surf/wave parks apparently are
"ramping up their efforts" to prevent this from occurring again. Some public health agencies
have also stepped in to ensure that this is the case with enhanced filtration requirements, as
well as the requirements for daily testing with water quality reports, detailing chlorine, pH,
sediment and E. coli levels.
2. The reasons for our letter and for my contacting you are as follow:
A. The desert is HOT (120 days over 100 degrees last year) and the hottest months are
June, July and August. We have been told repeatedly that there are NO plans by the
Developer to cool the surf/wave basin in the summer months.
We have concerns about the increased potential for proliferation of micro-
organisms in the heat of summer in the desert.
The only other desert pool that we know of is in WADI UAE where a 100 plus mile
dedicated pipeline is built to bring desalinated water in that is then cooled onsite for
use at its surf / wave basin.
We have concerns about the health and safety of the people who recreate in this very
hot water.
B. We have reviewed the DRAFT EIR to determine if there is evidence of a detailed cleaning
and disinfection plan in place for the ongoing maintenance of the pool, particularly with
number of hot days that we have here in the desert; there is none.
There is also no information on the presence of a filtration system that swimming pools
require.
From a public safety perspective, we would feel much more reassured about the
operation and maintenance of this surf/wave basin if a detailed maintenance protocol
was made publicly available, given this extraordinarily unusual HOT environment for his
type of recreational outlet.
There is nothing in the DEIR that outlines the required cleaning and maintenance
schedules or whether or not periodic complete pool emptying and refilling is
required.
There seems to be a somewhat perfunctory description of the intended disinfection
regime (4.8.18... Coral Mountain Resort DRAFT EIR) There is a generalized reference
made to Section 65529 (Public Pool Disinfection of Title 22 of the California Code of
Regulations CCR) in that the pool must be "disinfected continuously".
We see evidence of "materials" that will be used in June July and August (with
particular reference to sodium hypochlorite - NaCIO) as well as halogens, however no
evidence of a plan per se.
How is the contamination of the water with bodily fluids addressed ? ... e.g. blood,
urine, feces
C. We also question whether the operator of the wave basin will be able to maintain an
accurate concentration of the required disinfecting agents particularly because of high
rates of water evaporation due to the extraordinary heat, high winds and the wave action itself
in these desert conditions. How will accurate records be kept of the conditions that are
present at the pool? As stated above, the standard of care looks more and more like records
MUST be kept, with frequent assessment and input data for surf/wave basin water.
D. Who will administer the records and data ? Who will ensure compliance ?
E. We are concerned that Kelly Slater et al has essentially stated in the past that "treating and
filtering water pursuant to existing regulations makes a public surf park in California not
viable", as per a quote from the inertia https://www.theinertia.com/surf/kelly-slater-wave-
company-pool-regulations-surf-pool-wave-basin-california/. Thus our question - if this was
argued before by this surf ranch pool, will this aspect of pool maintenance now be taken
seriously by the operators ? It appears that it wasn't in WACO, prior to that young man's death.
Thank you for allowing me to lay out our concerns regarding the maintenance of the surf wave
basin with respect to appropriate cleaning and disinfecting regimes, particularly as related to
the possibility of proliferation of pathogens in water that is not cooled and/or properly
treated in this hot desert environment. Because of the lack of cooling, we are also
concerned about the safety of the people who surf in that type of hot desert environment.
I can be reached at 403 870-2109 should you have any questions.
Kind regards,
Dr. Diane Rebryna B.Sc., D.D.S
60149 Honeysuckle Street
La Quinta, CA
92253
cc:
Kim Saruwatari, MPH, Director
Health Administration Building
4065 County Circle Drive,
Riverside, CA 92503
Thursday, August 5, 2021 at 12:22:10 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR
Date: Thursday, August 5, 2021 at 11:57:16 AM Pacific Daylight Time
From: Harvey Reed
To: consultingplanner@laquintaca.gov
Attachments: Wave Park Locations.jpg, Wave Park Nland_Austin.jpg
Please accept this email as notification of my opposition to the proposed location of the
Coral Mountain Resort. Changing the zoning of the proposed location from "Low Density
Residential -Open Space Recreation" to "Tourist -Commercial" is inconsistent with current and
planned land use. A zoning change will also negatively affect the quality of life for thousands
of La Quinta residents who live adjacent to the proposed location.
The Draft Environmental Impact Report (DEIR) describes the proposed private resort as
having 80 -foot tall light poles, a public address system, an immense hydraulic and mechanical
system pulling a wave sled and other industrial equipment operating from 7:00AM — 10:OOPM,
365 days a year. Based on operations at the developer's other wave park resorts, jet skis will
also operate on the wave basin during the same time. According to the DEIR, this private
resort will host special events throughout the year lasting up to four days in length with an
estimated 2,500 outside attendees per day.
It should be noted that the developers have built wave park resorts in areas that are not
surrounded by residential communities (please see attached photos). They now desire to
build what they describe as "The world's largest wave basin" in the center of a residential area
in La Quinta.
In the DEIR, the developers briefly admit that, "The project site is surrounded by developed
residential communities..." What the DEIR does not articulate is that the residential
communities of The Quarry, Santerra, Coral Mountain Estates, Andalusia, and Trilogy are
adjacent to the proposed location. New home developments are currently planned
immediately south of the proposed location including the Estate Collection at Coral Mountain
and the 1,200 residential Travertine community. When those developments are completed,
the proposed wave park will literally be surrounded by residential communities. The location
of the proposed wave park is currently zoned "Low Density Residential, Open Space -
Recreational" which is consistent with the design and use of existing adjacent residential
communities and those being planned.
The location, size, design and operating characteristics of this proposed project are not
compatible with existing and future land uses. Furthermore, the project will create traffic,
lighting and noise conditions which will negatively impact thousands of La Quinta residents
living in the adjacent residential communities.
Please consider different locations that are appropriate for this project.
Sincerely,
Harvey Reed
60595 Living Stone Drive
La Quinta, CA 92253
(760) 989-1528
Page 1 of 1
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P: (626) 381-9248
F: (626) 389-5414
E: info@mitchtsailaw.com
Mitchell M. Tsai
Attorney At Law
155 South El Molino Avenue
Suite 104
Pasadena, California 91101
VIA E-MAIL
August 5, 2021
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
78495 Calle Tampico La Quinta, CA 92253
Em: consultingplannera,laquintaca.gov
RE: Coral Mountain Resort (SCH #2021020310) — Comments on Draft
Environmental Impact Report
Dear Nucole Sauviat Criste,
On behalf of the Southwest Regional Council of Carpenters ("Commenters" or
"Southwest Carpenters"), my Office is submitting these comments on the City of
La Quinta's ("City" or "Lead Agency") Draft Environmental Impact Report
("DEIR") (SCH No. 2021020310) for the proposed Coral Mountain Resort Project
("Project").
The City proposes to adopt the Project, carving out 386 acres of a 929 -acre area of
the City, to promote future development of the Coral Mountain Resort. The Project
would allow for the development of 600 residential units, a 150 -room resort hotel
plus complementary uses and amenities, a recreational surf facility, 57,000 square feet
of commercial development, 60,000 square feet of neighborhood commercial uses,
and 23.6 acres of recreational uses. As part of the Project, the City would initiate a
general plan amendment and zoning change to designate the Project area for "Tourist
Commercial" uses; a specific plan amendment to exclude the Project area from a
previous specific plan; the adoption of the Project's specific plan; the adoption of a
tentative tract map; site development permits; and the adoption of a development
agreement with the Project applicant.
The Southwest Carpenters is a labor union representing more than 50,000 union
carpenters in six states and has a strong interest in well ordered land use planning and
addressing the environmental impacts of development projects.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 2 of 33
Individual members of the Southwest Carpenters live, work, and recreate in the City
and surrounding communities and would be directly affected by the Project's
environmental impacts.
Commenters expressly reserve the right to supplement these comments at or prior to
hearings on the Project, and at any later hearings and proceedings related to this
Project. Cal. Gov. Code § 65009(b); Cal. Pub. Res. Code § 21177(a); Bakersfield Citizens
for Local Control v. Bakersfield (2004) 124 Cal. App. 4th 1184, 1199-1203; see Galante
Vineyards v. Monterey Water Dist. (1997) 60 Cal. App. 4th 1109, 1121.
Commenters incorporate by reference all comments raising issues regarding the EIR
submitted prior to certification of the EIR for the Project. Citizens for Clean Energy v
City of Woodland (2014) 225 Cal. App. 4th 173, 191 (finding that any party who has
objected to the Project's environmental documentation may assert any issue timely
raised by other parties).
Moreover, Commenters request that the Lead Agency provide notice for any and all
notices referring or related to the Project issued under the California Environmental
Quality Act ("CEQA"), Cal Public Resources Code ("PRC") § 21000 et seq, and the
California Planning and Zoning Law ("Planning and Zoning Law"), Cal. Gov't
Code §§ 65000-65010. California Public Resources Code Sections 21092.2, and
21167(f) and Government Code Section 65092 require agencies to mail such notices
to any person who has filed a written request for them with the clerk of the agency's
governing body.
The City should require the Applicant provide additional community benefits such as
requiring local hire and use of a skilled and trained workforce to build the Project.
The City should require the use of workers who have graduated from a Joint Labor
Management apprenticeship training program approved by the State of California, or
have at least as many hours of on-the-job experience in the applicable craft which
would be required to graduate from such a state approved apprenticeship training
program or who are registered apprentices in an apprenticeship training program
approved by the State of California.
Community benefits such as local hire and skilled and trained workforce requirements
can also be helpful to reduce environmental impacts and improve the positive
economic impact of the Project. Local hire provisions requiring that a certain
percentage of workers reside within 10 miles or less of the Project Site can reduce the
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 3 of 33
length of vendor trips, reduce greenhouse gas emissions and providing localized
economic benefits. Local hire provisions requiring that a certain percentage of
workers reside within 10 miles or less of the Project Site can reduce the length of
vendor trips, reduce greenhouse gas emissions and providing localized economic
benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length
from the default value has the potential to result in a reduction of
construction -related GHG emissions, though the significance of the
reduction would vary based on the location and urbanization level of the
project site.
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and
Considerations for Greenhouse Gas Modeling.
Skilled and trained workforce requirements promote the development of skilled trades
that yield sustainable economic development. As the California Workforce
Development Board and the UC Berkeley Center for Labor Research and Education
concluded:
... labor should be considered an investment rather than a cost — and
investments in growing, diversifying, and upskilling California's workforce
can positively affect returns on climate mitigation efforts. In other words,
well trained workers are key to delivering emissions reductions and
moving California closer to its climate targets.'
Recently, on May 7, 2021, the South Coast Air Quality Management District found that
that the "[u]se of a local state -certified apprenticeship program or a skilled and trained
workforce with a local hire component" can result in air pollutant reductions.2
Cities are increasingly adopting local skilled and trained workforce policies and
requirements into general plans and municipal codes. For example, the City of
Hayward 2040 General Plan requires the City to "promote local hiring ... to help
1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action
Plan for 2030 at p. ii, available athttps://laborcenter.berkeley.edu/wp-content/uploads/2020/09/Putting-California-on-
the-High-Road.pdf
2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt
Proposed Rule 2305 — Warehouse Indirect Source Rule — Warehouse Actions and Investments to Reduce Emissions
Program, and Proposed Rule 316 — Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve
Supporting Budget Actions, available athttp://www.agmd.gov/docs/default-source/Agendas/Governing-
Board/2021 /2021-May7-027.pdf?sfvrsn=10
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
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achieve a more positive jobs -housing balance, and reduce regional commuting, gas
consumption, and greenhouse gas emissions."3
In fact, the City of Hayward has gone as far as to adopt a Skilled Labor Force policy
into its Downtown Specific Plan and municipal code, requiring developments in its
Downtown area to requiring that the City "[c]ontribute to the stabilization of regional
construction markets by spurring applicants of housing and nonresidential
developments to require contractors to utilize apprentices from state -approved, joint
labor-management training programs, ..."4 In addition, the City of Hayward requires
all projects 30,000 square feet or larger to "utilize apprentices from state -approved,
joint labor-management training programs."5
Locating jobs closer to residential areas can have significant environmental benefits.
As the California Planning Roundtable noted in 2008:
People who live and work in the same jurisdiction would be more likely
to take transit, walk, or bicycle to work than residents of less balanced
communities and their vehicle trips would be shorter. Benefits would
include potential reductions in both vehicle miles traveled and vehicle
hours traveled.'
In addition, local hire mandates as well as skill training are critical facets of a strategy
to reduce vehicle miles traveled. As planning experts Robert Cervero and Michael
Duncan noted, simply placing jobs near housing stock is insufficient to achieve VMT
reductions since the skill requirements of available local jobs must be matched to
those held by local residents.' Some municipalities have tied local hire and skilled and
trained workforce policies to local development permits to address transportation
issues. As Cervero and Duncan note:
In nearly built -out Berkeley, CA, the approach to balancing jobs and
housing is to create local jobs rather than to develop new housing." The
3 City of Hayward (2014) Hayward 2040 General Plan Policy Document at p. 3-99, available at https://www.hayward-
ca.gov/sites/default/files/documents/General Plan FINAL.pdf.
4 City of Hayward (2019) Hayward Downtown Specific Plan at p. 5-24, available at https://www.hayward-
ca.gov/site s /default/ file s /Hayward%20D owntown%
20Specific%20Plan.pdf.
5 City of Hayward Municipal Code, Chapter 10, § 28.5.3.020(C).
6 California Planning Roundtable (2008) Deconstructing Jobs -Housing Balance at p. 6, available at
http s: / /cproundtable.org/static /media/uploads /publications / cpr-jobs-housing.pdf
Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs -Housing Balance or Retail -
Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at
http://reconnectingamerica.org/assets/Uploads/UTCT-825.pdf.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 5 of 33
city's First Source program encourages businesses to hire local residents,
especially for entry- and intermediate -level jobs, and sponsors vocational
training to ensure residents are employment -ready. While the program is
voluntary, some 300 businesses have used it to date, placing more than
3,000 city residents in local jobs since it was launched in 1986. When
needed, these carrots are matched by sticks, since the city is not shy about
negotiating corporate participation in First Source as a condition of
approval for development permits.
The City should consider utilizing skilled and trained workforce policies and
requirements to benefit the local area economically and mitigate greenhouse gas, air
quality and transportation impacts.
The City should also require the Project to be built to standards exceeding the current
2019 California Green Building Code to mitigate the Project's environmental impacts
and to advance progress towards the State of California's environmental goals.
I. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT
A. Background Concerning the California Environmental Quality Act
CEQA has two basic purposes. First, CEQA is designed to inform decision makers
and the public about the potential, significant environmental effects of a project. 14
California Code of Regulations ("CCR" or "CEQA Guidelines") § 15002(a)(1).8 "Its
purpose is to inform the public and its responsible officials of the environmental
consequences of their decisions before they are made. Thus, the EIR `protects not only
the environment but also informed self-government.' [Citation.]" Citizens of Goleta
Valley v. Board of Supervisors (1990) 52 Cal. 3d 553, 564. The EIR has been described as
"an environmental `alarm bell' whose purpose it is to alert the public and its
responsible officials to environmental changes before they have reached ecological
points of no return." Berkeley Keep Jets Over the Bay v. Bd. of Port Comm'rs. (2001) 91 Cal.
App. 4th 1344, 1354 ("Berkeley Jets'; County of Inyo v. Yorty (1973) 32 Cal. App. 3d 795,
810.
8 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 150000 et seq, are regulatory
guidelines promulgated by the state Natural Resources Agency for the implementation of CEQA. (Cal. Pub. Res. Code §
21083.) The CEQA Guidelines are given "great weight in interpreting CEQA except when ... clearly unauthorized or
erroneous." Center for Biological Diversity v. Department of Fish & Wildlife (2015) 62 Cal. 4th 204, 217.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 6 of 33
Second, CEQA directs public agencies to avoid or reduce environmental damage
when possible by requiring alternatives or mitigation measures. CEQA Guidelines §
15002(a)(2) and (3). See also, Berkeley Jets, 91 Cal. App. 4th 1344, 1354; Citizens of Goleta
Valley v. Board of Supervisors (1990) 52 Ca1.3d 553; Laurel Heights ImprovementAss'n v.
Regents of the University of California (1988) 47 Ca1.3d 376, 400. The EIR serves to
provide public agencies and the public in general with information about the effect
that a proposed project is likely to have on the environment and to "identify ways that
environmental damage can be avoided or significantly reduced." CEQA Guidelines 5
15002(a)(2). If the project has a significant effect on the environment, the agency may
approve the project only upon finding that it has "eliminated or substantially lessened
all significant effects on the environment where feasible" and that any unavoidable
significant effects on the environment are "acceptable due to overriding concerns"
specified in CEQA section 21081. CEQA Guidelines § 15092(b) (2) (A—B).
While the courts review an EIR using an "abuse of discretion" standard, "the
reviewing court is not to `uncritically rely on every study or analysis presented by a
project proponent in support of its position.' A `clearly inadequate or unsupported
study is entitled to no judicial deference."' Berkeley Jets, 91 Cal.App.4th 1344, 1355
(emphasis added) (quoting Laurel Heights, 47 Ca1.3d at 391, 409 fn. 12). Drawing this
line and determining whether the EIR complies with CEQA's information disclosure
requirements presents a question of law subject to independent review by the courts.
Sierra Club v. Cnty. of Fresno (2018) 6 Cal. 5th 502, 515; Madera Oversight Coalition, Inc. v.
County of Madera (2011) 199 Cal.App.4th 48, 102, 131. As the court stated in Berkeley
Jets, 91 Cal. App. 4th at 1355:
A prejudicial abuse of discretion occurs "if the failure to include relevant
information precludes informed decision-making and informed public
participation, thereby thwarting the statutory goals of the EIR process.
The preparation and circulation of an EIR is more than a set of technical hurdles for
agencies and developers to overcome. The EIR's function is to ensure that
government officials who decide to build or approve a project do so with a full
understanding of the environmental consequences and, equally important, that the
public is assured those consequences have been considered. For the EIR to serve
these goals it must present information so that the foreseeable impacts of pursuing
the project can be understood and weighed, and the public must be given an adequate
opportunity to comment on that presentation before the decision to go forward is
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 7 of 33
made. Communities for a Better Environment v. Richmond (2010) 184 Cal. App. 4th 70, 80
(quoting Vineyard Area Citiens for Responsible Growth, Inc. v. City of Rancho Cordova (2007)
40 Ca1.4th 412, 449-450).
B. CEQA Requires Revision and Recirculation of an Environmental Impact
Report When Substantial Changes or New Information Comes to Light
Section 21092.1 of the California Public Resources Code requires that "[w]hen
significant new information is added to an environmental impact report after notice
has been given pursuant to Section 21092 ... but prior to certification, the public
agency shall give notice again pursuant to Section 21092, and consult again pursuant
to Sections 21104 and 21153 before certifying the environmental impact report" in
order to give the public a chance to review and comment upon the information.
CEQA Guidelines § 15088.5.
Significant new information includes "changes in the project or environmental
setting as well as additional data or other information" that "deprives the public of a
meaningful opportunity to comment upon a substantial adverse environmental effect
of the project or a feasible way to mitigate or avoid such an effect (including a
feasible project alternative)." CEQA Guidelines § 15088.5(a). Examples of significant
new information requiring recirculation include "new significant environmental
impacts from the project or from a new mitigation measure," "substantial increase in
the severity of an environmental impact," "feasible project alternative or mitigation
measure considerably different from others previously analyzed" as well as when "the
draft EIR was so fundamentally and basically inadequate and conclusory in nature
that meaningful public review and comment were precluded." Id.
An agency has an obligation to recirculate an environmental impact report for public
notice and comment due to "significant new information" regardless of whether the
agency opts to include it in a project's environmental impact report. Cadiz Land Co. v.
Rail Cycle (2000) 83 Cal.App.4th 74, 95 [finding that in light of a new expert report
disclosing potentially significant impacts to groundwater supply "the EIR should have
been revised and recirculated for purposes of informing the public and governmental
agencies of the volume of groundwater at risk and to allow the public and
governmental agencies to respond to such information."]. If significant new
information was brought to the attention of an agency prior to certification, an agency
is required to revise and recirculate that information as part of the environmental
impact report.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 8 of 33
C. Due to the COVID-19 Crisis, the City Must Adopt a Mandatory Finding
of Significance that the Project May Cause a Substantial Adverse Effect
on Human Beings and Mitigate COVID-19 Impacts
CEQA requires that an agency make a finding of significance when a Project may
cause a significant adverse effect on human beings. PRC § 21083(b)(3); CEQA
Guidelines § 15065(a)(4).
Public health risks related to construction work requires a mandatory finding of
significance under CEQA. Construction work has been defined as a Lower to High-
risk activity for COVID-19 spread by the Occupations Safety and Health
Administration. Recently, several construction sites have been identified as sources of
community spread of COVID-19.9
SWRCC recommends that the Lead Agency adopt additional CEQA mitigation
measures to mitigate public health risks from the Project's construction activities.
SWRCC requests that the Lead Agency require safe on-site construction work
practices as well as training and certification for any construction workers on the
Project Site.
In particular, based upon SWRCC's experience with safe construction site work
practices, SWRCC recommends that the Lead Agency require that while construction
activities are being conducted at the Project Site:
Construction Site Design:
• The Project Site will be limited to two controlled entry
points.
• Entry points will have temperature screening technicians
taking temperature readings when the entry point is open.
• The Temperature Screening Site Plan shows details
regarding access to the Project Site and Project Site logistics
for conducting temperature screening.
• A 48-hour advance notice will be provided to all trades prior
to the first day of temperature screening.
9 Santa Clara County Public Health Oune 12, 2020) COVID-19 CASES AT CONSTRUCTION SITES HIGHLIGHT
NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available at
https: / /www. sccgov. org/ sites / covid 19 /Page s /pre s s -release -06 -12 -2020 -case s -at -c onstruction-sites. aspx.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
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• The perimeter fence directly adjacent to the entry points will
be clearly marked indicating the appropriate 6 -foot social
distancing position for when you approach the screening
area. Please reference the Apex temperature screening site
map for additional details.
• There will be clear signage posted at the project site directing
you through temperature screening.
• Provide hand washing stations throughout the construction
site.
Testing Procedures:
• The temperature screening being used are non -contact
devices.
• Temperature readings will not be recorded.
• Personnel will be screened upon entering the testing center
and should only take 1-2 seconds per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen or any
other cosmetics must be removed on the forehead before
temperature screening.
• Anyone who refuses to submit to a temperature screening or
does not answer the health screening questions will be
refused access to the Project Site.
• Screening will be performed at both entrances from 5:30 am
to 7:30 am.; main gate [ZONE 1] and personnel gate
[ZONE 2]
• After 7:30 am only the main gate entrance [ZONE 1] will
continue to be used for temperature testing for anybody
gaining entry to the project site such as returning personnel,
deliveries, and visitors.
• If the digital thermometer displays a temperature reading
above 100.0 degrees Fahrenheit, a second reading will be
taken to verify an accurate reading.
• If the second reading confirms an elevated temperature,
DHS will instruct the individual that he/she will not be
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 10 of 33
allowed to enter the Project Site. DHS will also instruct the
individual to promptly notify his/her supervisor and his/her
human resources (HR) representative and provide them with
a copy of Annex A.
Planning
• Require the development of an Infectious Disease Preparedness
and Response Plan that will include basic infection prevention
measures (requiring the use of personal protection equipment),
policies and procedures for prompt identification and isolation of
sick individuals, social distancing (prohibiting gatherings of no
more than 10 people including all -hands meetings and all -hands
lunches) communication and training and workplace controls that
meet standards that may be promulgated by the Center for
Disease Control, Occupational Safety and Health Administration,
Cal/OSHA, California Department of Public Health or applicable
local public health agencies.10
The United Brotherhood of Carpenters and Carpenters International Training Fund
has developed COVID-19 Training and Certification to ensure that Carpenter union
members and apprentices conduct safe work practices. The Agency should require
that all construction workers undergo COVID-19 Training and Certification before
being allowed to conduct construction activities at the Project Site.
D. The DEIR's Project Objectives are Unduly Narrow and Circumscribe
Appropriate Project Alternatives
A project description must state the objectives sought by the proposed project. The
statement of objectives should include the underlying purpose of the project, and it
should be clearly written to guide the selection of mitigation measures and alternatives
to be evaluated in the EIR. (CEQA Guidelines § 15124(b).) An EIR's description of
the underlying purpose of the project is the touchstone for its identification of
specific project objectives, and the statement of project objectives can help to define
1° See also The Center for Construction Research and Training, North America's Building Trades Unions (April 27 2020)
NABTU and CPWR COVIC-19 Standards for U.S Constructions Sites, available athttps.//www.cpwr.com/sites/
default/files/NABTU CPWR Standards COVID-19.pdf; Los Angeles County Department of Public Works (2020)
Guidelines for Construction Sites During COVID-19 Pandemic, available athttps://dpw.lacounty.gov/building-and-
safety/docs/pw guidelines-construction-sites.pdf.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
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the contours of the project's purpose. (Center for Biological Diversity v. County of San
Bernardino (2016) 247 Cal. App. 4th 326, 347.)
While a lead agency has discretion to formulate the project objectives, they cannot be
so narrowly defined that they preclude discussion of project alternatives that could
still achieve the underlying purpose of the project. (North Coast Rivers Alliance v.
Kawamura (2015) 243 Cal. App. 4th 647, 668.) This is so because project alternatives
that do not achieve the project's underlying purpose need not be considered. (In re
Bay -Delta Programmatic Envt'l Impact Report Coordinated Proceedings (2008) 43 Cal. 4th
1143, 1166.) And the statement of objectives should be based upon the underlying
purpose of the project—not the nature of the project itself. (Habitat & Watershed
Caretakers v. City of Santa Cru (2013) 213 Cal. App. 4th 1277, 1299.)
Here, the DEIR inappropriately narrows the objectives of the project based upon the
nature of the project, and not on any underlying purpose. The Project's objectives
include the "[development of] a high-quality private wave basin ('The Wave) that
provides unique recreational opportunities for future residents of the project, and that
attracts resort guests and creates a landmark facility that will enhance the City's
reputation as the 'Gem of the Desert."' (DEIR, 3-8.) If this remains a project
objective, the DEIR need not consider project alternatives that do not provide "high-
quality private wave basins." Certainly, there is no specific requirement that the
tourism or residential housing needs of the City or region demand a surf simulation
facility. The Objective should be reformulated so that a meaningful analysis of project
alternatives can be considered.
E. The DEIR Fails to Support Its Findings with Substantial Evidence
When new information is brought to light showing that an impact previously
discussed in the DEIR but found to be insignificant with or without mitigation in the
DEIR's analysis has the potential for a significant environmental impact supported by
substantial evidence, the EIR must consider and resolve the conflict in the evidence.
See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal. App. 5th 1, 13, 17; see also Protect
the Historic Amador i'aterways v. Amador WaterAgency (2004) 116 Cal. App. 4th 1099,
1109. While a lead agency has discretion to formulate standards for determining
significance and the need for mitigation measures—the choice of any standards or
thresholds of significance must be "based to the extent possible on scientific and
factual data and an exercise of reasoned judgment based on substantial evidence.
CEQA Guidelines § 15064(b); Cleveland Nat'l Forest Found. v. San Diego Ass'n of Gov'ts
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 12 of 33
(2017) 3 Cal. App. 5th 497, 515; Mission Bay Alliance v. Office of Community Inv. &
Infrastructure (2016) 6 Cal. App. 5th 160, 206. And when there is evidence that an
impact could be significant, an EIR cannot adopt a contrary finding without providing
an adequate explanation along with supporting evidence. East Sacramento Partnership for
a Livable City v. City of Sacramento (2016) 5 Cal. App. 5th 281, 302.
In addition, a determination that regulatory compliance will be sufficient to prevent
significant adverse impacts must be based on a project -specific analysis of potential
impacts and the effect of regulatory compliance. Californians for Alternatives to Toxics v.
Department of Food &Agric. (2005) 136 Cal. App. 4th 1; see also Ebbetts Pass Forest Watch
v Department of Forestry & Fire Protection (2008) 43 Cal. App. 4th 936, 956 (fact that
Department of Pesticide Regulation had assessed environmental effects of certain
herbicides in general did not excuse failure to assess effects of their use for specific
timber harvesting project).
1. The DEIR Fails to Support its Findings on Greenhouse Gas and Air
,Quality Impacts with Substantial Evidence.
CEQA Guidelines § 15064.4 allow a lead agency to determine the significance of a
project's GHG impact via a qualitative analysis (e.g., extent to which a project
complies with regulations or requirements of state/regional/local GHG plans),
and/or a quantitative analysis (e.g., using model or methodology to estimate project
emissions and compare it to a numeric threshold). So too, CEQA Guidelines allow
lead agencies to select what model or methodology to estimate GHG emissions so
long as the selection is supported with substantial evidence, and the lead agency
"should explain the limitations of the particular model or methodology selected for
use." CEQA Guidelines § 15064.4(c).
CEQA Guidelines sections 15064.4(b)(3) and 15183.5(b) allow a lead agency to
consider a project's consistency with regulations or requirements adopted to
implement a statewide, regional, or local plan for the reduction or mitigation of GHG
emissions.
CEQA Guidelines §§ 15064.4(b)(3) and 15183.5(b)(1) make clear qualified GHG
reduction plans or CAPs should include the following features:
(1) Inventory: Quantify GHG emissions, both existing and
projected over a specified time period, resulting from activities (e.g.,
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projects) within a defined geographic area (e.g., lead agency
jurisdiction);
(2) Establish GHG Reduction Goal: Establish a level, based
on substantial evidence, below which the contribution to GHG
emissions from activities covered by the plan would not be
cumulatively considerable;
(3) Analyze Project Types: Identify and analyze the GHG
emissions resulting from specific actions or categories of actions
anticipated within the geographic area;
(4) Craft Performance Based Mitigation Measures: Specify
measures or a group of measures, including performance standards,
that substantial evidence demonstrates, if implemented on a project -
by -project basis, would collectively achieve the specified emissions
level;
(5) Monitoring: Establish a mechanism to monitor the CAP
progress toward achieving said level and to require amendment if
the plan is not achieving specified levels;
Collectively, the above -listed CAP features tie qualitative measures to quantitative
results, which in turn become binding via proper monitoring and enforcement by the
jurisdiction—all resulting in real GHG reductions for the jurisdiction as a whole, and
the substantial evidence that the incremental contribution of an individual project is
not cumulatively considerable.
Here, the DEIR's analysis of GHG impacts is unsupported by substantial evidence, as
it relies on outdated modeling. The DEIR's analysis of air quality and GHG impacts
throughout the DEIR relies on data created using Ca1EEMod version 2016.3.2. (See,
e.g., DEIR, 4.1-13). A newer version of this software (currently CalEEMod version
2020.4.0) became available prior to the release of the DEIR. The DEIR provides no
discussion or justification for use of the outdated 2016 version of the software. The
use of outdated modeling software may result in underestimation of the Project's
GHG emissions, calling the DEIR's conclusions into question.
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The DEIR's reliance on inaccurate modeling also affects its analysis of air quality
impacts and energy impacts. The DEIR potentially vastly undercounts the Project's air
pollutant emissions.
Moreover, in its discussion of the GHG impact Significance Threshold chosen for its
GHG analysis, the DEIR chooses to use a target of 3.65 MTCO2e/yr per service
population, stating that this screening target was chosen as a linear interpolation
between the 2020 and 2030 2017 Scoping Plan reduction/efficiency targets based on
the projected 2026 buildout of the Project. (DEIR, 4.7-10). However, the DEIR fails
to provide any reasoning for this choice in either the DEIR itself or the Appendix I
Greenhouse Gas Report. Given that the 2017 Scoping Plan has a target of 2.88
MTCO2e/yr to be attained by 2030,11 it is unclear how a proration of GHG emissions
targets between 2020 and 2030 would be consistent with meeting the goals of AB 32
and SB 32.
2. The DEIR is Required to Consider and Adopt All Feasible Air Quality
and GHG Mitigation Measures
A fundamental purpose of an EIR is to identify ways in which a proposed project's
significant environmental impacts can be mitigated or avoided. Pub. Res. Code §
21002.1(a), 21061. To implement this statutory purpose, an EIR must describe any
feasible mitigation measures that can minimize the project's significant environmental
effects. PRC §§ 21002.1(a), 21100(b) (3); CEQA Guidelines §§ 15121(a), 15126.4(a).
If the project has a significant effect on the environment, the agency may approve the
project only upon finding that it has "eliminated or substantially lessened all significant
effects on the environment where feasible"12 and find that `specific overriding
economic, legal, social, technology or other benefits of the project outweigh the
significant effects on the environment."13 "A gloomy forecast of environmental
degradation is of little or no value without pragmatic, concrete means to minimize the
impacts and restore ecological equilibrium." Environmental Council of Sacramento v. City of
Sacramento (2006) 142 Cal.App.4th 1018, 1039.
Here, the DEIR finds that the Project will have significant and unavoidable impacts on
air quality and greenhouse gas emissions, yet proposes mitigation measures that fall
11 Representing an emissions deduction of 40% from 1990 levels.
12 PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(A).
13 PRC §§ 21002; 21002.1, 21081; CEQA Guidelines §§ 15091, 15092(b)(2)(B).
City of La Quinta — Coral Mountain Resort DEIR
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short of the "all feasible mitigation measures" standard set by CEQA. Mitigation
Measure AQ -2 requires future developments to employ U.S. EPA Tier 3 construction
equipment. However, it fails to justify with substantial evidence why U.S. EPA Tier 4
Final -compliant should not be required. Further, Mitigation Measure AQ -3 demands
the use of low-VOC architectural coatings within the Project area, but the DEIR does
not contemplate the feasibility of a requirement that "Super -Complaint" architectural
be utilized to further decrease Air Quality impacts.
Additionally, the DEIR notes that the Project will require the "design [of] building
shells and building components... to meet 2019 Title 24 Standards," (DEIR, 4.1-14),
but does not specify which standards it is specifically referring to—energy efficiency
standards or CalGreen building standards. Though the DEIR states that both should
apply, it does not state the Project's level of compliance with Tile 24 standards. The
Title 24 "CalGreen" building standards include two different standard "tiers" (Tier 1
and Tier 2) for both residential and non-residential buildings. (Cal. Code of
Regulations, Title 24, Part 11, Appendix A4 at A4.601 and Appendix A5 at A5.601).
The DEIR does not address which tier is applicable within the Project's specific plan
area, and does not state that that the more stringent Tier 2 standards for residential and
non-residential development should be followed. The City should reevaluate the
mitigation measures proposed in the DEIR to ensure the adoption of all feasible
mitigation measures as required by CEQA.
3. The DEIR Improperly Labels Mitigation Measures as `Project Design
Features"
The DEIR improperly labels mitigation measures for "Project Design Features" or
"PDFs" which the DEIR purports will reduce environmental impacts. (See, e.g., DEIR,
4.1-13 through 4.1-15 (Air Quality); see also DEIR, 4.5-18 through 4.5-19 (Energy);
DEIR, 4.7-11 through 13 (Greenhouse Gas Emissions).) Many of the DEIR's
conclusions regarding mitigation of environmental impacts below levels of significance
rely on the implementation of these PDFs, and that as such no additional mitigation is
required.
However, it is established that "'[a]voidance, minimization and / or mitigation
measure' ... are not 'part of the project.' ... compressing the analysis of impacts and
mitigation measures into a single issue .. disregards the requirements of CEQA."
(Lotus v. Department of Transportation (2014) 223 Cal. App. 4th 645, 656.)
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When "an agency decides to incorporate mitigation measures into its significance
determination, and relies on those mitigation measures to determine that no
significant effects will occur, that agency must treat those measures as though there
were adopted following a finding of significance." (Lotus, supra, 223 Cal. App. 4th at
652 [citing CEQA Guidelines § 15091(a) (1) and Cal. Public Resources Code §
21081(a) (1).])
By labeling mitigation measures as project design features, the City violates CEQA by
failing to disclose "the analytic route that the agency took from the evidence to its
findings." (Cal. Public Resources Code § 21081.5; CEQA Guidelines § 15093; Village
Laguna of Laguna Beach, Inc. v. Board of Supervisors (1982) 134 Cal. App. 3d 1022, 1035
[quoting Topanga Assn for a Scenic Community v. County of Los Angeles (1974) 11 Cal. 3d
506, 515.])
The DEIR's use of "Project Design Features" further violates CEQA because such
measures would not be included in the Project's Mitigation Monitoring and Reporting
Program CEQA requires lead agencies to adopt mitigation measures that are fully
enforceable and to adopt a monitoring and/or reporting program to ensure that the
measures are implemented to reduce the Project's significant environmental effects to
the extent feasible. (PRC § 21081.6; CEQA Guidelines § 15091(d).) Though they are
presumably enforceable by the City pursuant to the terms of the Project's
Development Agreement, the PDFs should be properly adopted as mitigations and
subject to a mitigation monitoring and reporting program under CEQA.
4. The DEIR Fails to Support Its Findings on Population and Housing and
Recreation with Substantial Evidence
The City's Notice of Preparation ("NOP") concluded that the Project will have a less
than significant impact on population and housing, and thus precluded the DEIR from
undertaking any further analysis of the direct or indirect effects of the Project on
population growth in the City. Thus, the DEIR does not analyze the issue. Analysis of
Population and Housing impacts was ruled out by NOP, on the grounds that projected
population growth related to the Project still puts the City under its 2035 population
forecast. (DEIR, Appendix A, NOP at pp. 39-40.) La Quinta's General Plan
Environmental Impact Report forecasts a population of 46,297 people by 2035 (Id.),
whereas predicted growth related to the project is 1,698 new residents, (DEIR, 6-6),
raising the population to 42,358 (2,181 new residents in the NOP (raising the
population to 42,841)). However, SCAG's comment on the City's NOP forecasts a
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lower population of 45,034 by 2035. (DEIR, Appendix A, Letter from Southern
California Association of Governments to Nicole Sauviat Criste (April 1, 2021) at p. 4.)
The Project will ultimately result in a net increase in housing, and may have
cumulatively considerable impacts with other housing projects in the area, especially
the adjacent Andalusia project. An EIR's discussion of cumulative impacts is required
by CEQA Guidelines §15130(a). The determination of whether there are cumulative
impacts in any issue area should be determined based on an assessment of the project's
incremental effects "viewed in connection with the effects of past projects, the effects
of other current projects, and the effects of probable future projects." (CEQA
Guidelines §15065(a)(3); Banning Ranch Conservancy v City of Newport Beach (2012) 211
Cal. App. 4th 1209, 1228; see also CEQA Guidelines §15355(b).)
The DEIR demurs on any cumulative impacts analysis based on the assumption that
the Project "is not anticipated to result in an indirect growth inducing impact vecause
the existing infrastructure has been sized to accommodate long term growth... and
because the projected population growth is already included in the City of La Quinta's
General Plan." (DEIR, 6-7). The DEIR cannot simply ignore the fact that 1,698 new
residents will potentially be drawn to the City by the Project and not consider the
cumulative effect of that projected population growth with that of other pending
projects. This is a potentially significant impact that the DEIR should analyze.
In addition, neither the DEIR nor the NOP contain any substantive discussion of
Recreation impacts. (See NOP at pp. 41-42; DEIR, 6-7 through 6-8). The CEQA
Guidelines identify a threshold of significance related to whether or not a project will
include recreational facilities or require the construction or expansion of recreational
facilities that might have an adverse physical effect on the environment. The Project
dedicates 23.6 acres of previously -open space to the development of recreational
facilities on in the Project area, including the potential development of rope courses.
This has reasonably foreseeable environmental impacts and requires analysis in the
DEIR. Payment of Quimby fees (a mitigation) does not excuse the DEIR from
analysis of environmental impacts the Project will have via the creation of recreational
spaces.
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F. The DEIR Fails to Demonstrate Consistency with SCAG's RTP/SCS
Plans
Senate Bill No. 375 requires regional planning agencies to include a sustainable
communities strategy in their regional transportation plans. Gov. Code 5 65080,
sub.(b)(2)(B).) CEQA Guidelines § 15125(d) provides that an EIR "shall discuss any
inconsistencies between the proposed project and...regional plans. Such regional plans
include...regional transportation plans." Thus, CEQA requires analysis of any
inconsistencies between the Project and the relevant RTP/SCS plan.
In April 2012, SCAG adopted its 2012-2035 RTP/ SCS ("2012 RTP/SCS"), which
proposed specific land use policies and transportation strategies for local governments
to implement that will help the region achieve GHG emission reductions of 9 percent
per capita in 2020 and 16 percent per capita in 2035.
In April 2016, SCAG adopted the 2016-2040 RTP/SCS ("2016 RTP/SCS")14, which
incorporates and builds upon the policies and strategies in the 2012 RTP/SCS15, that
will help the region achieve GHG emission reductions that would reduce the region's
per capita transportation emissions by eight percent by 2020 and 18 percent by 2035.16
SCAG's RTP/SCS plan is based upon the same requirements outlined in CARB's 2017
Scoping Plan and SB 375.
On September 3, 2020, SCAG adopted the 2020 — 2045 RTP / SCS titled Connect
SoCal ("2020 RTP/ SCS").17 The 2020 RTP / SCS adopts policies and strategies aimed
at reducing the region's per capita greenhouse gas emissions by 8% below 2005 per
capita emissions levels by 2020 and 19% below 2005 per capita emissions levels by
2035. 18
For both the 2012 and 2016 RTP/SCS, SCAG prepared Program Environmental
Impact Reports ("PEIR") that include Mitigation Monitoring and Reporting Programs
("MMRP") that list project -level environmental mitigation measures that directly
and/or indirectly relate to a project's GHG impacts and contribution to the region's
15 SCAG (Apr. 2016) 2016 RTP/SCS, p. 69, 75-115 (attached as Exhibit D).
16 Id., p. 8, 15, 153, 166.
17 SCAG (Sept 2020) Connect Socal: The 2020 — 2045 Regional Transportation Plan / Sustainable
Communities Strategy of the Southern California Association of Governments, available at
https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal-plan 0.pdf?1606001176
18 Id. At xiii.
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GHG emissions.' These environmental mitigation measures serve to help local
municipalities when identifying mitigation to reduce impacts on a project -specific basis
that can and should be implemented when they identify and mitigate project -specific
environmental impacts.20
Here, the DEIR fails to analyze the Project's is consistency with any of SCAG's
aforementioned RTP/SCS Plans. The DEIR must demonstrate that the Project is
consistent with the RTP/SCS Plans' project -level goals, including:
Land Use and Transportation
• Providing transit fare discounts21;
• Implementing transit integration strategies22; and
• Anticipating shared mobility platforms, car -to -car communications, and
automated vehicle technologies.23
GHG Emissions Goals24
• Reduction in emissions resulting from a project through implementation of
project features, project design, or other measures, such as those described in
Appendix F of the State CEQA Guidelines,25 such as:
o Potential measures to reduce wasteful, inefficient and unnecessary
consumption of energy during construction, operation, maintenance
and/or removal. The discussion should explain why certain measures
were incorporated in the project and why other measures were dismissed.
19 Id., p. 116-124; see also SCAG (April 2012) Regional Transportation Plan 2012 - 20135, fn. 38, p. 77-86
(attached as Exhibit E).
2° SCAG 2012 RTP/SCS (attached as Exhibit E), p. 77; see also SCAG 2016 RTP/SCS, fn. 41, p. 115.
21 SCAG 2016 RTP/SCS, pp. 75-114
22 Id.
23 Id.
24 SCAG 2012 RTP/SCS (Mar. 2012) Final PEIR MMRP, p. 6-2-6-14 (including mitigation measures ("MM")
AQ3, BIO/OS3, CUL2, GEO3, GHG15, HM3, LU14, NO1, POP4, PS12, TR23, W9 [stating "[1]ocal
agencies can and should comply with the requirements of CEQA to mitigate impacts to [the environmental]
as applicable and feasible ... [and] may refer to Appendix G of this PEIR for examples of potential mitigation
to consider when appropriate in reducing environmental impacts of future projects." (Emphasis added)]),; see
also id., Final PEIR Appendix G (including MMs AQI-23, GHGI-8, PS1-104, TR1-83, W1-62),; SCAG 2016
RTP/SCS (Mar. 2016) Final PEIR MMRP, p. 11-63 (including MMs AIR -2(b), AIR -4(b), EN- 2(b), GHG-
3(b), HYD -1(b), HYD -2(b), HYD -8(b), TRA -1(b), TRA -2(b), USS -4(b), USS -6(b)).
25 CEQA Guidelines, Appendix F -Energy Conservation, http://resources.ca.gov/ceqa/
guidelines/Appendix_F.html.
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o The potential siting, orientation, and design to minimize energy
consumption, including transportation energy.
o The potential for reducing peak energy demand.
o Alternate fuels (particularly renewable ones) or energy systems.
o Energy conservation which could result from recycling efforts.
• Off-site measures to mitigate a project's emissions.
• Measures that consider incorporation of Best Available Control Technology
(BACT) during design, construction and operation of projects to minimize
GHG emissions, including but not limited to:
o Use energy and fuel-efficient vehicles and equipment;
o Deployment of zero- and/or near zero emission technologies;
o Use cement blended with the maximum feasible amount of flash or other
materials that reduce GHG emissions from cement production;
o Incorporate design measures to reduce GHG emissions from solid waste
management through encouraging solid waste recycling and reuse;
o Incorporate design measures to reduce energy consumption and increase
use of renewable energy;
o Incorporate design measures to reduce water consumption;
o Use lighter -colored pavement where feasible;
o Recycle construction debris to maximum extent feasible;
• Adopting employer trip reduction measures to reduce employee trips such as
vanpool and carpool programs, providing end -of -trip facilities, and
telecommuting programs.
• Designate a percentage of parking spaces for ride -sharing vehicles or high -
occupancy vehicles, and provide adequate passenger loading and unloading for
those vehicles;
• Land use siting and design measures that reduce GHG emissions, including:
o Measures that increase vehicle efficiency, encourage use of zero and low
emissions vehicles, or reduce the carbon content of fuels, including
City of La Quinta — Coral Mountain Resort DEIR
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constructing or encouraging construction of electric vehicle charging
stations or neighborhood electric vehicle networks, or charging for
electric bicycles; and
o Measures to reduce GHG emissions from solid waste management
through encouraging solid waste recycling and reuse.
Hydrology & Water Quality Goals
• Incorporate measures consistent in a manner that conforms to the standards set
by regulatory agencies responsible for regulating water quality/supply
requirements, such as:
o Reduce exterior consumptive uses of water in public areas, and should
promote reductions in private homes and businesses, by shifting to
drought -tolerant native landscape plantings(xeriscaping), using weather -
based irrigation systems, educating other public agencies about water use,
and installing related water pricing incentives.
o Promote the availability of drought -resistant landscaping options and
provide information on where these can be purchased. Use of reclaimed
water especially in median landscaping and hillside landscaping can and
should be implemented where feasible.
o Implement water conservation best practices such as low -flow toilets,
water -efficient clothes washers, water system audits, and leak detection
and repair.
o Ensure that projects requiring continual dewatering facilities implement
monitoring systems and long-term administrative procedures to ensure
proper water management that prevents degrading of surface water and
minimizes, to the greatest extent possible, adverse impacts on
groundwater for the life of the project. Comply with appropriate building
codes and standard practices including the Uniform Building Code.
o Maximize, where practical and feasible, permeable surface area in existing
urbanized areas to protect water quality, reduce flooding, allow for
groundwater recharge, and preserve wildlife habitat. Minimized new
impervious surfaces to the greatest extent possible, including the use of
in -lieu fees and off-site mitigation.
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o Avoid designs that require continual dewatering where feasible.
o Where feasible, do not site transportation facilities in groundwater
recharge areas, to prevent conversion of those areas to impervious
surface.
• Incorporate measures consistent in a manner that conforms to the standards set
by regulatory agencies responsible for regulating and enforcing water quality and
waste discharge requirements, such as:
o Complete, and have approved, a Stormwater Pollution Prevention Plan
("SWPPP") before initiation of construction.
o Implement Best Management Practices to reduce the peak stormwater
runoff from the project site to the maximum extent practicable.
o Comply with the Caltrans stormwater discharge permit as applicable; and
identify and implement Best Management Practices to manage site
erosion, wash water runoff, and spill control.
o Complete, and have approved, a Standard Urban Stormwater
Management Plan, prior to occupancy of residential or commercial
structures.
o Ensure adequate capacity of the surrounding stormwater system to
support stormwater runoff from new or rehabilitated structures or
buildings.
o Prior to construction within an area subject to Section 404 of the Clean
Water Act, obtain all required permit approvals and certifications for
construction within the vicinity of a watercourse (e.g., Army Corps 5 404
permit, Regional Waterboard § 401 permit, Fish & Wildlife § 401 permit).
o Where feasible, restore or expand riparian areas such that there is no net
loss of impervious surface as a result of the project.
o Install structural water quality control features, such as drainage channels,
detention basins, oil and grease traps, filter systems, and vegetated buffers
to prevent pollution of adjacent water resources by polluted runoff where
required by applicable urban stormwater runoff discharge permits, on
new facilities.
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o Provide structural stormwater runoff treatment consistent with the
applicable urban stormwater runoff permit where Caltrans is the
operator, the statewide permit applies.
o Provide operational best management practices for street cleaning, litter
control, and catch basin cleaning are implemented to prevent water
quality degradation in compliance with applicable stormwater runoff
discharge permits; and ensure treatment controls are in place as early as
possible, such as during the acquisition process for rights-of-way, not just
later during the facilities design and construction phase.
o Comply with applicable municipal separate storm sewer system discharge
permits as well as Caltrans' stormwater discharge permit including long-
term sediment control and drainage of roadway runoff.
o Incorporate as appropriate treatment and control features such as
detention basins, infiltration strips, and porous paving, other features to
control surface runoff and facilitate groundwater recharge into the design
of new transportation projects early on in the process to ensure that
adequate acreage and elevation contours are provided during the right-of-
way acquisition process.
o Design projects to maintain volume of runoff, where any downstream
receiving water body has not been designed and maintained to
accommodate the increase in flow velocity, rate, and volume without
impacting the water's beneficial uses. Pre -project flow velocities, rates,
volumes must not be exceeded. This applies not only to increases in
stormwater runoff from the project site, but also to hydrologic changes
induced by flood plain encroachment. Projects should not cause or
contribute to conditions that degrade the physical integrity or ecological
function of any downstream receiving waters.
o Provide culverts and facilities that do not increase the flow velocity, rate,
or volume and/or acquiring sufficient storm drain easements that
accommodate an appropriately vegetated earthen drainage channel.
o Upgrade stormwater drainage facilities to accommodate any increased
runoff volumes. These upgrades may include the construction of
detention basins or structures that will delay peak flows and reduce flow
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velocities, including expansion and restoration of wetlands and riparian
buffer areas. System designs shall be completed to eliminate increases in
peak flow rates from current levels.
o Encourage Low Impact Development ("LID") and incorporation of
natural spaces that reduce, treat, infiltrate and manage stormwater runoff
flows in all new developments, where practical and feasible.
• Incorporate measures consistent with the provisions of the Groundwater
Management Act and implementing regulations, such as:
o For projects requiring continual dewatering facilities, implement
monitoring systems and long-term administrative procedures to ensure
proper water management that prevents degrading of surface water and
minimizes, to the greatest extent possible, adverse impacts on
groundwater for the life of the project, Construction designs shall comply
with appropriate building codes and standard practices including the
Uniform Building Code.
o Maximize, where practical and feasible, permeable surface area in existing
urbanized areas to protect water quality, reduce flooding, allow for
groundwater recharge, and preserve wildlife habitat. Minimize to the
greatest extent possible, new impervious surfaces, including the use of in -
lieu fees and off-site mitigation.
o Avoid designs that require continual dewatering where feasible.
o Avoid construction and siting on groundwater recharge areas, to prevent
conversion of those areas to impervious surface.
o Reduce hardscape to the extent feasible to facilitate groundwater recharge
as appropriate.
• Incorporate mitigation measures to ensure compliance with all federal, state, and
local floodplain regulations, consistent with the provisions of the National
Flood Insurance Program, such as:
o Comply with Executive Order 11988 on Floodplain Management, which
requires avoidance of incompatible floodplain development, restoration
and preservation of the natural and beneficial floodplain values, and
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maintenance of consistency with the standards and criteria of the
National Flood Insurance Program.
o Ensure that all roadbeds for new highway and rail facilities be elevated at
least one foot above the 100 -year base flood elevation. Since alluvial fan
flooding is not often identified on FEMA flood maps, the risk of alluvial
fan flooding should be evaluated and projects should be sited to avoid
alluvial fan flooding. Delineation of floodplains and alluvial fan
boundaries should attempt to account for future hydrologic changes
caused by global climate change.
Transportation, Traffic, and Safety
• Institute teleconferencing, telecommute and/or flexible work hour programs to
reduce unnecessary employee transportation.
• Create a ride -sharing program by designating a certain percentage of parking
spaces for ride sharing vehicles, designating adequate passenger loading and
unloading for ride sharing vehicles, and providing a web site or message board
for coordinating rides.
• Provide a vanpool for employees.
• Provide a Transportation Demand Management (TDM) plan containing
strategies to reduce on-site parking demand and single occupancy vehicle travel.
The TDM shall include strategies to increase bicycle, pedestrian, transit, and
carpools/vanpool use, including:
o Inclusion of additional bicycle parking, shower, and locker facilities that
exceed the requirement.
o Direct transit sales or subsidized transit passes.
o Guaranteed ride home program.
o Pre-tax commuter benefits (checks).
o On-site car -sharing program (such as City Car Share, Zip Car, etc.).
o On-site carpooling program.
o Distribution of information concerning alternative transportation
options.
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o Parking spaces sold/leased separately.
o Parking management strategies; including attendant/valet parking and
shared parking spaces.
• Promote ride sharing programs e.g., by designating a certain percentage of
parking spaces for high -occupancy vehicles, providing larger parking spaces to
accommodate vans used for ride -sharing, and designating adequate passenger
loading and unloading and waiting areas.
• Encourage the use of public transit systems by enhancing safety and cleanliness
on vehicles and in and around stations, providing shuttle service to public
transit, offering public transit incentives and providing public education and
publicity about public transportation services.
• Build or fund a major transit stop within or near transit development upon
consultation with applicable CTCs.
• Work with the school districts to improve pedestrian and bike access to schools
and to restore or expand school bus service using lower -emitting vehicles.
• Purchase, or create incentives for purchasing, low or zero -emission vehicles.
• Provide the necessary facilities and infrastructure to encourage the use of low or
zero -emission vehicles.
• Promote ride sharing programs, if determined feasible and applicable by the
Lead Agency, including:
o Designate a certain percentage of parking spaces for ride -sharing vehicles.
o Designate adequate passenger loading, unloading, and waiting areas for
ride -sharing vehicles.
o Provide a web site or message board for coordinating shared rides.
o Encourage private, for-profit community car -sharing, including parking
spaces for car share vehicles at convenient locations accessible by public
transit.
o Hire or designate a rideshare coordinator to develop and implement
ridesharing programs.
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• Support voluntary, employer -based trip reduction programs, if determined
feasible and applicable by the Lead Agency, including:
o Provide assistance to regional and local ridesharing organizations.
o Advocate for legislation to maintain and expand incentives for employer
ridesharing programs.
o Require the development of Transportation Management Associations
for large employers and commercial/ industrial complexes.
o Provide public recognition of effective programs through awards, top ten
lists, and other mechanisms.
• Implement a "guaranteed ride home" program for those who commute by
public transit, ridesharing, or other modes of transportation, and encourage
employers to subscribe to or support the program.
• Encourage and utilize shuttles to serve neighborhoods, employment centers and
major destinations.
• Create a free or low-cost local area shuttle system that includes a fixed route to
popular tourist destinations or shopping and business centers.
• Work with existing shuttle service providers to coordinate their services.
• Facilitate employment opportunities that minimize the need for private vehicle
trips, such as encourage telecommuting options with new and existing
employers, through project review and incentives, as appropriate.
• Organize events and workshops to promote GHG-reducing activities.
• Implement a Parking Management Program to discourage private vehicle use,
including:
o Encouraging carpools and vanpools with preferential parking and a
reduced parking fee.
o Institute a parking cash -out program or establish a parking fee for all
single -occupant vehicles.
Utilities & Service Systems
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 28 of 33
• Integrate green building measures consistent with CALGreen (Title 24, part 11),
U.S. Green Building Council's Leadership in Energy and Environmental Design,
energy Star Homes, Green Point Rated Homes, and the California Green
Builder Program into project design including, but not limited to the following:
o Reuse and minimization of construction and demolition (C&D) debris
and diversion of C&D waste from landfills to recycling facilities.
o Inclusion of a waste management plan that promotes maximum C&D
diversion.
o Development of indoor recycling program and space.
o Discourage exporting of locally generated waste outside of the SCAG
region during the construction and implementation of a project.
Encourage disposal within the county where the waste originates as much
as possible. Promote green technologies for long-distance transport of
waste (e.g., clean engines and clean locomotives or electric rail for waste -
by -rail disposal systems) and consistency with SCAQMD and 2016
RTP/SCS policies can and should be required.
o Develop ordinances that promote waste prevention and recycling
activities such as: requiring waste prevention and recycling efforts at all
large events and venues; implementing recycled content procurement
programs; and developing opportunities to divert food waste away from
landfills and toward food banks and composting facilities.
o Develop alternative waste management strategies such as composting,
recycling, and conversion technologies.
o Develop and site composting, recycling, and conversion technology
facilities that have minimum environmental and health impacts.
o Require the reuse and recycle construction and demolition waste
(including, but not limited to, soil, vegetation, concrete, lumber, metal,
and cardboard).
o Integrate reuse and recycling into residential industrial, institutional and
commercial projects.
o Provide recycling opportunities for residents, the public, and tenant
businesses.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 29 of 33
o Provide education and publicity about reducing waste and available
recycling services.
o Implement or expand city or county -wide recycling and composting
programs for residents and businesses. This could include extending the
types of recycling services offered (e.g., to include food and green waste
recycling) and providing public education and publicity about recycling
services.
The DEIR fails to mention or demonstrate consistency with the above listed measures
and strategies of the SCAG RTP/SCS Plans. The DEIR should be revised to indicate
what specific project -level mitigation measures that will be followed to demonstrate
consistency with the RTP/SCS Plans.
G. Failure to Include Consultation and Preparation Section
CEQA requires all EIRs contain certain contents. See CEQA Guidelines §§ 15122 —
15131. CEQA expressly requires an EIR "identify all federal, state, or local agencies,
other organizations, and private individuals consulted in preparing the draft EIR, and
the persons, firm, or agency preparing the draft EIR, by contract or other
authorization." CEQA Guidelines § 15129. This information is critical to
demonstrating a lead agency fulfilled its obligation to "consult with, and obtain
comments from, each responsible agency, trustee agency, any public agency that has
jurisdiction by law with respect to the project, and any city or county that borders on
a city or county within which the project is located ...." PRC § 21104(a).
Failure to provide sufficient information concerning the lead agency's consultation
efforts could undermine the legal sufficiency of an EIR. Courts determine de novo
whether a CEQA environmental document sufficiently discloses information required
by CEQA as "noncompliance with the information disclosure provisions" of CEQA
is a failure to proceed in a manner required by law. PRC § 21005(a); see also Sierra Club
v. County of Fresno (2018) 6 Cal. 5th 502, 515.
Here, the DEIR fails to identify which federal agencies, state agencies, local agencies,
or other organizations, if any, that were consulted in the preparation of this DEIR.
The DEIR should be revised to identify the organizations the City consulted with in
the preparation of the DEIR in compliance with Section 21104(a) of the Public
Resources Code.
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 30 of 33
II. THE PROJECT VIOLATES THE STATE PLANNING AND
ZONING LAW AS WELL AS THE CITY'S GENERAL PLAN
A. Background Regarding the State Planning and Zoning Law
Each California city and county must adopt a comprehensive, long-term general plan
governing development. Napa Citizens for Honest Gov. v. Napa County Bd. of Supervisors
(2001) 91 Cal.App.4th 342, 352, citing Gov. Code §§ 65030, 65300. The general plan
sits at the top of the land use planning hierarchy, and serves as a "constitution" or
"charter" for all future development. DeVita v. County of Napa (1995) 9 Ca1.4th 763,
773; Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Ca1.3d 531, 540.
General plan consistency is "the linchpin of California's land use and development
laws; it is the principle which infused the concept of planned growth with the force
of law." See Debottari v. Norco City Council (1985) 171 Cal.App.3d 1204, 1213.
State law mandates two levels of consistency. First, a general plan must be internally
or "horizontally" consistent: its elements must "comprise an integrated, internally
consistent and compatible statement of policies for the adopting agency." See Gov.
Code § 65300.5; Sierra Club v. Bd. of Supervisors (1981) 126 Cal.App.3d 698, 704. A
general plan amendment thus may not be internally inconsistent, nor may it cause the
general plan as a whole to become internally inconsistent. See DeVita, 9 Ca1.4th at 796
fn. 12.
Second, state law requires "vertical" consistency, meaning that zoning ordinances and
other land use decisions also must be consistent with the general plan. See Gov.
Code § 65860(a)(2) [land uses authorized by zoning ordinance must be "compatible
with the objectives, policies, general land uses, and programs specified in the
[general] plan."]; see also Neighborhood Action Group v. County of Calaveras (1984) 156
Cal.App.3d 1176, 1184. A zoning ordinance that conflicts with the general plan or
impedes achievement of its policies is invalid and cannot be given effect. See Lesher,
52 Ca1.3d at 544.
State law requires that all subordinate land use decisions, including conditional use
permits, be consistent with the general plan. See Gov. Code § 65860(a)(2);
Neighborhood Action Group, 156 Cal.App.3d at 1184.
A project cannot be found consistent with a general plan if it conflicts with a general
plan policy that is "fundamental, mandatory, and clear," regardless of whether it is
consistent with other general plan policies. See Endangered Habitats League v. County of
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 31 of 33
Orange (2005) 131 Cal.App.4th 777, 782-83; Families Unafraid to Uphold Rural El Dorado
County v. Bd. of Supervisors (1998) 62 Cal.App.4th 1332, 1341-42 ("FUTURE").
Moreover, even in the absence of such a direct conflict, an ordinance or development
project may not be approved if it interferes with or frustrates the general plan's
policies and objectives. See Napa Citizens, 91 Cal.App.4th at 378-79; see also Lesher, 52
Ca1.3d at 544 (zoning ordinance restricting development conflicted with growth -
oriented policies of general plan).
As explained in full below, the Project is inconsistent with the City's General Plan. As
such, the Project violates the State Planning and Zoning law.
B. The Project is Inconsistent with the General Plan, and thus the DEIR's
Conclusions Regarding Impacts on Land Use and Planning are
Unsupported by Substantial Evidence
The DEIR fail to establish the Project's consistency with several General Plan goals,
policies, and programs including the following:
• Policy LU -2.3: The City's outdoor lighting ordinance will be maintained;
• Goal LU -3 and associated policies and programs: Safe and identifiable
neighborhoods that provide a sense of place;
• Policy LU -5.1: Use development incentives to achieve a mix of housing,
including affordable housing;
• Policy CIR-1.14: Private streets shall be developed in accordance with
development standards set forth in the Municipal Code, relevant Public
Works Bulletins, and other applicable standards and guidelines;
• Policy SC -1.2: Reduce water consumption at a minimum consistent with
the Greenhouse Gas Reduction Plan (also see Air Quality Element);
• Policy SC -1.4: Reduce Greenhouse Gas emissions at a minimum
consistent with the Greenhouse Gas Reduction Plan (also see Air Quality
Element);
• Goal H-2 and associated policies and programs: Assist in the creation and
provision of resources to support housing for lower and moderate income
households;
• Goal H-3 and associated policies and programs: Create a regulatory system
that does not unduly constrain the maintenance, improvement, and
development of housing affordable to all La Quinta residents;
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 32 of 33
• Goal H-5 and associated policies and programs: Provide equal housing
opportunities for all persons;
• Goal AQ -1 and associated policies and programs: A reduction in all air
emissions generated within the City;
• Goal BIO -1 and associated policies and programs: The protection and
preservation of native and environmentally significant biological resources
and their habitats;
• Policy WR -1.6: Encourage the use of permeable pavements in residential
and commercial development projects;
• Goal OS -2 and associated policies and programs: Good stewardship of
natural open space and preservation of open space areas;
• Goal OS -3 and associated policies and programs: Preservation of scenic
resources as vital contributions to the City's economic health and overall
quality of life;
• Policy UTL-1.3: New development shall reduce its projected water
consumption rates over "business -as -usual" consumption rates.
The Project fails to discuss its conformity with each of the aforementioned Goals,
Policies, and Programs laid out in the City's General Plan, even though the Project will
have reasonably foreseeable impacts on land use, traffic, housing and population,
biological resources, vehicle trip generation, air quality, and GHG emissions. This
discussion is relevant not only to compliance with land use and zoning law, but also
with the contemplation of the Project's consistency with land use plans, policies, and
regulations adopted for the purpose of avoiding or mitigating environmental impacts.
The DEIR should be amended to include analysis of the Project's comportment with
the Goals, Policies, and Programs listed above.
Further, the DEIR should be revised to analyze the Project's consistency with the
City's upcoming 6th Cycle Housing Element Update and its related Regional Housing
Needs Assessment.
III. CONCLUSION
Commenters request that the City revise and recirculate the Project's DEIR and/or
prepare an environmental impact report which addresses the aforementioned
concerns. If the City has any questions or concerns, feel free to contact my Office.
Sincerely,
City of La Quinta — Coral Mountain Resort DEIR
August 5, 2021
Page 33 of 33
Mitchell M. Tsai
Attorneys for Southwest Regional Council of Carpenters
Attached:
March 8, 2021 SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and
Considerations for Greenhouse Gas Modeling (Exhibit A);
Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B);
Air Quality and GHG Expert Matt Hagemann CV (Exhibit C);
EXHIBIT A
SWAPE
Technical Consultation, Data Analysis and
Litigation Support for the Environment
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
mhagemann@swape.com
Paul E. Rosenfeld, PhD
(310) 795-2335
prosenfeld@swape.com
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling
Dear Mr. Tsai,
Soil Water Air Protection Enterprise ("SWAPE") is pleased to provide the following draft technical report
explaining the significance of worker trips required for construction of land use development projects with
respect to the estimation of greenhouse gas ("GHG") emissions. The report will also discuss the potential for
local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the
potential GHG impacts.
Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model ("CaIEEMod") is a "statewide land use emissions computer model
designed to provide a uniform platform for government agencies, land use planners, and environmental
professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both
construction and operations from a variety of land use projects."' CaIEEMod quantifies construction -related
emissions associated with land use projects resulting from off-road construction equipment; on -road mobile
equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition,
truck loading, and on -road vehicles traveling along paved and unpaved roads; and architectural coating
activities; and paving.2
The number, length, and vehicle class of worker trips are utilized by CaIEEMod to calculate emissions associated
with the on -road vehicle trips required to transport workers to and from the Project site during construction.3
1 "California Emissions Estimator Model." CAPCOA, 2017, available at: http://www.agmd.gov/caleemod/home.
2 "California Emissions Estimator Model." CAPCOA, 2017, available at: http://www.agmd.gov/caleemod/home.
"CaIEEMod User's Guide." CAPCOA, November 2017, available at: http://www.agmd.gov/docs/default-
source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34.
1
Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled ("VMT")
associated with construction. Then, utilizing vehicle -class specific EMFAC 2014 emission factors, CaIEEMod
calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction -related VMT,
including personal vehicles for worker commuting.'
Specifically, in order to calculate VMT, CaIEEMod multiplies the average daily trip rate by the average overall trip
length (see excerpt below):
"VMTd=1(Average Daily Trip Rate i * Average Overall Trip Length I) n
Where:
n = Number of land uses being modeled."5
Furthermore, to calculate the on -road emissions associated with worker trips, CaIEEMod utilizes the following
equation (see excerpt below):
"EmisSlonspollutant = VMT * EFrunning,pollutant
Where:
Emissionspollutant = emissions from vehicle running for each pollutant
VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions."6
Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT
and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running
emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall
trip length, by way of a local hire requirement or otherwise.
Default Worker Trip Parameters and Potential Local Hire Requirements
As previously discussed, the number, length, and vehicle class of worker trips are utilized by CaIEEMod to
calculate emissions associated with the on -road vehicle trips required to transport workers to and from the
Project site during construction.' In order to understand how local hire requirements and associated worker trip
length reductions impact GHG emissions calculations, it is important to consider the CaIEEMod default worker
trip parameters. CaIEEMod provides recommended default values based on site-specific information, such as
land use type, meteorological data, total lot acreage, project type and typical equipment associated with project
type. If more specific project information is known, the user can change the default values and input project -
specific values, but the California Environmental Quality Act ("CEQA") requires that such changes be justified by
substantial evidence.' The default number of construction -related worker trips is calculated by multiplying the
"Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at: http://www.agmd.gov/docs/default-
source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15.
5 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at: http://www.agmd.gov/docs/default-
source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 23.
6 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default-
source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 15.
"'CaIEEMod User's Guide." CAPCOA, November 2017, available at: http://www.agmd.gov/docs/default-
source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34.
$ CaIEEMod User Guide, available at: http://www.caleemod.com/, p. 1, 9.
2
number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the
building construction and architectural coating phases.' Furthermore, the worker trip vehicle class is a 50/25/25
percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively."10 Finally, the
default worker trip length is consistent with the length of the operational home -to -work vehicle trips.' The
operational home -to -work vehicle trip lengths are:
"[B]ased on the location and urbanization selected on the project characteristic screen. These values
were supplied by the air districts or use a default average for the state. Each district (or county) also
assigns trip lengths for urban and rural settings" (emphasis added). 12
Thus, the default worker trip length is based on the location and urbanization level selected by the User when
modeling emissions. The below table shows the CaIEEMod default rural and urban worker trip lengths by air
basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin
Rural (miles) Urban (miles)
Great Basin Valleys 16.8 10.8
Lake County 16.8 10.8
Lake Tahoe 16.8 10.8
Mojave Desert 16.8 10.8
Mountain Counties 16.8 10.8
North Central Coast 17.1 12.3
North Coast 16.8 10.8
Northeast Plateau 16.8 10.8
Sacramento Valley 16.8 10.8
Salton Sea 14.6 11
San Diego 16.8 10.8
San Francisco Bay Area 10.8 10.8
San Joaquin Valley 16.8 10.8
South Central Coast 16.8 10.8
South Coast 19.8 14.7
Average 16.47 11.17
Minimum 10.80 10.80
Maximum 19.80 14.70
Range 9.00 3.90
"CaIEEMod User's Guide." CAPCOA, November 2017, available at: http://www.agmd.gov/docs/default-
source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34.
10 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at:
http://www.agmd.gov/docs/default-source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 15.
11 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at:
http://www.agmd.gov/docs/default-source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 14.
12 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at:
http://www.agmd.gov/docs/default-source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 21.
13 "Appendix D Default Data Tables." CAPCOA, October 2017, available at: http://www.agmd.gov/docs/default-
source/caleemod/05 appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 - D-86.
3
As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8 -
miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7 -
miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban
worker trip lengths tend to be shorter in length. Based on these trends evident in the CaIEEMod default worker
trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent
upon the urbanization of the project site, as well as the project location.
Practical Application of a Local Hire Requirement and Associated Impact
To provide an example of the potential impact of a local hire provision on construction -related GHG emissions,
we estimated the significance of a local hire provision for the Village South Specific Plan ("Project") located in
the City of Claremont ("City"). The Project proposed to construct 1,000 residential units, 100,000 -SF of retail
space, 45,000 -SF of office space, as well as a 50 -room hotel, on the 24 -acre site. The Project location is classified
as Urban and lies within the Los Angeles -South Coast County. As a result, the Project has a default worker trip
length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project's
construction -related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10
miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10 -mile radius were to be
implemented, the GHG emissions associated with Project construction would decrease by approximately 17%
(see table below and Attachment C).
Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e)
3,623
Amortized Construction GHG Emissions (MT CO2e/year)
120.77
With Local Hire Provision
Total Construction GHG Emissions (MT CO2e)
3,024
Amortized Construction GHG Emissions (MT CO2e/year)
% Decrease in Construction -related GHG Emissions
100.80
17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project
could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire
requirement that results in a decreased worker trip length from the default value has the potential to result in a
reduction of construction -related GHG emissions, though the significance of the reduction would vary based on
the location and urbanization level of the project site.
This serves as an example of the potential impacts of local hire requirements on estimated project -level GHG
emissions, though it does not indicate that local hire requirements would result in reduced construction -related
GHG emission for all projects. As previously described, the significance of a local hire requirement depends on
the worker trip length enforced and the default worker trip length for the project's urbanization level and
location.
14 "Appendix D Default Data Tables." CAPCOA, October 2017, available at: http://www.agmd.gov/docs/default-
source/caleemod/05 appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85.
4
Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we
retain the right to revise or amend this report when additional information becomes available. Our professional
services have been performed using that degree of care and skill ordinarily exercised, under similar
circumstances, by reputable environmental consultants practicing in this or similar localities at the time of
service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and
protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which
were limited to information that was reasonably accessible at the time of the work, and may contain
informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of
information obtained or provided by third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
5
EXHIBIT B
SWAPE
Technical Consultation, Data Analysis and
Litigation Support for the Environment
SOIL WATER AIR PROTECTION ENTERPRISE
2656 29th Street, Suite 201
Santa Monica, California 90405
Attn: Paul Rosenfeld, Ph.D.
Mobil: (310) 795-2335
Office: (310) 452-5555
Fax: (310) 452-5550
Email: prosenfeld@swape.com
Paul Rosenfeld, Ph.D.
Chemical Fate and Transport & Air Dispersion Modeling
Principal Environmental Chemist Risk Assessment & Remediation Specialist
Education
Ph.D. Soil Chemistry, University of Washington, 1999. Dissertation on volatile organic compound filtration.
M.S. Environmental Science, U.C. Berkeley, 1995. Thesis on organic waste economics.
B.A. Environmental Studies, U.C. Santa Barbara, 1991. Thesis on wastewater treatment.
Professional Experience
Dr. Rosenfeld has over 25 years' experience conducting environmental investigations and risk assessments for
evaluating impacts to human health, property, and ecological receptors. His expertise focuses on the fate and
transport of environmental contaminants, human health risk, exposure assessment, and ecological restoration. Dr.
Rosenfeld has evaluated and modeled emissions from unconventional oil drilling operations, oil spills, landfills,
boilers and incinerators, process stacks, storage tanks, confined animal feeding operations, and many other industrial
and agricultural sources. His project experience ranges from monitoring and modeling of pollution sources to
evaluating impacts of pollution on workers at industrial facilities and residents in surrounding communities.
Dr. Rosenfeld has investigated and designed remediation programs and risk assessments for contaminated sites
containing lead, heavy metals, mold, bacteria, particulate matter, petroleum hydrocarbons, chlorinated solvents,
pesticides, radioactive waste, dioxins and furans, semi- and volatile organic compounds, PCBs, PAHs, perchlorate,
asbestos, per- and poly-fluoroalkyl substances (PFOA/PFOS), unusual polymers, fuel oxygenates (MTBE), among
other pollutants. Dr. Rosenfeld also has experience evaluating greenhouse gas emissions from various projects and is
an expert on the assessment of odors from industrial and agricultural sites, as well as the evaluation of odor nuisance
impacts and technologies for abatement of odorous emissions. As a principal scientist at SWAPE, Dr. Rosenfeld
directs air dispersion modeling and exposure assessments. He has served as an expert witness and testified about
pollution sources causing nuisance and/or personal injury at dozens of sites and has testified as an expert witness on
more than ten cases involving exposure to air contaminants from industrial sources.
Paul E. Rosenfeld, Ph.D. Page 1 of 10 June 2019
Professional History:
Soil Water Air Protection Enterprise (SWAPE); 2003 to present; Principal and Founding Partner
UCLA School of Public Health; 2007 to 2011; Lecturer (Assistant Researcher)
UCLA School of Public Health; 2003 to 2006; Adjunct Professor
UCLA Environmental Science and Engineering Program; 2002-2004; Doctoral Intern Coordinator
UCLA Institute of the Environment, 2001-2002; Research Associate
Komex H2O Science, 2001 to 2003; Senior Remediation Scientist
National Groundwater Association, 2002-2004; Lecturer
San Diego State University, 1999-2001; Adjunct Professor
Anteon Corp., San Diego, 2000-2001; Remediation Project Manager
Ogden (now Amec), San Diego, 2000-2000; Remediation Project Manager
Bechtel, San Diego, California, 1999 — 2000; Risk Assessor
King County, Seattle, 1996 — 1999; Scientist
James River Corp., Washington, 1995-96; Scientist
Big Creek Lumber, Davenport, California, 1995; Scientist
Plumas Corp., California and USFS, Tahoe 1993-1995; Scientist
Peace Corps and World Wildlife Fund, St. Kitts, West Indies, 1991-1993; Scientist
Publications:
Remy, L.L., Clay T., Byers, V., Rosenfeld P. E. (2019) Hospital, Health, and Community Burden After Oil
Refinery Fires, Richmond, California 2007 and 2012. Environmental Health. 18:48
Simons, R.A., Seo, Y. Rosenfeld, P., (2015) Modeling the Effect of Refinery Emission On Residential Property
Value. Journal of Real Estate Research. 27(3):321-342
Chen, J. A, Zapata A. R., Sutherland A. J., Molmen, D.R., Chow, B. S., Wu, L. E., Rosenfeld, P. E., Hesse, R. C.,
(2012) Sulfur Dioxide and Volatile Organic Compound Exposure To A Community In Texas City Texas Evaluated
Using Aermod and Empirical Data. American Journal of Environmental Science, 8(6), 622-632.
Rosenfeld, P.E. & Feng, L. (2011). The Risks of Hazardous Waste. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2011). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Agrochemical Industry, Amsterdam: Elsevier Publishing.
Gonzalez, J., Feng, L., Sutherland, A., Waller, C., Sok, H., Hesse, R., Rosenfeld, P. (2010). PCBs and
Dioxins/Furans in Attic Dust Collected Near Former PCB Production and Secondary Copper Facilities in Sauget, IL.
Procedia Environmental Sciences. 113-125.
Feng, L., Wu, C., Tam, L., Sutherland, A.J., Clark, J.J., Rosenfeld, P.E. (2010). Dioxin and Furan Blood Lipid and
Attic Dust Concentrations in Populations Living Near Four Wood Treatment Facilities in the United States. Journal
of Environmental Health. 73(6), 34-46.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2010). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Wood and Paper Industries. Amsterdam: Elsevier Publishing.
Cheremisinoff, N.P., & Rosenfeld, P.E. (2009). Handbook of Pollution Prevention and Cleaner Production: Best
Practices in the Petroleum Industry. Amsterdam: Elsevier Publishing.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (2009). Dioxin and furan blood lipid concentrations in populations living
near four wood treatment facilities in the United States. WIT Transactions on Ecology and the Environment, Air
Pollution, 123 (17), 319-327.
Paul E. Rosenfeld, Ph.D. Page 2 of 10 June 2019
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). A Statistical Analysis Of Attic Dust And Blood Lipid
Concentrations Of Tetrachloro-p-Dibenzodioxin (TCDD) Toxicity Equivalency Quotients (TEQ) In Two
Populations Near Wood Treatment Facilities. Organohalogen Compounds, 70, 002252-002255.
Tam L. K.., Wu C. D., Clark J. J. and Rosenfeld, P.E. (2008). Methods For Collect Samples For Assessing Dioxins
And Other Environmental Contaminants In Attic Dust: A Review. Organohalogen Compounds, 70, 000527-
000530.
Hensley, A.R. A. Scott, J. J. J. Clark, Rosenfeld, P.E. (2007). Attic Dust and Human Blood Samples Collected near
a Former Wood Treatment Facility. Environmental Research. 105, 194-197.
Rosenfeld, P.E., J. J. J. Clark, A. R. Hensley, M. Suffet. (2007). The Use of an Odor Wheel Classification for
Evaluation of Human Health Risk Criteria for Compost Facilities. Water Science & Technology 55(5), 345-357.
Rosenfeld, P. E., M. Suffet. (2007). The Anatomy Of Odour Wheels For Odours Of Drinking Water, Wastewater,
Compost And The Urban Environment. Water Science & Technology 55(5), 335-344.
Sullivan, P. J. Clark, J.J.J., Agardy, F. J., Rosenfeld, P.E. (2007). Toxic Legacy, Synthetic Toxins in the Food,
Water, and Air in American Cities. Boston Massachusetts: Elsevier Publishing
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash. Water Science
and Technology. 49(9),171-178.
Rosenfeld P. E., J.J. Clark, I.H. (Mel) Suffet (2004). The Value of An Odor -Quality -Wheel Classification Scheme
For The Urban Environment. Water Environment Federation's Technical Exhibition and Conference (WEFTEC)
2004. New Orleans, October 2-6, 2004.
Rosenfeld, P.E., and Suffet, I.H. (2004). Understanding Odorants Associated With Compost, Biomass Facilities,
and the Land Application of Biosolids. Water Science and Technology. 49(9), 193-199.
Rosenfeld, P.E., and Suffet I.H. (2004). Control of Compost Odor Using High Carbon Wood Ash, Water Science
and Technology, 49( 9), 171-178.
Rosenfeld, P. E., Grey, M. A., Sellew, P. (2004). Measurement of Biosolids Odor and Odorant Emissions from
Windrows, Static Pile and Biofilter. Water Environment Research. 76(4), 310-315.
Rosenfeld, P.E., Grey, M and Suffet, M. (2002). Compost Demonstration Project, Sacramento California Using
High -Carbon Wood Ash to Control Odor at a Green Materials Composting Facility. Integrated Waste Management
Board Public Affairs Office, Publications Clearinghouse (MS -6), Sacramento, CA Publication #442-02-008.
Rosenfeld, P.E., and C.L. Henry. (2001). Characterization of odor emissions from three different biosolids. Water
Soil and Air Pollution. 127(1-4), 173-191.
Rosenfeld, P.E., and Henry C. L., (2000). Wood ash control of odor emissions from biosolids application. Journal
of Environmental Quality. 29, 1662-1668.
Rosenfeld, P.E., C.L. Henry and D. Bennett. (2001). Wastewater dewatering polymer affect on biosolids odor
emissions and microbial activity. Water Environment Research. 73(4), 363-367.
Rosenfeld, P.E., and C.L. Henry. (2001). Activated Carbon and Wood Ash Sorption of Wastewater, Compost, and
Biosolids Odorants. Water Environment Research, 73, 388-393.
Rosenfeld, P.E., and Henry C. L., (2001). High carbon wood ash effect on biosolids microbial activity and odor.
Water Environment Research. 131(1-4), 247-262.
Paul E. Rosenfeld, Ph.D. Page 3 of 10 June 2019
Chollack, T. and P. Rosenfeld. (1998). Compost Amendment Handbook For Landscaping. Prepared for and
distributed by the City of Redmond, Washington State.
Rosenfeld, P. E. (1992). The Mount Liamuiga Crater Trail. Heritage Magazine of St. Kitts, 3(2).
Rosenfeld, P. E. (1993). High School Biogas Project to Prevent Deforestation On St. Kitts. Biomass Users
Network, 7(1).
Rosenfeld, P. E. (1998). Characterization, Quantification, and Control of Odor Emissions From Biosolids
Application To Forest Soil. Doctoral Thesis. University of Washington College of Forest Resources.
Rosenfeld, P. E. (1994). Potential Utilization of Small Diameter Trees on Sierra County Public Land. Masters
thesis reprinted by the Sierra County Economic Council. Sierra County, California.
Rosenfeld, P. E. (1991). How to Build a Small Rural Anaerobic Digester & Uses Of Biogas In The First And Third
World. Bachelors Thesis. University of California.
Presentations:
Rosenfeld, P.E., Sutherland, A; Hesse, R.; Zapata, A. (October 3-6, 2013). Air dispersion modeling of volatile
organic emissions from multiple natural gas wells in Decatur, TX. 44th Western Regional Meeting, American
Chemical Society. Lecture conducted from Santa Clara, CA.
Sok, H.L.; Waller, C.C.; Feng, L.; Gonzalez, J.; Sutherland, A.J.; Wisdom -Stack, T.; Sahai, R.K.; Hesse, R.C.;
Rosenfeld, P.E. (June 20-23, 2010). Atrazine: A Persistent Pesticide in Urban Drinking Water.
Urban Environmental Pollution. Lecture conducted from Boston, MA.
Feng, L.; Gonzalez, J.; Sok, H.L.; Sutherland, A.J.; Waller, C.C.; Wisdom -Stack, T.; Sahai, R.K.; La, M.; Hesse,
R.C.; Rosenfeld, P.E. (June 20-23, 2010). Bringing Environmental Justice to East St. Louis,
Illinois. Urban Environmental Pollution. Lecture conducted from Boston, MA.
Rosenfeld, P.E. (April 19-23, 2009). Perfluoroctanoic Acid (PFOA) and Perfluoroactane Sulfonate (PFOS)
Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the United
States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting, Lecture conducted
from Tuscon, AZ.
Rosenfeld, P.E. (April 19-23, 2009). Cost to Filter Atrazine Contamination from Drinking Water in the United
States" Contamination in Drinking Water From the Use of Aqueous Film Forming Foams (AFFF) at Airports in the
United States. 2009 Ground Water Summit and 2009 Ground Water Protection Council Spring Meeting. Lecture
conducted from Tuscon, AZ.
Wu, C., Tam, L., Clark, J., Rosenfeld, P. (20-22 July, 2009). Dioxin and furan blood lipid concentrations in
populations living near four wood treatment facilities in the United States. Brebbia, C.A. and Popov, V., eds., Air
Pollution XVII: Proceedings of the Seventeenth International Conference on Modeling, Monitoring and
Management of Air Pollution. Lecture conducted from Tallinn, Estonia.
Rosenfeld, P. E. (October 15-18, 2007). Moss Point Community Exposure To Contaminants From A Releasing
Facility. The 23rd Annual International Conferences on Soils Sediment and Water. Platform lecture conducted from
University of Massachusetts, Amherst MA.
Rosenfeld, P. E. (October 15-18, 2007). The Repeated Trespass of Tritium -Contaminated Water Into A
Surrounding Community Form Repeated Waste Spills From A Nuclear Power Plant. The 23rd Annual International
Conferences on Soils Sediment and Water. Platform lecture conducted from University of Massachusetts, Amherst
MA.
Paul E. Rosenfeld, Ph.D. Page 4 of 10 June 2019
Rosenfeld, P. E. (October 15-18, 2007). Somerville Community Exposure To Contaminants From Wood Treatment
Facility Emissions. The 23'd Annual International Conferences on Soils Sediment and Water. Lecture conducted
from University of Massachusetts, Amherst MA.
Rosenfeld P. E. (March 2007). Production, Chemical Properties, Toxicology, & Treatment Case Studies of 1,2,3-
Trichloropropane (TCP). The Association for Environmental Health and Sciences (AEHS) Annual Meeting. Lecture
conducted from San Diego, CA.
Rosenfeld P. E. (March 2007). Blood and Attic Sampling for Dioxin/Furan, PAH, and Metal Exposure in Florala,
Alabama. The AEHS Annual Meeting. Lecture conducted from San Diego, CA.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (August 21 — 25, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. The 26th International Symposium on
Halogenated Persistent Organic Pollutants — DIOXIN2006. Lecture conducted from Radisson SAS Scandinavia
Hotel in Oslo Norway.
Hensley A.R., Scott, A., Rosenfeld P.E., Clark, J.J.J. (November 4-8, 2006). Dioxin Containing Attic Dust And
Human Blood Samples Collected Near A Former Wood Treatment Facility. APHA 134 Annual Meeting &
Exposition. Lecture conducted from Boston Massachusetts.
Paul Rosenfeld Ph.D. (October 24-25, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
Mealey's C8/PFOA. Science, Risk & Litigation Conference. Lecture conducted from The Rittenhouse Hotel,
Philadelphia, PA.
Paul Rosenfeld Ph.D. (September 19, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation PEMA Emerging Contaminant Conference. Lecture conducted from Hilton
Hotel, Irvine California.
Paul Rosenfeld Ph.D. (September 19, 2005). Fate, Transport, Toxicity, And Persistence of 1,2,3 -TCP. PEMA
Emerging Contaminant Conference. Lecture conducted from Hilton Hotel in Irvine, California.
Paul Rosenfeld Ph.D. (September 26-27, 2005). Fate, Transport and Persistence of PDBEs. Mealey's Groundwater
Conference. Lecture conducted from Ritz Carlton Hotel, Marina Del Ray, California.
Paul Rosenfeld Ph.D. (June 7-8, 2005). Fate, Transport and Persistence of PFOA and Related Chemicals.
International Society of Environmental Forensics: Focus On Emerging Contaminants. Lecture conducted from
Sheraton Oceanfront Hotel, Virginia Beach, Virginia.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Fate Transport, Persistence and Toxicology of PFOA and Related
Perfluorochemicals. 2005 National Groundwater Association Ground Water And Environmental Law Conference.
Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld Ph.D. (July 21-22, 2005). Brominated Flame Retardants in Groundwater: Pathways to Human
Ingestion, Toxicology and Remediation. 2005 National Groundwater Association Ground Water and
Environmental Law Conference. Lecture conducted from Wyndham Baltimore Inner Harbor, Baltimore Maryland.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. and Rob Hesse R.G. (May 5-6, 2004). Tert-butyl Alcohol Liability
and Toxicology, A National Problem and Unquantified Liability. National Groundwater Association. Environmental
Law Conference. Lecture conducted from Congress Plaza Hotel, Chicago Illinois.
Paul Rosenfeld, Ph.D. (March 2004). Perchlorate Toxicology. Meeting of the American Groundwater Trust.
Lecture conducted from Phoenix Arizona.
Hagemann, M.F., Paul Rosenfeld, Ph.D. and Rob Hesse (2004). Perchlorate Contamination of the Colorado River.
Meeting of tribal representatives. Lecture conducted from Parker, AZ.
Paul E. Rosenfeld, Ph.D. Page 5 of 10 June 2019
Paul Rosenfeld, Ph.D. (April 7, 2004). A National Damage Assessment Model For PCE and Dry Cleaners.
Drycleaner Symposium. California Ground Water Association. Lecture conducted from Radison Hotel, Sacramento,
California.
Rosenfeld, P. E., Grey, M., (June 2003) Two stage biofilter for biosolids composting odor control. Seventh
International In Situ And On Site Bioremediation Symposium Battelle Conference Orlando, FL.
Paul Rosenfeld, Ph.D. and James Clark Ph.D. (February 20-21, 2003) Understanding Historical Use, Chemical
Properties, Toxicity and Regulatory Guidance of 1,4 Dioxane. National Groundwater Association. Southwest Focus
Conference. Water Supply and Emerging Contaminants.. Lecture conducted from Hyatt Regency Phoenix Arizona.
Paul Rosenfeld, Ph.D. (February 6-7, 2003). Underground Storage Tank Litigation and Remediation. California
CUPA Forum. Lecture conducted from Marriott Hotel, Anaheim California.
Paul Rosenfeld, Ph.D. (October 23, 2002) Underground Storage Tank Litigation and Remediation. EPA
Underground Storage Tank Roundtable. Lecture conducted from Sacramento California.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Understanding Odor from Compost, Wastewater and
Industrial Processes. Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water
Association. Lecture conducted from Barcelona Spain.
Rosenfeld, P.E. and Suffet, M. (October 7- 10, 2002). Using High Carbon Wood Ash to Control Compost Odor.
Sixth Annual Symposium On Off Flavors in the Aquatic Environment. International Water Association. Lecture
conducted from Barcelona Spain.
Rosenfeld, P.E. and Grey, M. A. (September 22-24, 2002). Biocycle Composting For Coastal Sage Restoration.
Northwest Biosolids Management Association. Lecture conducted from Vancouver Washington..
Rosenfeld, P.E. and Grey, M. A. (November 11-14, 2002). Using High -Carbon Wood Ash to Control Odor at a
Green Materials Composting Facility. Soil Science Society Annual Conference. Lecture conducted from
Indianapolis, Maryland.
Rosenfeld. P.E. (September 16, 2000). Two stage biofilter for biosolids composting odor control. Water
Environment Federation. Lecture conducted from Anaheim California.
Rosenfeld. P.E. (October 16, 2000). Wood ash and biofilter control of compost odor. Biofest. Lecture conducted
from Ocean Shores, California.
Rosenfeld, P.E. (2000). Bioremediation Using Organic Soil Amendments. California Resource Recovery
Association. Lecture conducted from Sacramento California.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation With High -Carbon Wood -Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., and C.L. Henry. (1999). An evaluation of ash incorporation with biosolids for odor reduction. Soil
Science Society of America. Lecture conducted from Salt Lake City Utah.
Rosenfeld, P.E., C.L. Henry, R. Harrison. (1998). Comparison of Microbial Activity and Odor Emissions from
Three Different Biosolids Applied to Forest Soil. Brown and Caldwell. Lecture conducted from Seattle Washington.
Rosenfeld, P.E., C.L. Henry. (1998). Characterization, Quantification, and Control of Odor Emissions from
Biosolids Application To Forest Soil. Biofest. Lecture conducted from Lake Chelan, Washington.
Paul E. Rosenfeld, Ph.D. Page 6 of 10 June 2019
Rosenfeld, P.E, C.L. Henry, R. Harrison. (1998). Oat and Grass Seed Germination and Nitrogen and Sulfur
Emissions Following Biosolids Incorporation With High -Carbon Wood -Ash. Water Environment Federation 12th
Annual Residuals and Biosolids Management Conference Proceedings. Lecture conducted from Bellevue
Washington.
Rosenfeld, P.E., C.L. Henry, R. B. Harrison, and R. Dills. (1997). Comparison of Odor Emissions From Three
Different Biosolids Applied to Forest Soil. Soil Science Society of America. Lecture conducted from Anaheim
California.
Teaching Experience:
UCLA Department of Environmental Health (Summer 2003 through 20010) Taught Environmental Health Science
100 to students, including undergrad, medical doctors, public health professionals and nurses. Course focused on
the health effects of environmental contaminants.
National Ground Water Association, Successful Remediation Technologies. Custom Course in Sante Fe, New
Mexico. May 21, 2002. Focused on fate and transport of fuel contaminants associated with underground storage
tanks.
National Ground Water Association; Successful Remediation Technologies Course in Chicago Illinois. April 1,
2002. Focused on fate and transport of contaminants associated with Superfund and RCRA sites.
California Integrated Waste Management Board, April and May, 2001. Alternative Landfill Caps Seminar in San
Diego, Ventura, and San Francisco. Focused on both prescriptive and innovative landfill cover design.
UCLA Department of Environmental Engineering, February 5, 2002. Seminar on Successful Remediation
Technologies focusing on Groundwater Remediation.
University Of Washington, Soil Science Program, Teaching Assistant for several courses including: Soil Chemistry,
Organic Soil Amendments, and Soil Stability.
U.C. Berkeley, Environmental Science Program Teaching Assistant for Environmental Science 10.
Academic Grants Awarded:
California Integrated Waste Management Board. $41,000 grant awarded to UCLA Institute of the Environment.
Goal: To investigate effect of high carbon wood ash on volatile organic emissions from compost. 2001.
Synagro Technologies, Corona California: $10,000 grant awarded to San Diego State University.
Goal: investigate effect of biosolids for restoration and remediation of degraded coastal sage soils. 2000.
King County, Department of Research and Technology, Washington State. $100,000 grant awarded to University of
Washington: Goal: To investigate odor emissions from biosolids application and the effect of polymers and ash on
VOC emissions. 1998.
Northwest Biosolids Management Association, Washington State. $20,000 grant awarded to investigate effect of
polymers and ash on VOC emissions from biosolids. 1997.
James River Corporation, Oregon: $10,000 grant was awarded to investigate the success of genetically engineered
Poplar trees with resistance to round -up. 1996.
United State Forest Service, Tahoe National Forest: $15,000 grant was awarded to investigating fire ecology of the
Tahoe National Forest. 1995.
Kellogg Foundation, Washington D.C. $500 grant was awarded to construct a large anaerobic digester on St. Kitts
in West Indies. 1993
Paul E. Rosenfeld, Ph.D. Page 7 of 10 June 2019
Deposition and/or Trial Testimony:
In the United States District Court For The District of New Jersey
Duarte et al, Plaintiffs, vs. United States Metals Refining Company et. al. Defendant.
Case No.: 2:17-cv-01624-ES-SCM
Rosenfeld Deposition. 6-7-2019
In the United States District Court of Southern District of Texas Galveston Division
M/T Carla Maersk, Plaintiffs, vs. Conti 168., Schiffahrts-GMBH & Co. Bulker KG MS "Conti Perdido"
Defendant.
Case No.: 3:15 -CV -00106 consolidated with 3:15 -CV -00237
Rosenfeld Deposition. 5-9-2019
In The Superior Court of the State of California In And For The County Of Los Angeles — Santa Monica
Carole-Taddeo-Bates et al., vs. Ifran Khan et al., Defendants
Case No.: No. BC615636
Rosenfeld Deposition, 1-26-2019
In The Superior Court of the State of California In And For The County Of Los Angeles — Santa Monica
The San Gabriel Valley Council of Governments et al. vs El Adobe Apts. Inc. et al., Defendants
Case No.: No. BC646857
Rosenfeld Deposition, 10-6-2018; Trial 3-7-19
In United States District Court For The District of Colorado
Bells et al. Plaintiff vs. The 3M Company et al., Defendants
Case: No 1:16-cv-02531-RBJ
Rosenfeld Deposition, 3-15-2018 and 4-3-2018
In The District Court Of Regan County, Texas, 112th Judicial District
Phillip Bales et al., Plaintiff vs. Dow Agrosciences, LLC, et al., Defendants
Cause No 1923
Rosenfeld Deposition, 11-17-2017
In The Superior Court of the State of California In And For The County Of Contra Costa
Simons et al., Plaintiffs vs. Chevron Corporation, et al., Defendants
Cause No C12-01481
Rosenfeld Deposition, 11-20-2017
In The Circuit Court Of The Twentieth Judicial Circuit, St Clair County, Illinois
Martha Custer et al., Plaintiff vs. Cerro Flow Products, Inc., Defendants
Case No.: No. 0i9 -L-2295
Rosenfeld Deposition, 8-23-2017
In The Superior Court of the State of California, For The County of Los Angeles
Warrn Gilbert and Penny Gilber, Plaintiff vs. BMW of North America LLC
Case No.: LC102019 (c/w BC582154)
Rosenfeld Deposition, 8-16-2017, Trail 8-28-2018
In the Northern District Court of Mississippi, Greenville Division
Brenda J. Cooper, et al., Plaintiffs, vs. Meritor Inc., et al., Defendants
Case Number: 4:16-cv-52-DMB-JVM
Rosenfeld Deposition: July 2017
Paul E. Rosenfeld, Ph.D. Page 8 of 10 June 2019
In The Superior Court of the State of Washington, County of Snohomish
Michael Davis and Julie Davis et al., Plaintiff vs. Cedar Grove Composting Inc., Defendants
Case No.: No. 13-2-03987-5
Rosenfeld Deposition, February 2017
Trial, March 2017
In The Superior Court of the State of California, County of Alameda
Charles Spain., Plaintiff vs. Thermo Fisher Scientific, et al., Defendants
Case No.: RG14711115
Rosenfeld Deposition, September 2015
In The Iowa District Court In And For Poweshiek County
Russell D. Winburn, et al., Plaintiffs vs. Doug Hoksbergen, et al., Defendants
Case No.: LALA002187
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Jerry Dovico, et al., Plaintiffs vs. Valley View Sine LLC, et al., Defendants
Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Iowa District Court For Wapello County
Doug Pauls, et al.,, et al., Plaintiffs vs. Richard Warren, et al., Defendants
Law No,: LALA105144 - Division A
Rosenfeld Deposition, August 2015
In The Circuit Court of Ohio County, West Virginia
Robert Andrews, et al. v. Antero, et al.
Civil Action NO. 14-C-30000
Rosenfeld Deposition, June 2015
In The Third Judicial District County of Dona Ana, New Mexico
Betty Gonzalez, et al. Plaintiffs vs. Del Oro Dairy, Del Oro Real Estate LLC, Jerry Settles and Deward
DeRuyter, Defendants
Rosenfeld Deposition: July 2015
In The Iowa District Court For Muscatine County
Laurie Freeman et. al. Plaintiffs vs. Grain Processing Corporation, Defendant
Case No 4980
Rosenfeld Deposition: May 2015
In the Circuit Court of the 17t Judicial Circuit, in and For Broward County, Florida
Walter Hinton, et. al. Plaintiff, vs. City of Fort Lauderdale, Florida, a Municipality, Defendant.
Case Number CACE07030358 (26)
Rosenfeld Deposition: December 2014
In the United States District Court Western District of Oklahoma
Tommy McCarty, et al., Plaintiffs, v. Oklahoma City Landfill, LLC d/b/a Southeast Oklahoma City
Landfill, et al. Defendants.
Case No. 5 :12-cv-01152-C
Rosenfeld Deposition: July 2014
Paul E. Rosenfeld, Ph.D. Page 9 of 10 June 2019
In the County Court of Dallas County Texas
Lisa Parr et al, Plaintiff, vs. Aruba et al, Defendant.
Case Number cc -11-01650-E
Rosenfeld Deposition: March and September 2013
Rosenfeld Trial: April 2014
In the Court of Common Pleas of Tuscarawas County Ohio
John Michael Abicht, et al., Plaintiffs, vs. Republic Services, Inc., et al., Defendants
Case Number: 2008 CT 10 0741 (Cons. w/ 2009 CV 10 0987)
Rosenfeld Deposition: October 2012
In the United States District Court of Southern District of Texas Galveston Division
Kyle Cannon, Eugene Donovan, Genaro Ramirez, Carol Sassler, and Harvey Walton, each Individually and
on behalf of those similarly situated, Plaintiffs, vs. BP Products North America, Inc., Defendant.
Case 3:10-cv-00622
Rosenfeld Deposition: February 2012
Rosenfeld Trial: April 2013
In the Circuit Court of Baltimore County Maryland
Philip E. Cvach, II et al., Plaintiffs vs. Two Farms, Inc. d/b/a Royal Farms, Defendants
Case Number: 03-C-12-012487 OT
Rosenfeld Deposition: September 2013
Paul E. Rosenfeld, Ph.D. Page 10 of 10 June 2019
EXHIBIT C
SWAPE
Technical Consultation, Data Analysis and
Litigation Support for the Environment
Matthew F. Hagemann, P.G., C.Hg., QSD, QSP
1640 5th St.., Suite 204 Santa
Santa Monica, California 90401
Tel: (949) 887-9013
Email: mhagemann@swape.com
Geologic and Hydrogeologic Characterization
Industrial Stormwater Compliance
Investigation and Remediation Strategies
Litigation Support and Testifying Expert
CEQA Review
Education:
M.S. Degree, Geology, California State University Los Angeles, Los Angeles, CA, 1984.
B.A. Degree, Geology, Humboldt State University, Arcata, CA, 1982.
Professional Certifications:
California Professional Geologist
California Certified Hydrogeologist
Qualified SWPPP Developer and Practitioner
Professional Experience:
Matt has 25 years of experience in environmental policy, assessment and remediation. He spent nine
years with the U.S. EPA in the RCRA and Superfund programs and served as EPA's Senior Science
Policy Advisor in the Western Regional Office where he identified emerging threats to groundwater from
perchlorate and MTBE. While with EPA, Matt also served as a Senior Hydrogeologist in the oversight of
the assessment of seven major military facilities undergoing base closure. He led numerous enforcement
actions under provisions of the Resource Conservation and Recovery Act (RCRA) while also working
with permit holders to improve hydrogeologic characterization and water quality monitoring.
Matt has worked closely with U.S. EPA legal counsel and the technical staff of several states in the
application and enforcement of RCRA, Safe Drinking Water Act and Clean Water Act regulations. Matt
has trained the technical staff in the States of Califomia, Hawaii, Nevada, Arizona and the Territory of
Guam in the conduct of investigations, groundwater fundamentals, and sampling techniques.
Positions Matt has held include:
• Founding Partner, Soil/Water/Air Protection Enterprise (SWAPE) (2003 — present);
• Geology Instructor, Golden West College, 2010 — 2014;
• Senior Environmental Analyst, Komex H2O Science, Inc. (2000 -- 2003);
• Executive Director, Orange Coast Watch (2001 - 2004);
• Senior Science Policy Advisor and Hydrogeologist, U.S. Environmental Protection Agency (1989-
1998);
• Hydrogeologist, National Park Service, Water Resources Division (1998 - 2000);
• Adjunct Faculty Member, San Francisco State University, Department of Geosciences (1993 -
1998);
• Instructor, College of Marin, Department of Science (1990 -1995);
• Geologist, U.S. Forest Service (1986 -1998); and
• Geologist, Dames & Moore (1984 -1986).
Senior Regulatory and Litigation Support Analyst:
With SWAPE, Matt's responsibilities have included:
• Lead analyst and testifying expert in the review of over 100 environmental impact reports
since 2003 under CEQA that identify significant issues with regard to hazardous waste, water
resources, water quality, air quality, Valley Fever, greenhouse gas emissions, and geologic
hazards. Make recommendations for additional mitigation measures to lead agencies at the
local and county level to include additional characterization of health risks and
implementation of protective measures to reduce worker exposure to hazards from toxins
and Valley Fever.
• Stormwater analysis, sampling and best management practice evaluation at industrial facilities.
• Manager of a project to provide technical assistance to a community adjacent to a former
Naval shipyard under a grant from the U.S. EPA.
• Technical assistance and litigation support for vapor intrusion concerns.
• Lead analyst and testifying expert in the review of environmental issues in license applications
for large solar power plants before the California Energy Commission.
• Manager of a project to evaluate numerous formerly used military sites in the western U.S.
• Manager of a comprehensive evaluation of potential sources of perchlorate contamination in
Southern California drinking water wells.
• Manager and designated expert for litigation support under provisions of Proposition 65 in the
review of releases of gasoline to sources drinking water at major refineries and hundreds of gas
stations throughout California.
• Expert witness on two cases involving MTBE litigation.
• Expert witness and litigation support on the impact of air toxins and hazards at a school.
• Expert witness in litigation at a former plywood plant.
With Komex H2O Science Inc., Matt's duties included the following:
• Senior author of a report on the extent of perchlorate contamination that was used in testimony
by the former U.S. EPA Administrator and General Counsel.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of MTBE use, research, and regulation.
• Senior researcher in the development of a comprehensive, electronically interactive chronology
of perchlorate use, research, and regulation.
• Senior researcher in a study that estimates nationwide costs for MTBE remediation and drinking
water treatment, results of which were published in newspapers nationwide and in testimony
against provisions of an energy bill that would limit liability for oil companies.
• Research to support litigation to restore drinking water supplies that have been contaminated by
MTBE in California and New York.
2
• Expert witness testimony in a case of oil production -related contamination in Mississippi.
• Lead author for a multi -volume remedial investigation report for an operating school in Los
Angeles that met strict regulatory requirements and rigorous deadlines.
3
• Development of strategic approaches for cleanup of contaminated sites in consultation with
clients and regulators.
Executive Director:
As Executive Director with Orange Coast Watch, Matt led efforts to restore water quality at Orange
County beaches from multiple sources of contamination including urban runoff and the discharge of
wastewater. In reporting to a Board of Directors that included representatives from leading Orange
County universities and businesses, Matt prepared issue papers in the areas of treatment and disinfection
of wastewater and control of the discharge of grease to sewer systems. Matt actively participated in the
development of countywide water quality permits for the control of urban runoff and permits for the
discharge of wastewater. Matt worked with other nonprofits to protect and restore water quality, including
Surfrider, Natural Resources Defense Council and Orange County CoastKeeper as well as with business
institutions including the Orange County Business Council.
Hydrogeology:
As a Senior Hydrogeologist with the U.S. Environmental Protection Agency, Matt led investigations to
characterize and cleanup closing military bases, including Mare Island Naval Shipyard, Hunters Point
Naval Shipyard, Treasure Island Naval Station, Alameda Naval Station, Moffett Field, Mather Army
Airfield, and Sacramento Army Depot. Specific activities were as follows:
• Led efforts to model groundwater flow and contaminant transport, ensured adequacy of
monitoring networks, and assessed cleanup alternatives for contaminated sediment, soil, and
groundwater.
• Initiated a regional program for evaluation of groundwater sampling practices and laboratory
analysis at military bases.
• Identified emerging issues, wrote technical guidance, and assisted in policy and regulation
development through work on four national U.S. EPA workgroups, including the Superfund
Groundwater Technical Forum and the Federal Facilities Forum.
At the request of the State of Hawaii, Matt developed a methodology to determine the vulnerability of
groundwater to contamination on the islands of Maui and Oahu. He used analytical models and a GIS to
show zones of vulnerability, and the results were adopted and published by the State of Hawaii and
County of Maui.
As a hydrogeologist with the EPA Groundwater Protection Section, Matt worked with provisions of the
Safe Drinking Water Act and NEPA to prevent drinking water contamination. Specific activities included
the following:
• Received an EPA Bronze Medal for his contribution to the development of national guidance for
the protection of drinking water.
• Managed the Sole Source Aquifer Program and protected the drinking water of two communities
through designation under the Safe Drinking Water Act. He prepared geologic reports,
conducted public hearings, and responded to public comments from residents who were very
concerned about the impact of designation.
4
• Reviewed a number of Environmental Impact Statements for planned major developments,
including large hazardous and solid waste disposal facilities, mine reclamation, and water
transfer.
Matt served as a hydrogeologist with the RCRA Hazardous Waste program. Duties were as follows:
• Supervised the hydrogeologic investigation of hazardous waste sites to determine compliance
with Subtitle C requirements.
• Reviewed and wrote "part B" permits for the disposal of hazardous waste.
• Conducted RCRA Corrective Action investigations of waste sites and led inspections that formed
the basis for significant enforcement actions that were developed in close coordination with U.S.
EPA legal counsel.
• Wrote contract specifications and supervised contractor's investigations of waste sites.
With the National Park Service, Matt directed service -wide investigations of contaminant sources to
prevent degradation of water quality, including the following tasks:
• Applied pertinent laws and regulations including CERCLA, RCRA, NEPA, NRDA, and the
Clean Water Act to control military, mining, and landfill contaminants.
• Conducted watershed -scale investigations of contaminants at parks, including Yellowstone and
Olympic National Park.
• Identified high -levels of perchlorate in soil adjacent to a national park in New Mexico
and advised park superintendent on appropriate response actions under CERCLA.
• Served as a Park Service representative on the Interagency Perchlorate Steering Committee, a
national workgroup.
• Developed a program to conduct environmental compliance audits of all National Parks while
serving on a national workgroup.
• Co-authored two papers on the potential for water contamination from the operation of personal
watercraft and snowmobiles, these papers serving as the basis for the development of nation-
wide policy on the use of these vehicles in National Parks.
• Contributed to the Federal Multi -Agency Source Water Agreement under the Clean Water
Action Plan.
Policy:
Served senior management as the Senior Science Policy Advisor with the U.S. Environmental Protection
Agency, Region 9. Activities included the following:
• Advised the Regional Administrator and senior management on emerging issues such as the
potential for the gasoline additive MTBE and ammonium perchlorate to contaminate drinking
water supplies.
• Shaped EPA's national response to these threats by serving on workgroups and by contributing
to guidance, including the Office of Research and Development publication, Oxygenates in
Water: Critical Information and Research Needs.
• Improved the technical training of EPA's scientific and engineering staff.
• Earned an EPA Bronze Medal for representing the region's 300 scientists and engineers in
negotiations with the Administrator and senior management to better integrate scientific
principles into the policy-making process.
• Established national protocol for the peer review of scientific documents.
5
Geology:
With the U.S. Forest Service, Matt led investigations to determine hillslope stability of areas proposed for
timber harvest in the central Oregon Coast Range. Specific activities were as follows:
• Mapped geology in the field, and used aerial photographic interpretation and mathematical
models to determine slope stability.
• Coordinated his research with community members who were concerned with natural resource
protection.
• Characterized the geology of an aquifer that serves as the sole source of drinking water for the
city of Medford, Oregon.
As a consultant with Dames and Moore, Matt led geologic investigations of two contaminated sites (later
listed on the Superfund NPL) in the Portland, Oregon, area and a large hazardous waste site in eastern
Oregon. Duties included the following:
• Supervised year-long effort for soil and groundwater sampling.
• Conducted aquifer tests.
• Investigated active faults beneath sites proposed for hazardous waste disposal.
Teaching:
From 1990 to 1998, Matt taught at least one course per semester at the community college and university
levels:
• At San Francisco State University, held an adjunct faculty position and taught courses in
environmental geology, oceanography (lab and lecture), hydrogeology, and groundwater
contamination.
• Served as a committee member for graduate and undergraduate students.
• Taught courses in environmental geology and oceanography at the College of Marin.
Matt taught physical geology (lecture and lab and introductory geology at Golden West College in
Huntington Beach, California from 2010 to 2014.
Invited Testimony, Reports, Papers and Presentations:
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Presentation to the Public
Environmental Law Conference, Eugene, Oregon.
Hagemann, M.F., 2008. Disclosure of Hazardous Waste Issues under CEQA. Invited presentation to U.S.
EPA Region 9, San Francisco, California.
Hagemann, M.F., 2005. Use of Electronic Databases in Environmental Regulation, Policy Making and
Public Participation. Brownfields 2005, Denver, Coloradao.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Nevada and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust, Las
Vegas, NV (served on conference organizing committee).
Hagemann, M.F., 2004. Invited testimony to a California Senate committee hearing on air toxins at
schools in Southern California, Los Angeles.
6
Brown, A., Farrow, J., Gray, A. and Hagemann, M., 2004. An Estimate of Costs to Address MTBE
Releases from Underground Storage Tanks and the Resulting Impact to Drinking Water Wells.
Presentation to the Ground Water and Environmental Law Conference, National Groundwater
Association.
Hagemann, M.F., 2004. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in Arizona and the Southwestern U.S. Presentation to a meeting of the American Groundwater Trust,
Phoenix, AZ (served on conference organizing committee).
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River and Impacts to Drinking Water
in the Southwestern U.S. Invited presentation to a special committee meeting of the National Academy
of Sciences, Irvine, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
tribal EPA meeting, Pechanga, CA.
Hagemann, M.F., 2003. Perchlorate Contamination of the Colorado River. Invited presentation to a
meeting of tribal repesentatives, Parker, AZ.
Hagemann, M.F., 2003. Impact of Perchlorate on the Colorado River and Associated Drinking Water
Supplies. Invited presentation to the Inter -Tribal Meeting, Torres Martinez Tribe.
Hagemann, M.F., 2003. The Emergence of Perchlorate as a Widespread Drinking Water Contaminant.
Invited presentation to the U.S. EPA Region 9.
Hagemann, M.F., 2003. A Deductive Approach to the Assessment of Perchlorate Contamination. Invited
presentation to the California Assembly Natural Resources Committee.
Hagemann, M.F., 2003. Perchlorate: A Cold War Legacy in Drinking Water. Presentation to a meeting of
the National Groundwater Association.
Hagemann, M.F., 2002. From Tank to Tap: A Chronology of MTBE in Groundwater. Presentation to a
meeting of the National Groundwater Association.
Hagemann, M.F., 2002. A Chronology of MTBE in Groundwater and an Estimate of Costs to Address
Impacts to Groundwater. Presentation to the annual meeting of the Society of Environmental
Journalists.
Hagemann, M.F., 2002. An Estimate of the Cost to Address MTBE Contamination in Groundwater
(and Who Will Pay). Presentation to a meeting of the National Groundwater Association.
Hagemann, M.F., 2002. An Estimate of Costs to Address MTBE Releases from Underground Storage
Tanks and the Resulting Impact to Drinking Water Wells. Presentation to a meeting of the U.S. EPA and
State Underground Storage Tank Program managers.
Hagemann, M.F., 2001. From Tank to Tap: A Chronology of MTBE in Groundwater. Unpublished
report.
7
Hagemann, M.F., 2001. Estimated Cleanup Cost for MTBE in Groundwater Used as Drinking Water.
Unpublished report.
Hagemann, M.F., 2001. Estimated Costs to Address MTBE Releases from Leaking Underground Storage
Tanks. Unpublished report.
Hagemann, M.F., and VanMouwerik, M., 1999. Potential W ate r Quality Concerns Related
to Snowmobile Usage. Water Resources Division, National Park Service, Technical Report.
VanMouwerik, M. and Hagemann, M.F. 1999, Water Quality Concerns Related to Personal Watercraft
Usage. Water Resources Division, National Park Service, Technical Report.
Hagemann, M.F., 1999, Is Dilution the Solution to Pollution in National Parks? The George Wright
Society Biannual Meeting, Asheville, North Carolina.
Hagemann, M.F., 1997, The Potential for MTBE to Contaminate Groundwater. U.S. EPA Superfund
Groundwater Technical Forum Annual Meeting, Las Vegas, Nevada.
Hagemann, M.F., and Gill, M., 1996, Impediments to Intrinsic Remediation, Moffett Field Naval Air
Station, Conference on Intrinsic Remediation of Chlorinated Hydrocarbons, Salt Lake City.
Hagemann, M.F., Fukunaga, G.L., 1996, The Vulnerability of Groundwater to Anthropogenic
Contaminants on the Island of Maui, Hawaii. Hawaii Water Works Association Annual Meeting, Maui,
October 1996.
Hagemann, M. F., Fukanaga, G. L., 1996, Ranking Groundwater Vulnerability in Central Oahu,
Hawaii. Proceedings, Geographic Information Systems in Environmental Resources Management, Air
and Waste Management Association Publication VIP -61.
Hagemann, M.F., 1994. Groundwater Characterization and Cleanup at Closing Military Bases
in California. Proceedings, California Groundwater Resources Association Meeting.
Hagemann, M.F. and Sabol, M.A., 1993. Role of the U.S. EPA in the High Plains States Groundwater
Recharge Demonstration Program. Proceedings, Sixth Biennial Symposium on the Artificial Recharge of
Groundwater.
Hagemann, M.F., 1993. U.S. EPA Policy on the Technical Impracticability of the Cleanup of DNAPL-
contaminated Groundwater. California Groundwater Resources Association Meeting.
8
Hagemann, M.F., 1992. Dense Nonaqueous Phase Liquid Contamination of Groundwater: An Ounce of
Prevention... Proceedings, Association of Engineering Geologists Annual Meeting, v. 35.
Other Experience:
Selected as subject matter expert for the California Professional Geologist licensing examination, 2009-
2011.
9
Friday, August 6, 2021 at 17:02:03 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR
Date: Friday, August 6, 2021 at 4:58:45 PM Pacific Daylight Time
From: Sally Arroyo
To: consultingplanner@laquintaca.gov
CC: Kimberly Cuza, Bob Arroyo
Dear Ms. Nicole Sauviat Criste, Consulting Planner, City of La Quinta:
Thank you allowing us again to be part of the process in assessing the suitability of the Coral Mountain Resort "The
Wave.
After reading through the entire DEIR carefully many times it is clearly apparent that although it seems that the
consulting firms and the City of La Quinta think they have done their due diligence with their studies, they failed to
consider the human factor --- their residents, their constituents and this beautiful area. They are apparently only
concerned with development, revenues and the allure of world-wide recognition.
We also found the alternative comparisons interesting in that based on the findings there really is only one
alternative and that is the alternative that the developer and the City of La Quinta want, The Wave Basin and Resort.
We also found that many of the findings were deemed "less than significant." This may be the standard
term/language used within the parameters of Federal, State, County and City study mandates, but we nearby citizens
and homeowners and our opinions are not less than significant and absolutely reject the conclusions of these
findings.
The developer purchased this property knowing the current zoning. Promises and projections were then made at
meetings held for local residents to drum up support for the project. Those who attended those meetings have
reported that they now feel they were misled. The words in some of the correspondence were "bait and switch." The
City of La Quinta appears to have bought into this bad idea and has gone along with it by moving to allow proposed
zone changes, special events and everything else that nearby homeowners find unacceptable. This development will
have no advantage for La Quinta residents who will not reside in the resort or use its amenities, only disadvantages
such as more traffic, more noise, more water usage from our aquifer, more light pollution, etc. It does feel like the
City and the developer are attempting to sell us on what we absolutely don't want. Let's reject the tourist commercial
zoning as well as this whole project.
In an era of massive climate change the City of La Quinta should still be asking the major question of where the water
would come from to sustain the resort. Surf parks require massive amounts of water and this resort will waste even
more. This is irresponsible. We have seen estimates of 18 million gallons to fill the pool. In addition, this project will
have to recover/refill water lost to evaporation that nearly equals the amount used to fill the pool. Add this to the
amount of water used by residents, guests and commercial establishments as well as the golf course. Golf courses
have the advantage of being able to use desertscaping and grey water for non -potable uses, resulting in less water
use. Also, the DEIR did not validly compare best water uses for golf courses. The surf park will not be using grey water
in their pool and while they should have a filtration system, that still does not lessen the water lost through
evaporation. CVWD recommends that two new wells be drilled. These wells would tap into our aquifer, which is not
being replenished fast enough so it is a finite resource that people living here desperately need. CVWD is not thinking
far enough into even the near future. Climate change is drying up the entire West. We need the aquifer to augment
receiving less river water. We have had recently two of our hottest days on record for the Coachella Valley.
Projections are that it is only going to get worse and this represents what is happening everywhere in the West.
The light comparison alleging that 17 extremely bright lights, strong enough for water safety and lighting up waves,
mounted atop 80 foot poles are similar to 17 palm tree landscape lights pointed up at tree trunks is fiction. Anyone
who has seen the difference will tell you that there is no comparison. Not only will these lights cause light pollution
for our area and obliterate any California and La Quinta dark sky ordinances, but the toll on wildlife such as bats,
night birds, night wildlife and migrating birds would be extremely harmful. These lights would be especially harmful
Page 1 of 2
because the resort borders the Santa Rosa and San Jacinto Mountains National Monument and "flying" wildlife will
continue to fly over this project area.
The sound study tries to minimize the impact of noise by asserting that Coral Mountain will absorb equipment noises.
But Coral Mountain covers a tiny part of the project perimeter so nearly all of the neighborhoods around the
development would get noise from surf -purposed loudspeakers that will be nearly always on and noise from planned
special events. The planned sound from the Wave Basin will travel throughout our corridor from 7:00 a.m. to 10:00
p.m. seven days a week and Coral Mountain will not absorb it. Then add in the sounds from the loudspeakers for the
surfing and for the events and there will be a constant barrage of noise. Combine that with traffic noise. Most of our
traffic is from maintenance workers going to and from work, weekdays early in mornings and afternoons. One cannot
really call our traffic scenario rush hour traffic. We also have a low level of 24-hour traffic from 58th and Madison and
occasional distant daytime target practice from the range near Lake Cahuilla. At night we get some traffic noise, but
while even that is irritating we are fortunate to hear mostly wildlife sounds. We have consistent traffic now which
increases during "The Season" but regardless with a development of this scale, our traffic and noise will be much
worse.
Medical studies have shown that exposure to noises, while subjective, is detrimental to one's health. This is especially
true for those who already suffer hypertension. Most older adults have high blood pressure and many of those who
own homes here are older. More noise and the stress related to the noise leads to a host of medical issues.
Simultaneous noise from different sources, like individual cars, crowds and loudspeakers can multiply many times by
factors of 10. Noise from all the separate sources from this project could increase total noise logarithmically, meaning
by factors of 10, on a constant daily basis, especially in evenings when we all love our desert quiet. Think of living
near a freeway and barely noticing noise made by a few cars versus the jet engine roar made by many cars. This is the
type of situation that this project could cause. It must be noted that this area is generally very quiet so even one
speeding car on 58th or Madison is grating. It would be totally unacceptable to spoil the general silence of the desert.
In the DEIR it was pointed out that there will be no property tax revenue to the City through 2035. Nothing about this
project will contribute to the enjoyment of life for the residents of La Quinta. What happens, if as one resident wrote,
this ends up being an empty hole in the ground and a failed development. We can see the headlines now "The City of
La Quinta Gem of an Empty Promise and a Concrete Hole." Word to the wise, think before you buy into this fad. If the
City of La Quinta wants the Wave Basin so badly then perhaps they should make arrangements to have the Wave
Basin at their SilverRock Resort.
We could go on and on but will stop here.
Thank you for your consideration.
Sally and Bob Arroyo
Coral Mountain Estates
57712 Salida del Sol
La Quinta, CA 92253
Page 2 of 2
Memo to: Nicole Sauviat Criste, Consulting Planner, City of La Quinta
Copies to: La Quinta City Council
TLQMA: Board of Directors
From: Fritz E. Bachli, Professor / Consultant of Global Economics and Environmental Science
Subject: Coral Mountain Wave Project / Draft EIR / Citizen Comment, Dead -Line: 8/6/2021
Date: August 6, 2021
Ladies and Gentlemen,
The following perspective on the "Wave Project" is based on my educational background in the
field of Environmental Sciences and thirteen years of living experience here at Trilogy. I am not
surprised about the many concerns residents are voicing in opposition to the "Wave Park"?
The City of La Quinta must be concerned about the environmental complaints which are piling
up at the City Hall? Even re -zoning appears not a welcoming answer to accommodate the
"Wave Park!" However, common sense reminds us: "If it's not a fit — leave it!" It's surprising
that the Project applicant has not been able to locate a suitable alternative location in our city
or elsewhere?
The purpose of zoning is simple. It is designed to ensure balanced communities. Zoning allows
the government to control development of the land and ensure the public is satisfied with their
community. The Draft EIR claims that improving community health is one of the priorities of city
government in order to sustain life which can be enjoyed by residents? If citizens believe it's
not a fit — the city hall should listen and not promote it!
Hopefully my contributions will support the NOPs (Notice of Preparation) filed by concerned
citizens.
Following are three key points taken directly from the Draft EIR which are of
major concern to me as a Trilogy Resident?
1. NOISE
-The project will not generate operational noise levels that have anv significant impact on anv
sensitive receptors including residents in the surrounding communities.
Areas in the vicinity of the planned project are repeatedly defined as "Golf Course and
Residential Communities!" Trilogy, perhaps other communities as well, belong to a category of
housing which is not recognized as such in the Draft EIR? Trilogy with 1238 homes, housing
approx. 2500 residents, existed long before the planned construction of a Wave Park! The City
Council of LQ should recognize that 55+ Communities are the choice for many aging people
who want to focus attention to their mental, emotional and physical wellbeing. These adults
enjoy the serenity of quiet neighborhoods. 55+ adults often decide that the value of time is for
elderly individuals the greatest asset that they possess. Disappointing enough, the Draft EIR
does not recognize the needs expressed by residents who selected a 55+ community?
Trilogy residents are accustomed to noise levels of approx. 30 dBA! It will literally be a "bad
awakening" when they must live in an environment where 60 to 80 dBA is defined as the new
normal! (Measuring Instrument: METERK / MK 09 / Sound Level Meter)
2. AIR QUALITY
The National Heart Association classified the Southern Californian Counties as some, if not the
worst, air quality regions in our nation!
-The Wave Park is seven miles of the 1-10 freeway. The site is found outside the designated
"blowsand" area but is still exposed to seasonal wind activities capable of producing fugitive
dust from undeveloped ground conditions?"
The Draft EIR is incomplete without reporting available Health Data documented in the annual
Eisenhower Hospital and Imperial County Health Assessments and Improvement updates? This
is a substantial oversight and a sign of ignorance towards the constituents exposed and
complaining about an ever-increasing air contamination problem in the area?
Fugitive dust readings on my own patio and tests conducted at locations of Trilogy residents
who are hypersensitive to dust and suffering from pulmonary diseases are often exposed to
PM -2.5 particles at a level of 31.0 mg/3 and in terms of PM -10 particles of 110.2 mg/m3.
(Measuring Instrument: Dylos 1700) Such levels can be compared with a very bad "hair day" in
Beijing / China! Elevated PM -10 and PM- 2.5 levels are associated with increases of asthmatic
conditions, increase in Emergency Room visits and increased mortality rates.
Air Quality Standards considered safe and obtained from AQMD are taken from monitoring
stations in Palm Springs 18 miles southeast from the project, the Indio station is 6 miles away
and the distance to Mecca amounts to 11 miles. Air quality is a very local phenomenon and
measurements taken miles away from the project are not representative of the actual situation
as it is occurring at the project site and at individual sites of sensitive receptors.
Special events, four times a year, with a daily expectancy of 2500 "Wave Park" guests,
thousands of visitors per year will unquestionably contribute to a further overload of
environmental conditions for the area right across the street from the Trilogy community!
Mobile measuring devices which provide immediate on-site particle readings are becoming
household items! Some time ago, I demonstrated to an AQMD team from the City Hall of La
Quinta during a visit to the Golf Course Perimeter a slide presentation and test methods I used
to measure PM -10 and PM -2.5 particle loads at the Trilogy community. They were surprised
about the immediate results with handheld high quality measuring devices and the accurate
readings when compared with fixed measuring stations.
-SCAQMD has the legal obligation to enforce air pollution regulations!"
From the moment a legitimate complaint is filed, and actions taken by the AQMD may literally
take weeks, months or even years. Very frustrating process which might have been improved
when compared in previous years?
-LST's (Localized Significance Threshold) limits were developed in response to environmental
justice and health concerns raised by the public regarding the exposure to individuals to
criteria pollutants in local communities.
Is Trilogy qualifying for such an exemption?
3) WATER
--The Wave Park could result in cumulatively significant impacts to water supplies and
infrastructure if not reviewed by the City and CVWD?
I wish there would be more concrete definition in the (Draft EIR) like this one. An eye opener
for ordinary residents without in depth knowledge in the field of water issues!
A surfer confessed to me that Wave Parks are fun. But pulling ground water especially in the
desert and deleting aquifers is against all common-sense Environmental principles. Such water
is not being used to benefit a society. It's being used for middle, upper financial elite classes
for leisurely escapism. AKA a vacation while the world burns, farm animals have to be
slottered due to lack of food and water. The greenhouse effect takes its tall!
CONCLUSION/ REASON:
Fugitive Dust from Project Site to Trilogy
Dylos Particle Meter / Model 1700
THE PROJECTED WAVE PARK IS NOT A PLANNED COMMUNITY THAT COMPLIMENTS EXISTING
DEVELOPMENTS IN THE SURROUNDING AREA AND IS CONTRIBUTING TO THE ALREADY
EXISTING ENVIRONMENTAL OVERLOAD IN THE SURROUNDING ENVIRONMENT.
Friday, August 6, 2021 at 16:10:47 Pacific Daylight Time
Subject: Opposition to the DEIR of the Coral Mountain Resort
Date: Friday, August 6, 2021 at 4:03:28 PM Pacific Daylight Time
From: Ramon Baez
To: consultingplanner@laquintaca.gov
CC: kellymbaez@gmail.com
Attachments: MORE RE: In opposition of a Wave park a Coral Mountain.eml, Wave Park Development at
Coral Mountain .eml
Reference: email from Ramon Baez dated 3/10/2021 (attached); email from Mr. Rob
Michiels dated 7/21/2021 (attached)
Dear Ms. Sauviat Criste,
As I stated in the attached referenced email dated March 10, 2021, we enjoy the
tranquility and serenity of the Andalusia Country Club. Prior to the scoping meeting,
we were opposed to this project and now after a careful review of the DEIR and having
discussions with the developer representatives we are even more opposed to many
facets of this project. We believe it will be incompatible to the 2035 General Plan and
the culture of the community within the South East La Quinta area. We actually do
not believe it is compatible to any residential area of the Coachella valley.
We are not NIMBY type people. My wife and I are big supporters of development but
it needs to be compatible to the overall community and provide value to the overall
community. We believe that this project will have a significant negative impact to the
overall environment with everything we have read from a traffic, noise and light
pollution. By rezoning this area to tourist commercial, we will no longer have a similar
community adjacent to us but will have a Surf Amusement Park with planned surf
festivals and tournaments several times a year. We are sure that there is not one
planned community in the La Quinta area that would want such a project to be
erected adjacent to them.
We respectfully request that the Planning Commission and the City Council not
approve the rezoning being requested by the developers to allow the construction of
the Wave Basin and providing them the ability to build 750 STVRs in the middle of a
low-density residential area which are truly neighborhoods.
My fellow Andalusia resident, Mr. Rob Michiels, submitted questions concerning the
DEIR (see attachment dated July 21, 2021) that we believe need to be answered for all
of us that are very concerned about this very complex project.
Sincerely,
Page 1 of 2
Ramon and Kelly Baez, Resident
81245 Andalusia La Quinta, CA 92253
Page 2 of 2
Friday, August 6, 2021 at 16:11:19 Pacific Daylight Time
Subject: MORE RE: In opposition of a Wave park a Coral Mountain
Date: Wednesday, July 21, 2021 at 3:46:48 PM Pacific Daylight Time
From: Rob Michiels
To: Consulting Planner
CC: Ria Michiels, Mike Charles, Ramon Baez, Igresidentsstopthewave@gmail.com,
drebryna@telusplanet.net
Dear Ms Sauviat Criste,
I would like to remind the City leaders that the 2035 La Quinta General Plan is the (long) existing plan for our
communities. This plan was supposed to be legally binding and now it appears that the City mayor and council are
going to use loopholes to invalidate it?
I would also like to add to my previous comments (email dated 07/20/21) by adding the following specific questions
that need to be addressed by the review process:
1. First, the legal record should clearly reflect that this proposed development is not in compliance with the
existing 2035 zoning plan for La Quinta.
a. Why does the City even consider this project?
b. To clarify the process, the city should provide its residents with a written and public justification of its
intent, so that there can be no misunderstanding of facts, history and responsibilities if the future
brings lawsuits.
c. The rezoning process requires a rigorous investigation of all factors and a specific justification of
communal benefits. The current reports submitted by the developer are anything but that.
d. Neutrality of reporting is paramount. So why are these not 3rd party studies, instead of experts hired
by the developer?
e. DEIR documents are meant to be read and understood by the average person and are supposed to
follow a specific format and size requirement. The currently submitted documents are anything but
that and are full of vague and subjective language, which of course is not inconsistent with having
been written by people being paid by the developer. Why can the City not commission new studies
and reports from non -conflicted independent experts?
2. The City is being asked to rezone based on grounds of (doubtful) benefits and (undefined) developer
promises to local government officials (DEIR 3-18).
a. This proposed amusement park is private. How does that benefit La Quinta residents?
b. This proposed development is focused on short term rentals and also features fractional ownership
formulas. How does that reconcile with the nature of the surrounding residential developments?
c. Most cities are fighting against short term rentals nuisances. Why would La Quinta be intent on
promoting such activities, instead of focusing on the needs of long-term residents?
d. This proposed development aims to operate 365 days a year from 7AM to 10PM with corresponding
traffic noise, operating noise (wave equipment noise, wave noise (roar), announcement/alarm noise,
music noise, etc...) (DEIR 1-29, 4.11-15, 4.11-47, 4.11-49)
i. Why are the reports not investigating each one of these noise categories individually?
ii. Why are the reports not investigating all of these noise categories combined?
iii. Why are the reports relying solely on theoretical noise models?
iv. Why are the reports allowed to use and extrapolate data from other non -identical facilities?
v. Why are the developers not asked to execute real-time and real-life noise experiments (for all
noise sources individually and cumulatively) within the affected communities?
vi. Why is everyone studiously ignoring the impact during construction over a number of years,
especially since the developer is projecting and requesting "open timing" for completion?
vii. How can the City accept the unrealistic and unscientific argument that a "mountain absorbs
noise"?
e. This proposed development aims to operate 365 days a year from 7AM to 10PM with corresponding
Page 1 of 5
light pollution from a number of proposed new light sources (DEIR 4.1-41, 4.1-39, 4.1-57, 4.10-28)
i. Why are the reports not investigating each one of the possible light sources individually?
ii. Why are the reports relying solely on theoretical light pollution models?
iii. How can a report that states "insignificant" impact from 80ft light poles be considered bona
fide? No refereed technical explanation or justification is provided in the report. Please
justify why such a glaring oversight should not be rectified and a new independent report
commissioned?
iv. How can the City accept the unrealistic and unscientific argument that "light will not
significantly reflect off water"?
v. Why would the developers be allowed an exemption (for 80ft) from the current municipal code
which allows only 8 ft pole heights for this type of use?
vi. Why are the developers not asked to execute real-time light impact experiments (for all light
sources individually and cumulatively — especially the two third mile long 80 ft poles every
20 ft along the basin) within the affected communities?
vii. Why should there not be an independent study of project light impacts on the surrounding
communities?
f. This proposed development aims to exceed the current permissible height specs of the municipal
code for various structures (DEIR 4.1-57, 4.1-12, 4.1-13).
i. Why do the current reports not address such structures individually and specifically?
ii. How can loss of mountain view by numerous surrounding residential developments not be
considered a substantial objection to this proposed project?
iii. How serious can you take a report that states that "vegetation is not permanent as it can
change form or be removed" as part of the argumentation that view loss is not an
applicable argument in this case? How can the City possibly accept this type of rationale
without further thought or question? Why should there not be an independent study of
impacts on the surrounding communities?
iv. At some point the report states: "However, impacts associated with scenic vistas cannot be
reduced to less than significant levels and will remain significant and unavoidable." (DEIR
4.1-45). How can this be deemed acceptable as an argument to support a zoning
change?
g. This proposed development will create potentially significant environmental impacts due to wasteful,
inefficient or unnecessary consumption of energy resources (DEIR 1-22) and will increase demand for
energy in the service areas of IID and SoCal Gas Co (DEIR 4.5-34). The developer admits that project
specific impacts to greenhouse gas emissions will be significant and unavoidable (DEIR 1-13).
i. How can the City justify a zoning change given these negative environmental facts?
ii. La Quinta residents are already being asked on a regular basis to conserve energy during
heat waves. How will the energy consumption of this project specifically impact the
surrounding communities?
iii. The EIR small print states that the developer will purchase vast amounts of carbon credits.
How can the City possibly believe, or prove, that this is a beneficially "green" project?
h. This proposed development will require massive amounts of hazardous chemicals that will be used
and stored on site (DEIR 4.8-18).
i. Nowhere in the reports is there any substantial or specific explanation of usage, storage or
safety measures. Local residents demand to know all risks as detailed in an independent
study.
ii. Available chemical treatments will not be sufficient during very hot summer months to provide
adequate protection from microscopic amoeba in the over -warm water. The developer has
stated the water will not be cooled during summer, hence this health risk is currently not be
mitigated:
• Who will be liable if/when brain (amebic meningoencephalitis) infections occur?
• Will the City (and thus ultimately residents) end up footing the bill after being sued by a
dead surfer's family?
• How will the developer specifically mitigate this issue?
2. Local community home values are likely to be negatively impacted by this development if it proceeds. Will
Riverside County reduce the property tax basis for the affected homeowners when that happens?
3. The developer is going to request separate permissions for mass events (DEIR 1-7).
a. How will noise violations during Special Events be enforced by the City and what process will be
Page 2 of 5
used?
b. How will illegal behavior during Special Events be monitored and mitigated?
c. Substantial additional traffic impact (including local gridlock for Trilogy and Andalusia) will be felt by
local residents. Why will the City not commission an independent study?
d. How will unavoidable large crowd litter/trash generation immediately outside the park boundaries be
monitored and mitigated?
e. Will the developer be asked to cover all additional City service expenses (law enforcement, medical
response, fire, road repair, traffic signalization)?
f. If events are allowed to occur, will the City limit such individual event permits to maximum 2 per year?
4. California is experiencing a severe drought. For years (and continuing) we are all trying to conserve water.
This project will require millions of gallons of potable water every year. Looking at DEIR 4.10-19, 1-27, 1-36,
4.10.20, 4.15-29, 4.15-34 (and I am probably missing a few) a number of questions arise.
a. The developer's own estimates project water usage within a "4% or so" margin. What happens when
they go over the contract allotted numbers? Can they just buy unlimited additional gallons?
b. The developer reports having a contract already for potable water from our local aquifer. How can the
local water company be allowed to execute such a wasteful contract when public water reserves are
already under tremendous pressure.
c. The argument that this project uses less water than a golf is invalid because golf course operations
now mostly use recycled (gray) water. Why can the developer not be required to use recycled water?
d. Is the City conscious of the fact that with rising population numbers the water wasted on this project
are going to be needed in the very near future?
e. The developer's reports on water usage are incomplete and rather less than scientifically justified.
Why does the City not request very detailed and scientifically/technically justified and independently
generated information regarding evaporation, specific water usage patterns for individual elements of
the project facilities, detailed wave pool maintenance requirements?
5. The traffic analysis submitted reflects middle of the COVID pandemic activity between November 2019 and
October 2020. This analysis mis-represents the actual anticipated traffic reality. (DEIR 4.13-42)
a. The impact on local residents will be large. Why will the City not commission an independent study at
the developer's expense?
b. What considerations are in place for possible (new) public or private bus transportation to the
development? Has a detailed study been submitted?
c. What considerations are in place for queue locations for taxi, Uber, Lyft, etc? Has a detailed study
been submitted?
Respectfully submitted,
Rob & Ria Michiels-Denayer
81301 Andalusia
La Quinta, CA 92253
Rob Michiels
Founding Partner
CONSILIUM Associates LLC
Cell +1 949 677 4165 (No Texting)
Email RMichiels@consiliumassociates.net
This message is intended only for the use of the individual or entity to which it is addressed, and may contain
information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this
message is not the intended recipient, or the employee or agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or
return e-mail. Thank you, CONSILIUM.
Page 3 of 5
From: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Sent: Wednesday, July 21, 2021 9:24 AM
To: Rob Michiels <rmichiels@consiliumassociates.net>
Cc: Ria Michiels <michiels.ria@gmail.com>; Mike Charles <mgacharles@yahoo.com>; Ramon Baez
<rfbaez7@gmail.com>
Subject: Re: In opposition of a Wave park a Coral Mountain
Mr, Michiels,
Thank you for your comments.
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
From: Rob Michiels <rmichiels@consiliumassociates.net>
Sent: Tuesday, July 20, 2021 4:24 PM
To: Consulting Planner <ConsultingPlanner@laquintaca.gov>
Cc: Ria Michiels <michiels.ria@gmail.com>; Mike Charles <mgacharles@yahoo.com>; Ramon Baez
<rfbaez7@gmail.com>
Subject: In opposition of a Wave park a Coral Mountain
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.
Good afternoon and thank you for allowing me to voice my strong opposition to this
project.
My wife and I have been homeowners at Andalusia for the past 11 years. I believe I am
also speaking on behalf of many of my neighbors.
We joined this beautiful Andalusia community because:
We love the peace and quiet;
We love the immaculately dark and clear night skies;
We were told the patch of wild and untamed desertscape across from us would
eventually be developed into a similarly quiet and uncrowded golf/low density residential
community.
So, imagine our dismay when that property was sold to another developer, who has
quickly, and under the radar, moved to change the zoning from low density residential to
high impact commercial.
We do not understand why the city of La Quinta would have given the initial permission
for that zoning change so this ill-conceived project could move forward to this stage of
planning?
Do our city leaders really want to tie their political legacy to the desecration of one of the
Page 4 of 5
last truly unique and peaceful tracts of La Quinta land by unscrupulous developers who
want to change it into a circus like attraction every day all year round? Why go forward
and spend untold dollars on investigations when any person with common sense knows
this can and should be stopped right now by the city simply holding fast to the original
zoning?
Why waste millions of gallons of drinking water when we are in the midst of a drought?
The so-called expert reports submitted in support of this project are at best theoretical
re -do's of earlier reports (from other projects). No real science or experiments are
behind these reports.
Is the only underlying agenda that wants to allow this permitting process change the
pursuit of a few extra dollars promised for city coffers?
If you go forward, I believe future generations will not look kindly on your legacy.
Thank you for your consideration.
Rob & Ria Michiels-Denayer
81301 Andalusia
La Quinta, CA 92253
Rob Michiels
Founding Partner
CONSILIUM Associates LLC
Cell +1 949 677 4165 (No Texting)
Email RMichiels@consiliumassociates.net
This message is intended only for the use of the individual or entity to which it is addressed, and may contain
information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this
message is not the intended recipient, or the employee or agent responsible for delivering the message to the
intended recipient, you are hereby notified that any dissemination, distribution or copying of this communication is
strictly prohibited. If you have received this communication in error, please notify us immediately by telephone or
return e-mail. Thank you, CONSILIUM.
Page 5 of 5
Friday, August 6, 2021 at 16:11:38 Pacific Daylight Time
Subject: Wave Park Development at Coral Mountain
Date: Wednesday, March 10, 2021 at 7:32:39 PM Pacific Standard Time
From: Ramon Baez
To: consultingplanner@laquintaca.gov
CC: kellymbaez@gmail.com
Attachments: Andalusia Backyard Southen West view .jpg, Public Notice - Coral Mountain Resort NOP.pdf,
Coral Mountain Resort Notice of Preparation Document.pdf
Attn: Nicole Sauviat Criste, Consulting Planner
City of La Quinta, CA
Re: Coral Mountain Resort Amendment V
Dear Ms. Criste,
My name is Ramon F. Baez, a homeowner at Andalusia Country Club for over 4 years.
My wife, Kelly and I fell in love with the ambience of Andalusia the moment we drove through the
gates in July of 2016. We are here now a good part of the year and we love the peaceful quiet, and
beautiful canopy of stars that we enjoy each evening. The views of the Coral Mountains in the
foreground of the Santa Rosa Mountains, coupled with the serene beauty and quiet of the desert sky
is a true natural marvel.
I am not a fan of the Wave Park development on many levels, but most significantly I am concerned
about the light pollution from the 80' towers that would spoil the night sky in this area. This would
ruin the tranquil desert evenings. I have attached a view from our backyard and it would have a
deleterious effect to this lovely view, especially at night. It would be like having a high school football
stadium built adjacent to us and would be like having Friday night lights every night of the week.
The City has prudently required an Environmental Impact Report be prepared in compliance with
CEQA guidelines. I respectfully request that the public comment period for this development be
extended to at least 30 days from receipt and distribution of the EIR so everyone can assess the impact
this project will have on all our dear friends and neighbors at Andalusia and surrounding communities.
Thank you for your consideration.
Kind Regards,
Ramon and Kelly Baez
81-245 Andalusia
La Quinta, CA 92253
Page 1 of 1
S:Ei'iP
A T TOR NE YS
August 6, 2021
Via Email & U.S. Mail
Jon McMillen (jmcmillen@laquintaca.gov)
City Manager, City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Cheri Flores (clflores@laquintaca.gov)
Planning Manager, City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Nicole Sauviat Criste (ConsultingPlanner@laquintaca.gov)
Consulting Planner, City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
BRUCE T. BAUER
ATTORNEY
ADMITTED IN CA
REPLY To:
1800 E. Tahquitz Canyon Way
Palm Springs, California 92262
T (760) 322-2275 • F (760)
322-2107
bauer@sbemp.com
RE: The Wave Festival Project / Comments to Draft Environmental Report
Dear Mr. McMillen, Ms. Flores and Ms. Criste:
Our office represents residents in the City of La Quinta (City), La Quinta Residents for Responsible
Development (LQRRD), who are rightfully concerned about the development of a proposed project
within the City that portends fundamental changes in the character of the City. That proposed project,
described below, is the subject of a Draft Environmental Impact Report, SCH# 2021020310, prepared
by MSA Consulting Inc. (DEIR). Please consider the enclosed comments with respect to that DEIR
and consider, in particular, the concerns we have raised concerning the issues of traffic, noise, air
quality, water, and the Applicant's request to amend the City's General Plan.
I. THE PROPOSED WAVE FESTIVAL PROJECT
The subject of the DEIR is a proposal to be build an enormous development on land that is currently
slated in the City's General Plan for low-density residential development. The existing local area is
characterized by developed golf course and residential communities to the north, west, east, and
southeast, the Santa Rosa Mountains to the west and south, Monroe Street and vacant and agricultural
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 2
lands to the east, and open space to the south. (DEIR, p. 14, Section 1.2.1.) The area is in keeping,
then, with what most people expect in the residential areas of a beautiful desert city in the Coachella
Valley: (1) low density; (2) quiet; (3) low traffic; and (4) unencumbered mountain vistas that are
illuminated by the stars at night.
Instead of this low-density, and low-key, development that residents of the City were told would be
developed nearby, The Wave Development, LLC (Applicant), proposes a large-scale commercial
enterprise, replete with recurring festivals, that includes a 150 -room hotel and 600 residential units
(all of which will be permitted to have short -terms rentals). As part of this project, the focal point
of all of these short-term rental units will be an enormous 18 million gallon, 16 -acre, artificial surf
basin that will have artificial waves generated by a large locomotive -like engine. This wave basin will
be, in turn, illuminated with 80 -foot light towers, lighting up the darkened desert night sky, encircling
the basin. Additionally, Applicant proposes, as part of the Wave Festival Project, large scale
commercial development including, separately, 57,000 square feet and 60,000 square feet of
commercial uses. DEIR, p. 67, Section 2.51. The project will be referred hereinafter to the "Wave
Festival Project."
The Wave Festival Project's wave basin will be the focal point of a parade of at least four (4) events
a year of a four-day duration. As indicated by Applicant, there will be four (4) entertainment/special
events (of four (4) days duration or 16 days and nights of special events per year) (the "Special
Events.) Each day of these Special Events might easily bring in thousands of visitors per day (with
each such event the Applicant would be permitted to have 2,500 guests per day — this would be in
addition to the guests that are staying at the resort's villas and hotel, myriad employees and vendors
attending to all those guests, and does not include the days that will be needed for staging and
dismantling of each of the Special Events.)
1 In the DEIR it references these short-term rentals at p. 117: "Ownership and occupancy of these
units may include primary, secondary and fractional ownership, along with short term vacation
rentals." (See, DEIR at p. 117.) These short-term rentals are only mentioned four times in the 738 -
page DEIR document. Even then the impact of these short-term rentals is not studied. Rather, the
DEIR mentions that "potential increase of traffic as a result of the resort use and allowance of short-
term rentals at the project; ... " (See, DEIR, at p. 26.). The allowance for these short-term rentals is
further spelled out, at page 6, of the Coral Mountain Resort — Development Agreement Developer's
Proposed Terms For Amendment:
"Analysis completed by the City, short term vacation rentals will be an allowable use in
all planning areas within the Project, consistent with the recently enacted provisions in
the LQMC, § 3.25.055."
2 https://www.desertsun.com/story/news/local/la-quinta/2020/02/26/kelly-slater-surf-technology-
part-of-proposed-la-quinta-coral-mountain-development/4884466002/
Palm Springs, CA
T (760) 322-2275
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 3
Applicant then is seeking permission to allow approval of the Wave Festival Project with an enormous
amount of overnight guests in excess of 4,000 per night ((one can estimate that it might have 600
overnight guests for its planned 150 -room hotel (4 pillows per room x 150 rooms), plus 3,600
overnight guests for the planned 600 -villas (averaging 3 bedrooms each, 6 pillows X 600=3,600
overnight)), for a total over 4,000 overnight guests coming and going. There will then also be the
2,500 allowed visitors coming and going. The Wave Festival Project then promises to bring
significant changes to the City and its surrounding and adjoining communities compared to what was
previously approved for this area. Naturally, a project of this nature, that will continue to morph and
increase exponentially, should be given additional scrutiny.
The proposed Wave Festival Project is both out of scope of the nature of its proposed setting as set
forth in the City's General Plan as discussed below. The enormity of this request, and the scale of
change from the City's existing land use designation for the proposed site, is evidenced by the fact
that Applicant is seeking an extraordinary number of approvals including as follows:
(1) a General Plan Amendment (GPA 2019-0002);
(2) Zone Change (ZC 2019-0004);
(3) Specific Plan (SP 2020-0002);
(4) Tentative Tract Map (TTM 2019-0005);
(5) Site Development Permit (SDP 2021-0001); and,
(6) a Development Agreement (DA 2021-0002).
It is clear that the Wave Festival Project bears NO relationship to the development that had been
originally entitled for that area. The Wave Festival Project is not akin to a low-density golf -
centered master -planned community. No one can seriously contend such. The Wave Festival
Project is, in reality, a commercial entertainment -based venue endeavor and not a residential
development. The Wave Festival Project will be comprised of a commercial /high-density project
that will cause far more impact on the surrounding communities that could ever have been
conceived in prior entitlements and is being severely understated by the Applicant so that approval
can be obtained. The quiet and serene atmosphere currently enjoyed by the City's residents will
forever be destroyed. As such, we do not believe the Wave Festival Project, as proposed, should
move forward with the City, as analyzed, since it is not in keeping with the character and
entitlements envisioned by the City and its residents. However, should the City consider the Wave
Festival Project it must do so under only the most exacting review standards.
II. CEQA AND LEGAL REQUIREMENTS.
The California Environmental Quality Act (CEQA) requires state and local government agencies to
inform decision makers and the public about the potential environmental impacts of proposed
projects, and to reduce those environmental impacts to the extent feasible. CEQA requires that an
agency analyze the potential environmental impacts of its proposed actions in an environmental
impact report (`BIR") (except in certain limited circumstances). See, e.g., Pub. Res. Code § 21100.
Palm Springs, CA
T (760) 322-2275
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Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 4
The EIR is the very heart of CEQA. (Dunn -Edwards v. BAAQMD (1992) 9 Cal.App.4th 644, 652.)
"The `foremost principle' in interpreting CEQA is that the Legislature intended the act to be read so
as to afford the fullest possible protection to the environment within the reasonable scope of the
statutory language." (Comms. For a Better Env 't. v. Calif. Resources Agency (2002) 103
Cal.App.4th 98, 109.)
CEQA has two primary purposes. First, CEQA is designed to inform decisionmakers and the public
about the potential, significant environmental effects of a project. (14 Cal. Code Regs. §
15002(a)(1).) Its purpose is to inform the public and its responsible officials of the environmental
consequences of their decisions before they are made. Thus, the EIR `protects not only the
environment but also informed self-government.' (Citizens of Goleta Valley v. Board of
Supervisors, supra, 52 Ca1.3d at 564.) The EIR has been described as "an environmental `alarm
bell' whose purpose it is to alert the public and its responsible officials to environmental changes
before they have reached ecological points of no return." (Berkeley Keep Jets Over the Bay v. Bd. of
Port Comm'rs (2001) 91 Cal.App.4th 1344, 1354; County oflnyo v. Yorty (1973) 32 Cal.App.3d
795, 810).
Second, CEQA requires public agencies to avoid or reduce environmental damage when "feasible"
by requiring "environmentally superior" alternatives and all feasible mitigation measures. (14 Cal.
Code Regs. § 15002(a)(2) and (3); see also Berkeley Keep Jets Over the Bay, supra, 91 Cal.App.4th
1344, 1354; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Ca1.3d 553, 564.) The EIR
serves to provide agencies and the public with information about the environmental impacts of a
proposed project and to "identify ways that environmental damage can be avoided or significantly
reduced." (14 Cal. Code Regs. § 15002(a)(2).) If the project will have a significant effect on the
environment, the agency may approve the project only if it finds that it has "eliminated or
substantially lessened all significant effects on the environment were feasible" and that any
unavoidable significant effects on the environment are "acceptable due to overriding concerns."
(Pub. Res. Code § 21081; 14 Cal. Code Regs. § 15092(b)(2)(A) and (B).)
The DEIR that has been submitted is 738 -page document that has not afforded the public a
reasonable manner to decipher it, nor has it properly analyzed the Wave Festival Project for a
myriad of reasons as discussed below.
III. THE DEIR FAILS TO ADEQUATELY DISCLOSE, ANALYZE, AND MITIGATE
ALL POTENTIALLY SIGNIFICANT IMPACTS.
As discussed below, and in the attached expert comment letters of traffic (comment letter dated
August 3, 2021) and sound (comment letter dated August 2, 2021) experts, Minagar & Associates,
Inc., the DEIR fails to adequately analyze and mitigate the Wave Festival Project's impacts.
CEQA requires that a lead agency analyze all potentially significant environmental impacts of its
proposed actions in an EIR. (Pub. Res. Code § 21100(b)(1); 14 Cal. Code Regs. § 15126(a);
Palm Springs, CA
T (760) 322-2275
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 5
Berkeley Keep Jets Over the Bay, supra, 91 Cal.App.4th at 1354.) The EIR must not only identify
the impacts but must also provide "information about how adverse the impacts will be." (Santiago
County Water Dist. v. County of Orange (1981) 118 Cal.App.3d 818, 831.) The lead agency may
deem a particular impact to be insignificant only if it produces rigorous analysis and concrete
substantial evidence justifying the finding. (Kings County Farm Bureau v. City of Hanford (1990)
221 Cal.App.3d 692.)
While the courts review an EIR using an "abuse of discretion" standard, "the reviewing court is not
to `uncritically rely on every study or analysis presented by a project proponent in support of its
position. A `clearly inadequate or unsupported study is entitled to no judicial deference.' (Berkeley
Keep Jets Over the Bay, supra, 91 Cal.App.4th at 1355, quoting Laurel Heights Improvement Ass 'n
v. Regents of Univ. of Cal. (1988) 47 Ca1.3d 376, 391, 409, fn. 12.) A prejudicial abuse of discretion
occurs "if the failure to include relevant information precludes informed decision-making and
informed public participation, thereby thwarting the statutory goals of the EIR process." (San
Joaquin Raptor/Wildlife Rescue Center v. County of Stanislaus (1994) 27 Cal.App.4th 713, 722;
Galante Vineyards v. Monterey Peninsula Water Mgmt. Dist. (1997) 60 Cal.App.4th 1109, 1117.)
A. Traffic Impacts Have Not Been Adequately Analyzed or Mitigated.
Traffic impacts have not been adequately analyzed or mitigated in the DEIR. The DEIR greatly
understates traffic counts. It is well known that festivals of the nature that the Applicant proposes
with the Special Events bring in large crowds. Given the short-term rental nature of the residences
to be constructed, it is likely they will be densely occupied during those timeframes. Therefore, the
reliance on existing data of traffic counts is not reliable and trustworthy information. In normal
developments in the City, many neighborhoods are thinly occupied because they are often second
homes. Therefore, data utilizing existing traffic counts only reflect that sort of development.
However, the development sought in connection with the Wave Festival Project should more
closely be attuned to traffic counts for like developments (here a commercial entertainment
development) and particularized times of the year such as when festivals such as Coachella and
Stagecoach occur. Also, the DEIR has not considered when the Special Events will occur. The
timing of the Special Events is especially important given other busy events that occur during the
calendar as pointed out above.
Traffic counts utilized in the DEIR include Thursday, August 15, 2017, Tuesday, April 9, 2019,
Tuesday, May 7, 2019, and Tuesday, September 10, 2019. These counts were not taken during
either during the busiest part of the year, for City residents, i.e., the "High Season" in the middle of
the winter months when snowbirds have returned to the City (from October through March.) Those
more realistic dates should have been utilized to conduct a meaningful traffic analysis. The base
traffic volumes used in the analysis are therefore an underestimation of the actual volumes.
As opined by Minagar & Associates in their comment letter of August 3, 2021 (see, Exhibit 2
hereto), the analysis contained in the DEIR is also defective in several key respects:
Palm Springs, CA
T (760) 322-2275
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J
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 6
For a large mixed-use of the size contemplated by the Wave Festival Project,
utilization of traffic counts from Thursday, August 15, 2017, Tuesday, April
9, 2019, Tuesday, May 7, 2019, and Tuesday, September 10, 2019 is not
prudent. Current traffic counts could have been easily taken right after the
scoping agreement on February 12, 2020, and before the start of COVID-19
pandemic on March 15, 2020. It goes without saying that the traffic volumes
are the foundation of every traffic impact study. Once their validity is
questioned, then the public trust is eroded.
For the trip generation estimation for the Special Events during weekends,
since the national ITE Trip Generation Manual does not provide the required
rates, why surveys of similar facilities weren't used to establish the rates?
Why for the 2,500 -Guest Wave Basin Facility, the old trip generation rates
from SANDAG Manual for a recreation park (developed) from over 20 years
ago was used to generate new traffic estimates? Surveys of similar facilities
could have been performed.
There are a number of discrepancies among the land use sizes of The Wave
Basin Facility, The Wave Village, The Farm and related uses for the purposes
of trip generation calculations in different reports.
For the claimed VMT mitigation reductions, the specific source and category
from the State of California's CAPCOA Manual must be documented for
verification.
B. Water Supply Impacts Have Not Been Adequately Analyzed or Mitigated.
The seriousness of the state's water concerns means that large-scale projects like this in the middle
of the desert must be carefully planned to ensure adequate supplies of water, even in times of severe
drought. Cities and counties are required to verify that adequate long-term water supplies exist for
large development projects. (Water Code § 10910; Gov. Code § 66473.7.) These laws, working in
conjunction with CEQA, force municipalities to consider how they will supply water to new
projects. Thus, when an agency considers a detailed project proposal that would require additional
water, the public must have an opportunity to consider, in a detailed EIR, the project's water supply
and mitigation measures and alternatives that would lessen the related impacts. (Pub. Res. Code §
21093(a); 14 Cal. Code Regs. § 15152(a) -(c).) This detailed analysis is referred to as a Water
Supply Assessment ("WSA").
Water supply for the proposed project would be provided by the Coachella Valley Water District
(CVWD). (DEIR, at 4.9-19.) Coachella Valley relies on groundwater for its primary supply sources.
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Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 7
(DEIR, at 4.9-19.) The proposed project is expected to consume approximately 958.63 -acre feet per
year (AFY), which equates to an alarming 312,163,558 gallons of water per year. (DEIR, at 4.9-
19.) The DEIR vaguely states without any details that the groundwater basin can meet the water
demands of the Coachella Valley for extended normal and drought periods. (DEIR, at 4.9-28.)
However, the WSA admits repeatedly that the Coachella Valley relies on groundwater for its
primary supply source, and that "the amount of water in the acquifer has decreased over the years
due to heavy pumping to serve urban, rural and agricultural development in the Coachella Valley,
which has withdrawn water from the aquifer at a rate faster than its natural rate of recharge." (WSA,
p. 30.) The solution has been to import the majority of the water supply, primarily from the
Colorado River. This is not a sustainable model as Californians have acutely learned over the last
decade of drought -like conditions.
Coachella Valley's water conservation plans rely on source substitution with the Colorado River,
but the Colorado River is also experiencing historically low levels and drought conditions.
Countless other communities also rely on the Colorado River as a water source, so this practice is
not sustainable in the long term. In fact, the WSA only analyzes and accounts for the water supply
for the next 20 years, which is relatively soon. (DEIR, at 4.9-28.) With exponential population
growth expected, and the continuing effects of climate change, this analysis needs to account for a
much longer period.
Recent climatic developments, and the increasing impact of drought in the State and in the Western
state, especially an historic drought in the Colorado River basin of 20 years, demand that the City
not review water usage with "business as usual" calculations. See, e.g., California water regulators
took unprecedented action this week, passing an emergency regulation that will bar thousands of
Californians from diverting stream and river water as the drought worsens.
(https://www.latimes.com/california/story/2021-08-04/california-drought-water-restrictions-how-
bad-is-it ). Elsewhere, in the Colorado River basin, water levels in the water reserves held by Lake
Powell and Lake Mead, two of the US's largest reservoirs that both sit along the Colorado River
relied upon more than 40 million (including the Coachella Valley) are at record lows3.
https://www.popsci.com/science/lake-mead-lake-powell-drought/
As set forth above, the Wave Festival Project (even with water conservation measures) would have
a total water demand of 958.63 acre-feet per year (AFY). It is important to note that the DEIR fails
to equate the AFY by gallons of water per year. This was done purposefully. It does not want the
public to know just how many gallons of water this project will use on a yearly basis. Projects that
allow for 312,163,558 gallons of wasted resources should not be permitted to put pressure on
3 Lake Powell, which stretches along Utah and Arizona, dropped to 3,554 feet this week—the
lowest depth since its initial filling in the 1960s. Lake Mead, the nation's largest reservoir by water
capacity, is also at its lowest level since it was filled in the 1930s. It's currently at a depth of 1,067
feet, holding just one third of its potential capacity.
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already declining aquifers. This is especially true when the climate crisis is creating an uncertain
future where sustainability and demand on aquifers are getting harder and harder to predict.
C. Noise Has Not Been Adequately Analyzed or Mitigated.
Noise pollution, like air pollution, has significant health implications. In analyzing the Wave
Festival Project, Applicant has utilized its existing wave facility in Lemoore, California as a
barometer of certain issues including noise. (See, DEIR at p. 4.11-45.) For example, Applicant
states as follows:
Additionally, the noise expert stated that agricultural fields and desert floors are
considered soft surfaces for the purposes of sound propagation. Additionally, the
noise expert stated that Coral Mountain is likely to absorb, rather than reflect noise
back towards sensitive receiver locations. Only hard surfaces, such as pavement,
would change the sound attenuation characteristics of the project. In addition, the
worst - case reference noise level conditions were taken during peak wave noise
events at 12 feet, as stated above, whereas Coral Mountain is located approximately
650 feet from the Wave Basin. The reference noise level measurements themselves
do not include any sound attenuation for the agricultural fields. Therefore, although
the proposed project is located on the desert floor and adjacent to Coral Mountain,
the noise measurements from the Lemoore site provide an accurate comparison of
noise levels to occur at the project site. Id.
The absurdity of the suggestion that conditions of the Lemoore facility could be likened to the
proposed site of the Wave Festival Project can be seen clearly in an aerial photograph of that
facility:
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The Lemoore facility is in a rural, agricultural area that is devoid of nearby residential development.
The Wave Festival Project is proposed to be built next to adjoining large and well-developed
residential communities. The concerns that arise in an agricultural area are not the same as they are
in a residential up -scale area like the one that will surround the Wave Festival Project. The
comparison, for analysis purposes, of data from the Lemoore facility is therefore faulty since it is
akin to comparing "apples to oranges."
Moreover, the assertion that Coral Mountain is "likely to absorb, rather than reflect noise back
towards sensitive receiver locations" was never tested or analyzed and is contrary to common sense
and the experience of residents of the City. They know well that noise is AMPLIFIED off the hard
surfaces of the surrounding mountains that are largely devoid of vegetation that might absorb sound
as it does in an agricultural setting like Lemoore, California.
Construction and traffic noise are some of the largest producers of noise pollution. Prolonged
exposure to noise pollution can lead to hypertension and heart disease, hearing loss and
consequential sleep disturbances. Wave Basin/Wave machine activity, outdoor pool/spa activity,
outdoor activity, and neighborhood commercial land use activities will run from 7:00 a.m. to 10:00
p.m. (DEIR, at 4.11-44.)
Finally, and most importantly, the Wave Festival Project is also projected to host Special Events as
pointed out above. The Applicant must also properly analyze and mitigate significant impacts from
noise from the Wave Festival Project considering these Special Events. Special consideration as to
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when they will be scheduled must also be analyzed. Moreover, special consideration must be given
to the fact that all the proposed residential development will be in the nature of short-term rentals
which are known to create additional noise and havoc in a community. Indeed, the City knows
these problems exist with respect to short-term rentals. (See,
https://www. desertsun. com/story/news/local/la-quinta/2021 /07/21 /la-quinta-considers-noise-
monitor-mandate-str-properties/8033933002/.) The DEIR has not analyzed these impacts from the
short-term rentals that will be pervasive as the Wave Festival Project. This impact allowing these
rentals is significant since there are no nearby short-term rentals since most are prohibited in nearby
communities4.
The former project, where the Wave Festival Project is proposed, envisioned a quiet golf -based
community with little noise emanating from that project. The City generally enjoys a quiet noise
environment, with existing community noise being dominated by highway and local traffic,
intermittent aircraft flyovers, and commercial operations. The City enjoys an enviable quiet
environment that must be considered and not compromised in the manner sought by Applicant.
Low noise levels are a major economic asset of the City's resort and residential atmosphere and it is
precisely that reason that residents have relocated to the City. The Wave Festival Project, however,
anticipates that the Applicant will conduct Special Events including concerts and hosting large-scale
surfing venues with music. These issues have not been properly addressed or analyzed in the DEIR.
All these elements will contribute heavily to noise pollution in the area. Noise pollution does not
only adversely affect human lives. Wildlife, especially birds, are heavily impacted by increased
noise pollution. Communication, mating behavior, hunting and survival instincts of animals are
altered by excessive noise. As such, the City should carefully review proposals such as the Wave
Festival Project which we believe to be incompatible with the quiet environment present in the City.
D. Air Quality Has Not Been Adequately Analyzed or Mitigated.
The Wave Festival Project will also result in significantly compromised air quality in the area
throughout the construction process, and potentially once the development is completed. Removal
of stabilized soils and biological soil crust creates a destructive cycle of airborne particulates and
erosion. As more stabilized soils are removed, blowing particulates from recently eroded areas act
as abrasive catalysts that erode the remaining crusts thus resulting in more airborne particulates.
4 These short-term rentals are additionally a health concerns highlighted by the Covid-19 epidemic.
Indeed, the City recently issued an executive order in connection with such rentals. (see,
https://www.laquintaca.gov/home/showpublisheddocument/44617/637474189355200000) In
issuing this Executive Order, the City cited increased short term rental complaints and violations
during Covid-19 and a desire to "retain the quality of life for City residents." Additionally, the City
had issued a moratorium on such rentals. None of these concerns have been addressed by the
Applicant.
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The Coachella Valley is in the Salton Sea Air Basin ("SSAB") under South Coast Air Quality
Management District jurisdiction. (DEIR, at 4.1-2.) The regional climate, as well as the
temperature, wind, humidity, precipitation, and amount of sunshine significantly influence the air
quality in the SSAB. Currently, state and federal air quality standards are exceeded in most parts of
the SSAB. (DEIR, at 4.1-16.) Construction activities associated with the Wave Festival Project will
result in emissions of VOCs, NOX, SOX, CO, PM10, and PM2.5, which includes site preparation,
grading, building construction paving, and architectural coating. (DEIR, at 4.1-18.) A development
with this effect on emissions is unacceptable amidst the current state of our climate crisis.
The Wave Festival Project could result in significant impacts health effects from air quality emissions
as well considering the significant nature of the Special Events as has been outlined above. In Sierra
Club v. County of Fresno (Friant Ranch, L.P.) (2018) 6 Ca1.5th 502, the Court held that air quality
analysis must make a reasonable effort to substantively connect a project's air quality impacts to
likely health consequences. Any consideration of air quality must address the health effects to nearby
sensitive receptors from the large quantity of idling vehicles consistent with a development of the
type sought by Applicant. As pointed out above, because of the transient nature of the visitors to the
Wave Festival Project because of short-term rental and the significant impact of the Special Events,
there will likely be many idling vehicles. The analysis of the DEIR, to actually demonstrate that there
are no significant impacts to air quality, is required to "connect" adverse human health effects to the
levels of pollutants that would be emitted by the Wave Festival Project. The DEIR fails to do so.
E. Greenhouse Gas Emissions Have Not Been Adequately Analyzed or Mitigated.
The DEIR needs to go further in addressing the spike in greenhouse gas emissions during the
potentially multiple year construction and because of the Special Events and short-term rentals.
The Wave Festival Project will be constructed in three phases and will take approximately six (6)
years to complete. (DEIR, at 4.1-19.) Due to the use of heavy construction equipment, unsafe levels
of air pollutants would have an impact on the surrounding community and wildlife during that time.
The presence of toxic air contaminants during construction is discussed in relation with the sensitive
human receptors but ignores construction pollutant impact on wildlife and the ecosystem. For
example, alpine and subalpine ecosystems could decline by as much as 60 to 80% by the end of the
century because of increasing temperatures. (DEIR, Appendix I [GHG Report], p. 20.] The City
may not hide behind a self-serving threshold to avoid this significant impact.
F. Cumulative Impacts Have Not Been Adequately Analyzed or Mitigated.
As written, the DEIR also glosses over the aggregate environmental impacts of the Wave Festival
Project and misleads the reader through words such as "may" and "potentially." This Project cannot
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be viewed independently from other planned developments in the region. The EIR needs to address
the cumulative effects of the Wave Festival Project in relation to other nearby projects and planned
developments.
The cumulative impact from several projects is the change in the environment which
results from the incremental impact of the project when added to other closely
related past, present, and reasonably foreseeable probable future projects.
Cumulative impacts can result from individually minor but collectively significant
projects taking place over a period of time.
(14 Cal. Code Regs. § 15355(b).) Traffic, water demands, greenhouse gas emissions, noise and air
pollution are aggregate and have cumulative effects. It would be disastrous oversight for the City to
allow the Wave Festival Project to move forward without fully analyzing this Project impact in
relation to the overall impact of other projects in the region that are currently in development or in
the planning stages. This is especially true given the fact that the DEIR did not consider the
scheduling of Special Events (not defined or discussed in the DEIR), and their otherwise enormous
impact vis-a-vis other festivals in adjoining communities such as Coachella and Stagecoach and the
impact of the short-term rentals (again, not addressed in the DEIR.)
IV. THE DEIR IS INCONSISTENT WITH GENERAL PLAN PROGRAMS AND LAND
USE POLICIES.
CEQA requires that environmental impact reports analyze the consistency of a project with
applicable local plans, including General Plans. (See Napa Citizens for Honest Govt. v. Napa
County Bd. of Supervisors (2001) 91 Cal.App.4th 342, 386-87; 14 Cal. Code Regs. Appendix G, §
IX(b).) Inconsistencies with a General Plan or other local plan goals and policies that were enacted
to protect the environment are significant impacts in themselves and can also be evidence of other
significant impacts. (See id.; Pocket Protectors v. City of Sacramento (2004) 124 Cal.App.4th 903,
929.)
"The general plan is more than the legal underpinning for land use decisions; it is a vision about
how a community will grow, reflecting community priorities and values while shaping the future."
(See, General Plan Guidelines; Published by the Governor's Office of Planning and Research
(https://opr.ca.gov/docs/OPR_COMPLETE_7.31.17 .pdf )).
The City must abide by its general plan since it is, in essence the "Constitution" of the City:
"[T]he general plan [is] a ` "constitution" for future development' [citation] located
at the top of 'the hierarchy of local government law regulating land use' [citation].
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The general plan consists of a `statement of development policies ... setting forth
objectives, principles, standards, and plan proposals.' [Citation.] The plan must
include seven elements—land use, circulation, conservation, housing, noise, safety
and open space—and address each of these elements in whatever level of detail local
conditions require [citation]. General plans are also required to be `comprehensive
[and] long[]term' [citation] as well as `internally consistent.' [Citation.] The
planning law thus compels cities and counties to undergo the discipline of drafting a
master plan to guide future local land use decisions." (DeVita v. County of Napa
(1995) 9 Ca1.4th 763, 772-773 [38 Cal. Rptr. 2d 699, 889 P.2d 1019], fn. omitted.)
Since it is essentially the Constitution of the City, a general plan cannot be lightly amended. Much
thought and deliberation go into the formation of the general plan and any amendment thereto. The
City is well of aware of this fact and its last update its general plan took place over a period of
years. (See, https://www.laquintaca.gov/business/182035-general-plan/documents) Key to any such
updates is community participation which is integral to the update process. The City's general plan
is the 2035 La Quinta General Plan (General Plan).
Here, Applicant seeks an extraordinary request from the City in connection with the Wave Festival
Project, i.e., an amendment to the City's General Plan. This request skirts and short circuits the
normal procedure that the City undertakes when it amends its General Plan which involves years of
deliberations and community input. Moreover, such a request short circuits the expectations of
residents of the City who invest their life savings in the City in purchasing residences based on their
belief that the values of the General Plan will hold true for the foreseeable future. It is for that
reason the City must tread lightly and consider the request of the Applicant with great concern.
Here, the Applicant requests a dramatic change to the City's General Plan. The General Plan
Amendment (GPA 2019 - 0002) will amend the current General Plan land use designations from
General Commercial, Low Density Residential, and Open Space – Recreation to Neighborhood
Commercial, Low Density Residential, Tourist Commercial, and Open Space. (DEIR, at 3.5.2.)
The Wave Festival Project bears NO relationship to the development that had been originally
entitled for that area. The request of the Applicant is for a wholesale change in the character of the
land where they propose to build. The DEIR briefly states, "The project site is surrounded by
developed residential communities..." A serious examination of the area shows The Quarry,
Santerra, Coral Mountain Estates, Andalusia, and Trilogy residential communities surround the
proposed location. Additionally, new home developments immediately south of the proposed
location have been approved or are in review including the 57 residential Estate Collection at Coral
Mountain and the 1,200 residential Travertine community—a fact omitted from the EIR. Clearly,
the Wave Festival Project is a "horse of a different color" entirely and is primarily a commercial
enterprise where low-density housing is slated to be built.
The DEIR's analysis of the Wave Festival Project's consistency with the General Plan is
fundamentally flawed. The DEIR takes the position that because amendments and minor
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adjustments to the General Plan are proposed, the Wave Festival Project would be consistent with
both documents, and, therefore, any conflicts with plans would be less than significant. (DEIR, at
4.10-1.) To evaluate the accuracy of this statement and the Wave Festival Project's consistency with
the General Plan, the DEIR must identify the "minor adjustments" to the plan's policies.
Unfortunately, the DEIR fails to provide this critical information.
Moreover, in its analysis, the DEIR glosses over numerous, glaring inconsistencies to reach the
contrived conclusion that the Wave Festival Project is somehow consistent with the General Plan. In
addition to misinforming decision -makers and the public about the Wave Festival Project's
consistency with the General Plan, this analysis underestimates the actual impacts of the Wave
Festival Project and ignores some of the Wave Festival Project's most significant impacts.5 The
DEIR must be revised and recirculated to provide a comprehensive and accurate analysis of all
General Plan inconsistencies.
Numerous goals and policies within the City are relevant to the Wave Festival Project. Many of
these goals and policies are directly at odds with the Wave Festival Project. Some of the most
egregious violations are discussed below.
A. The Wave Festival Prolect is Inconsistent with General Plan Policies Pertaining
to Water Usages.
The General Plan embodies values and principles that recognize the importance of the water
resources in the area, including maintaining water availability to provide domestic water to existing
developments in the City. Despite these important principles, the DEIR fails to provide any General
Plan consistency analysis for water. The following goal is indisputably linked to protecting the
environment through avoiding impacts on water resources:
GOAL -WR -1
GOAL -WR -1 states: "The efficient use and conservation of the City's water resources." The
General Plan acknowledges that continued growth in the City and the region has resulted in an
increased demand for domestic water. As a result, CVWD extracts more water from the lower
thermal subarea than is naturally recharged into it every year — a condition known as overdraft.
(General Plan, p. III -58.) It further states that increased development will contribute to greater
demand for water resources and the potential for continued overdraft. (Id.)
5 Additionally, the DEIR's conclusion that the Project is consistent with various General Plan goals
and policies is fatally undermined by the fact that the DEIR does not contain an adequate discussion
of the Project's impacts on the resources which those goals and policies are meant to protect. (See
Napa Citizens for Honest Govt., supra, 91 Cal.App.4th at 381.)
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This Project is enormous and will require significant amount of the City's valuable water resources.
At project buildout, the Wave Festival Project could accommodate approximately 7.77 acres of
Neighborhood and Wave Farm Commercial uses; 232.07 acres of Low Density Residential; 117.70
acres of Hotel/Resort uses comprised of the hotel, the Wave Lagoon, attached residential uses and
various resort related amenities; and 27.01 acres of Open Space. The low-density residential land
use will include 496 units of detached residential. The hotel resort land use proposes 150 hotel keys,
104 attached resort residential units and 55,000 square feet of commercial uses
The 16 -acre surf wave basin and lagoon will serve as the focal point of the development. The
estimated total domestic water demand for indoor and outdoor use is approximately 941.03 acre-
feet per year (AFY), or 2.45 acre-feet per acre. The residential indoor demand estimate is 97.22
AFY, the non-residential indoor use estimate is 42.34 AFY, and the outdoor estimate is 801.47
AFY. (WSA, p. 20.) The majority of the water use is the outdoor water demand, which equates to
an outrageous 260,986,749.15 gallons of water per year. With precious water resources, a huge surf
lagoon in the middle of the desert clearly does not comply with General Plan GOAL -WR -1 as an
efficient use of water. The Wave Festival Project's inconsistency with this General Plan Goal
constitutes a significant impact.
B. The Wave Festival Project is Inconsistent with General Plan's Policies
Pertaining to Aesthetics and Light Pollution.
It is undisputable that the Wave Festival Project given the height, bulk, and scale of its proposed
structures — would irreparably alter the community's character and views of the surrounding
mountains. By the DEIR's own admission, the Wave Festival Project's impacts on scenic vistas, the
visual character or quality of the site, scenic resources, and light and glare would be significant and
unavoidable. (DEIR at 1-15.) The DEIR's conclusion that the Wave Festival Project would not
conflict with the General Plan policies pertaining to aesthetics would be laughable if the
implications were not so ominous. Certain of the most egregious violations include:
Guiding Principle:
One of the guiding principles of the General Plan is to reduce light pollution. (General Plan, p. 1-3.)
The Wave Festival Project is blatantly inconsistent with this principle. The Wave Festival Project
proposes 80 -foot -high light fixtures. The 80 -foot light fixtures proposed for the project would be
located around the Wave Basin to illuminate the recreational facility during the evenings. (DEIR, at
4.1-56.) The Wave Festival Project proposes seventeen (17) 80 -foot lights, separated approximately
20 feet from each other. The light poles lie within the line of sight for motorists and pedestrians, and
visible to the properties south of the Wave Festival Project. (DEIR, at 4.1-39, 4.1-41.) Even worse,
the lights will operate from dust to 10 PM. (Id.)
As opined by Minagar & Associates in their comment letter of August 2, 2021 (see, Exhibit 3), the
analysis contained in the DEIR is defective in several respects:
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Providing the right lighting solution for an exterior application should take into
consideration glare, along with the specific site requirements for spacing, efficiency,
and visual comfort. Current means of measuring glare in exterior applications are not
fully defined or comprehensive. Ways to is by the following: Shielding, diffusion,
selection of warm CCTs, and reducing contrast of the Effective Luminous Area.
Reducing glare may reduce the efficiency of the luminaire and the spacing, height
which were not addressed in this DEIR report nor in Appendix B due to cost and
potential redesign of the project. We have to bear in mind that, the level of glare that
an individual experiences is highly subjective. Therefore, the designers should install
mock-ups in order to confirm adequate performance and visual comfort of the
concerned parties affected by such installation. Shielding and Diffusion in LED
Luminaires has not been explored in the DEIR report nor in Appendix B. There is no
alternative solution/ study provided for the intensity from the luminaire, the number
of luminaires, the size of the luminaire, and the height or the angle of the luminaire.
The proposed lighting plan does not provide any gradients. It immediately changes
between dark and bright. For older residents/visitors in the surrounding area of the
proposed project site, it will inevitably create a lot of discomforts especially
bothering some individual's eyes.
Nor does the DEIR address concerns that are specific to the City and desert conditions. The City is
regularly buffeted by high winds. As a result, there is silica particulate blown about in the area of
the proposed project. That particulate is highly reflective. Nowhere in the DEIR does the
Applicant address this important issue.
The DEIR did not, then, properly analyze the light and glare emanating from the enormous 80 -foot
towers that will be constructed. There are no actual mockups of the proposed towers that would
provide real and credible analysis of their impacts, for example.
Moreover, the analysis of the DEIR did not consider the darkened skies of the surrounding
environment in the Coachella Valley. It is a much -hallowed quality that municipalities and
homeowner's associations go to great lengths to make certain that ambient light is dampened or
eliminated, e.g., some communities prohibit or limit light posts. This darkened atmosphere opens
the night skies to the beauty of illuminating stars. These darkened skies then are a particularly bad
backdrop from the glare that will most assuredly emanate from the 80 -foot light towers that
Applicant proposes especially when windstorm lift reflective particulate into the air. The light and
glare generated from the fixtures would result in significant impacts and is in direct contrast to the
City's principle to reduce light pollution.
GOAL OS -3:
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Goal OS -3 states the importance of the preservation of scenic resources as vital contributors
to the city's economic health and overall quality of life. (General Plan, at 11-30.) The Wave
Festival Project causes a significant change in the visual character of the area from a single -
story residential and golf environment to a hotel and Wave Basin facility. As determined in
the line -of -sight analyses and visual simulations, the project site will result in the partial
obstruction of views of Coral Mountain and the Santa Rosa Mountains, depending on
location and viewpoint. Therefore, development of the project property would result in
obstructed and partially obstructed views of these scenic resources. (DEIR, at 4.1-44.) The
Wave Festival Project's clear inconsistency with this General Plan Goal constitutes a
significant impact.
Policy LU -2.3:
Policy LU -2.3 states that the City's outdoor lighting ordinance will be maintained. The La Quinta
Municipal Code ("LQMC") Section 9.100.150, Outdoor Lighting, is intended to provide standards
for outdoor lighting which allow adequate energy efficient lighting for public safety while
minimizing adverse effect of lighting, such as lighting which has a detrimental effect on
astronomical observations; inefficiently utilizes scarce electrical energy; and/or creates a public
nuisance or safety hazard. As set forth above, the Wave Festival Project site, which is currently
undeveloped and vacant, provides largely unobstructed views of Coral Mountain and the Santa
Rosa Mountains from public rights -of -ways. (DEIR, at 4.1-72.) However, because of the enormous
light poles around the Wave Basin, it will create an unsafe glaring off the roads where cars travel.
The Wave Basin lights will be projected until 10 p.m. at night. The bright lights at the Wave Basin
in the evening hours will clearly conflict with the City's policy for public safety under the LQMC
outdoor lighting ordinance.
C. The Wave Festival Project is Inconsistent with General Plan Policies Pertaining
to Noise Pollution.
Notwithstanding the fact that the Wave Festival Project would result in significant noise pollution,
the DEIR identifies it as "less than significant." Moreover, it never bothers to analyze the Wave
Festival Project's consistency with the following General Plan policies:
Guiding Principle:
One of the guiding principles of the General Plan is to reduce noise pollution. (General Plan, p. 1-
3.) The City's ongoing efforts to preserve the quality of life for all its residents, present and future,
must include the protection of a quiet noise environment. The Wave Festival Project is clearly
inconsistent with this principle.
There are both operational and construction noise impacts associated with this Project. For example,
the Wave Basin and associated machinery/facilities will cause operational noise impacts. Prior to
Palm Springs, CA
T (760) 322-2275
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 18
each wave, the control tower announces the event over the public address system. (DEIR, Appendix
K.1 [Noise Study], at p. 73.) This is followed by the noise generated from the movement of the sled
and an increase in noise levels from the mechanical equipment buildings. As the sled moves
through the lagoon, noise from the cable and metal rollers is clearly audible. (Id.) During peak wave
events, the Wave Basin generates noise levels ranging from 62.6 dBA Leq at end of the lagoon,
73.8 dBA Leq in the lifeguard tower and 75.7 dBA Leq near the cable roller system. (Id.)
There are also serious noise levels concerns associated with outdoor hotel pool and spa activity.
These noise activities include the waterfall, people talking, and children and adults swimming and
playing in a pool. The measured reference noise level at 50 feet is 57.8 dBA Leq. (Id. at p. 75.)
In addition, there is noise level impacts associated with the Wave Festival Project's outdoor or
beach club activities, including parents speaking on cell phones, kids playing, and background
youth soccer games, with coaches shouting instructions and people cheering and clapping. The
special events will also contribute to additional noise. The Noise Study estimated the playground
activity noise level to be 43.4 dBA Leq. (Id.)
Finally, there is noise level impacts associated the proposed neighborhood commercial center. The
noise level measurements collected show a peak hourly noise level of 54.8 dBA Leq when
measured at 50 feet. (Id.) All the operational noise impacts exceed 219.3 dBA Leq.
There are also construction -related impacts associated with the Wave Festival Project, which
includes combination of trucks, power tools, concrete mixers, and portable generators that when
combined can reach high levels. Noise levels generated by heavy construction equipment can range
from approximately 68 dBA to more than 80 dBA when measured at 50 feet. (Id. at p. 81.)
Construction activity can result in varying degrees of ground vibration, depending on the equipment
and methods used, distance to the affected structures and soil type. The Wave Festival Project is
inconsistent with this general principle of reducing noise pollution. As discussed above, the
operational and construction noise impacts would affect human lives, as well as wildlife. The DEIR
cannot simply ignore this very real threat to public safety.
GOAL N-1
GOAL N-1 states as follows: "A helpful noise environment which complements the City's
residential and resort character." The primary source of noise in the City is traffic. (General Plan, p.
IV -4.) Traffic generated by the operation of the Wave Festival Project will influence the traffic
noise levels in surrounding off-site areas. (DEIR, Appendix K.1 [Noise Study], at p. 1.) The DEIR
acknowledges that the Wave Festival Project -related noise level increases are considered
"potentially significant" for Avenue 58 and Madison Street. (Id.) In addition to the resort itself,
there will be increased traffic from construction and special events. The Wave Festival Project's
inconsistency with these General Plan principles and goals constitutes a significant impact.
Palm Springs, CA
T (760) 322-2275
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 19
D. The Wave Festival Project is Inconsistent with General Plan Policies Pertaining
to Transportation.
If implemented, the Wave Festival Project would be directly at odds with the General Plan's
fundamental principles that development only be allowed in areas where the circulation and
transportation system capacity can accommodate such development. One of the guiding principles
in the General Plan is to "[p]romote and encourage a broad range of transportation opportunities,
especially those that reduce the impact to our environment, as well as effectively moving people
and goods. Continue to work closely with neighboring communities and regional agencies to
address regional transportation issues." (General Plan, at p. I-3.) The General Plan includes
numerous guiding policies centered on these themes, including, but not limited to:
Policy CIR-1.12
Policy CIR-1-1.12 states as follows: "As a means of reducing the vehicular traffic on major
roadways and to reduce vehicle miles traveled by traffic originating in the City, the City shall
pursue development of a land use pattern that maximizes interactions between adjacent or nearby
land uses." (General Plan, at p. II -126.) In direct violation of Policy CIR-1.12, if the Wave Festival
Project is approved, the City would be allowing significant and unavoidable traffic impacts on local
and regional highways. The Wave Festival Project is inconsistent with this General Plan Policy
which also constitutes a significant impact.
Policy CIR-2.1
Policy CIR-2.1 states as follows: "Encourage and cooperate with SunLine Transit Agency on the
expansion of routes, facilities, services and ridership especially in congested areas and those with
high levels of employment and commercial services and encourage the use of most energy efficient
and least polluting transportation technologies." (General Plan, at p. II -128 II -129.) Within this
Policy are several program goals, including:
Program CIR-2.1.a: Consult and coordinate with the SunLine Transit Agency on
immediate and long-term transit issues and assure pro active representation on the
Agency Board and its decision making process.
***
Program CIR-2.1.c: When reviewing development proposals, consult and
coordinate with SunLine and solicit comments and suggestions on how bus stops and
other public transit facilities and design concepts, including enhanced handicapped
access, should be integrated into project designs.
Program CIR-2.1.d: When reviewing large-scale development proposals, consult
and coordinate with SunLine to encourage the development of rideshare and other
Palm Springs, CA
T (760) 322-2275
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 20
alternative, high occupancy transit programs for employers with sufficient numbers
of employees.
(Id. at II -129.)
The DEIR simply states that "bus facilities are not located within the project study area." (DEIR, at
4.13-8.) It makes no mention of consulting with the SunLine Transit Agency or evaluating on ways
that transit services could be incorporated into the Wave Festival Project. In fact, the DEIR provides
no indication that the Wave Festival Project would result in an increase in transit mode share. Based
on the Coral Mountain Vehicle Miles Traveled (VMT) Analysis (Appendix L.2), the Wave Festival
Project has an estimated service population (SP) of 1,698 residents, 434 employees associated with
the hotel use, 240 employees associated with the retail use, and approximately 300 hotel occupants
for a total service population of 2,672. (DEIR, at 4.7-9.) With this type of large-scale project, it is
imperative that transit programs are evaluated in more detail.
Policy CIR-2.2
Policy CIR-2.2 states as follows: "Encourage reduction of greenhouse gas emissions (GHG) by
reducing vehicle miles traveled and vehicle hours of delay by increasing or encouraging the use of
alternative modes and transportation technologies, and implement and manage a hierarchy of
Complete Street multimodal transportation infrastructure and programs to deliver improved
mobility and reduce GHG emissions." (General Plan, at p. II -129.)
As set forth above, the DEIR is inadequate in its evaluation of alternative modes of transportation.
The DEIR states that the Wave Festival Project includes Project Design Features (PDFs) that
effectively reduce air quality and GHG emissions. (DEIR, at 7-6.) It goes on to list a few programs,
such as employer-sponsored shuttles, and commute trip reduction program. (Id.) However, the
DEIR provides very little detail on how these programs would be implemented. Without providing
any details, it is unclear whether it complies with Policy CIR-2.2 of the General Plan.
The Wave Festival Project is in clear violation of these General Plan Policies. The DEIR provides
no indication that the Wave Festival Project would result in an increase in transit mode share.
Rather than meeting recreational demand with transit service, the Wave Festival Project would
likely be completely auto -based. In addition, the Wave Festival Project would result in a significant
impact on local transit service providers for which the DEIR does not identify adequate mitigation.
The Wave Festival Project is inconsistent with this General Plan Policy which also constitutes a
significant impact.
CONCLUSION
Palm Springs, CA
T (760) 322-2275
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
Jon McMillen, City Manager
Cheri Flores. Planning Manager
Nicole Sauviat Criste, Consulting Planner
August 6, 2021
Page 21
We are concerned on several fronts that a project of the magnitude and impact of the Wave Festival
Project is being considered without sufficient consideration being given to its significant
environmental impact to the City and its residents. Moreover, we are concerned that the City is
running afoul of its requirements to conduct a thorough and meaningful analysis of the Wave Festival
Project as required by California law and by its own General Plan. Before the Wave Festival Project
can even be considered, then, there must be a credible analysis of its environmental impact. That
critical analysis has not been performed.
Sincerely,
17.1061/2.--
Bruce
T. Bauer, Esq.
Enclosures
Ex. 1 — Minagar & Associates, Inc. Resume
Ex. 2 - August 3, 2021, Minagar & Associates, Inc comment letter re traffic
Ex. 3 - August 2, 2021, Minagar & Associates, Inc comment letter re sound
CC: Linda Evans, Mayor (levans@laquintaca.gov)
Dr. Robert Radi, Mayor Pro Tem (rradi@laquintaca.gov)
John Pena, Council Member (jpena@laquintaca.gov)
Kathleen Fitzpatrick, Council Member (kfitzpartick@laquintaca.gov)
Steve Sanchez, Council Member (ssanchez@laquintaca.gov)
Palm Springs, CA
T (760) 322-2275
SLOVAK BARON EMPEY MURPHY & PINKNEY LLP
Indian Wells, CA Costa Mesa, CA San Diego, CA Princeton, NJ New York, NY
T (760) 322- 9240 T (714) 435-9592 T (619) 501-4540 T (609) 955-3393 T (212) 829-4399
www.sbemp.com
EXHIBIT "1"
Cali}ornie Environmental Protection Agency
efillAir Resources Board
MINAGAR & ASSOCIATES, INC -
ITS - Traffic/Civil/Electrical Engineering - Transportation Planning - Homeland Security - CEM
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Winner of the Orange County Engineering Council's Outstanding Service Award
2016 Winner of the ASCE's Outstanding Civil Engineer in the Private Sector Award in the State of California
20 Winner of the ASCE Los Angeles Section's Outstanding Civil Engineer in the Private Sector Award
2016 Winner of the ASCE Orange County Chapter's Outstanding Civil Engineer in the Private Sector Award
2016 Certificate of Recognition for Dedication to Support the ELTP Program by Los Angeles County MTA/Metro
20"" Winner of the Orange County Engineering Council's Outstanding Engineering Service Award
2015 Orange County Business Journal's 2015 Excellence in Entrepreneurship Award Nominee
2014 Orange County Business Journal's 2014 Excellence in Entrepreneurship Award Nominee
2012 Winner of Cal-EPA/California Air Resources Board's
Cool California Climate Leader
2C Award of Excellence in Service by Los Angeles County MTA/Metro
in the County of Los Angeles
Award of Excellence in Service by Los Angeles County MTA/Metro
in the County of Los Angeles
2010 Award of Excellence in Service by Los Angeles County MTA/Metro
in the County of Los Angeles
Winner of the ASCE's Outstanding Private Sector Civil Engineering Project
in Metropolitan Los Angeles
2009 Winner of the Caltrans' 2009 Excellence in Transportation Award
in the State of California
21..,. Winner of the ASCE's Outstanding Public/Private Sector
Civil Engineering Project in Metropolitan Los Angeles
2005 Winner of the APWA's Best Traffic Congestion Mitigation Project of the Year
in Southern California
2004 Top Nominee of Transportation Foundation's Highway Management Program
in the State of California
2003 Winner of the PTI's Best Transportation Technology Solutions Award
in the United States
21 Winner of the ITS -CA's Best Return on Investment Project Award
in the State of California
21 Award of Excellence in Service by Los Angeles County MTA/Metro
in the County of Los Angeles
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MINAGAR & ASSOCIATES, INC.
23282 Mill Creek Drive, Suite 120
Laguna Hills, CA 92653
Tel: (949)707-1199
Web: www.minaaarinc.com
28 Years of
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CORPORATE SUMMARY
23 Years of Excellence
Minagar & Associates, Inc. is a professional Traffic Engineering,
Transportation Planning & Intelligent Transportation Systems (ITS), firm based
in Irvine, CA. Since its inception in 1993, over 23 years ago, the firm has
completed over 300 traffic engineering projects in 11 counties and 76 cities in
the State of California alone, as well as 16 other states from Hawaii to New
York. Successful completed projects have comprised:
• 42 ITS Projects;
• 123 Transportation Planning Projects & Traffic Studies;
• 249 Signal Design Projects;
• 16 Construction Engineering Management (CEM) Projects;
• 47 Parking Studies;
• 25 EIS/EIR Projects;
• 25 Traffic Control Plans (TCP);
• 77 Traffic Signal, ITS, Interconnect PS&E Projects
• 1,600+ Synchronized & Retimed Signals
The firm is recipient to numerous, local, regional, state, national as well as international awards, such as:
Cal-EPA/California Air Resources Board's 2012 Cool California Climate Leader
ASCE's 2009 Outstanding Private Sector Civil Engineering Project in Metropolitan Los Angeles
• Caltrans' State Route 66 Adaptive Traffic Signal Control System Project
Caltrans' 2009 Excellence in Transportation Award
• Caltrans' State Route 66 ATCS Project
ASCE's 2007 Outstanding Public/Private Sector Civil Engineering Project in Metropolitan Los Angeles
• Intelligent Transportation Management System (ITMS) & Traffic Signal Interconnect
for Metro and the City of Santa Clarita
APWA's 2005 Best Traffic Congestion Mitigation Project of the Year in Southern California
• L.A. County Metro/City of Palmdale's Avenue R (ITS) Traffic Signal & Fiber -Optic
Interconnect Projects
CA -ITS 2002 Award of Excellence for the Best California Return on Investment
• Traffic Signal Synchronization of 121 City of Modesto, County & Caltrans Traffic
Signals in Northern California
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23 Years of Excellence
Representative Public Clients List
CITIES
• Baldwin Park, CA
• Bell, CA
• Bell Gardens, CA
• Buena Park, CA
• Burbank, CA
• Calabasas, CA
• Carson, CA
• Ceres, CA
• Chino Hills, CA
• Coachella, CA
• Colton, CA
• Commerce, CA
• Corona, CA
• Costa Mesa, CA
• Culver City, CA
• Delano, CA
• Desert Hot Springs, CA
• Diamond Bar, CA
• Garden Grove, CA
• Gardena, CA
• Glendora, CA
• Hermosa Beach, CA
• Huntington Beach, CA
• Inglewood, CA
• Irvine, CA
• La Habra, CA
• Laguna Beach, CA
• Laguna Hills, CA
• Laguna Woods, CA
• Lake Elsinore, CA
• Lake Forest, CA
• Lancaster, CA
• Lawndale, CA
• Lompoc, CA
• Long Beach, CA
• Los Angeles, CA
• Lynwood, CA
• Manhattan Beach, CA
• Mission Viejo, CA
• Modesto, CA
• Moreno Valley, CA
• Newport Beach, CA
• Palmdale, CA
• Pasadena, CA
• Pomona, CA
• Rancho Santa Margarita, CA
• Redlands, CA
• Redondo Beach, CA
• Rialto, CA
• Ridgecrest, CA
• Riverside, CA
• San Clemente, CA
• San Diego, CA
• San Juan Capistrano, CA
• San Marino, CA
• Santa Ana, CA
• Santa Clarita, CA
• Santa Fe Springs, CA
• Santa Monica, CA
• Solana Beach, CA
• South El Monte, CA
• South Gate, CA
• South Pasadena, CA
• Temecula, CA
• Tustin, CA
• Ventura, CA
• West Hollywood, CA
• Yorba Linda, CA
• Yucca Valley, CA
NATIONAL, STATE, REGIONAL, COUNTY & OTHER PUBLIC AGENCIES/ INSTITUTIONS
• Bethel University, San Diego, CA
• Caltrans Districts 7, 8, 10, 12 & HQ, CA
• County of Los Angeles Department of Public Works
(LACDPW), CA
• County of Riverside, CA
• County of San Bernardino, CA
• County of San Diego, CA
• Cypress School District, CA
• Drew University, Los Angeles, CA
• Eastern Municipal Water District, CA
• Federal Highway Administration (FHWA)
• Greater Cypress Park Neighborhood Council,
(GCPNC) CA
• Greater Griffith Park Neighborhood Council
(GGPNC), CA
• Hollywood United Neighborhood Council, CA
• Institute of Transportation Engineers (ITE)
• Kern County, CA
• Leisure World/Laguna Woods Village, CA
• Long Beach City College, CA
• Los Angeles World Airports (LAWA), CA
• Metro (L.A. County Metropolitan Transportation
Authority), CA
• Metropolitan Water District of Southern California
(MWD)
• Orange County Transportation Authority (OCTA), CA
• Southeast Asian Community Alliance (SEACA), CA
• Southern California Association of Governments
(SCAG), CA
• United States Dept. of Transportation (USDOT)
• Southern California Regional Rail Authority
(SCRRA) / Metrolink, CA
• West Coast Baptist College, Lancaster, CA
• Western Municipal Water District (WMWD), CA
INTERNATIONAL PUBLIC CLIENTS
• Government of People's Republic of China • Government of South Korea • Kingdom of Saudi Arabia
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TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Traffic Signal Modifications
Bulb -outs
Replace
ADA
Ramps
Fiber optic
Interconnect
1l
Burbank's Highway Safety Improvement
Project (HSIP3) on Verdugo Avenue at
Keystone Street, Parish Place and Olive
Avenue
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared a full Plans,
Specifications and Estimates (PS&E) package for the City of Burbank to provide traffic
signal modifications and pedestrian crossing improvements on Verudugo Avenue at the
intersections of Keystone Street and Parish Place. Project features included:
CMI Improvements:
• Reconstruction of four (4) intersections corners in front of the existing Burroughs
High School athletic fields with "bulb -out" sidewalk extensions to provide:
o Double perpendicular ramps (replaces single ramps);
o Caltrans/ADA conforming detectable warning surface panels;
o Reduction in the crossing distance of school pedestrians across Verdugo,
and subsequent delay times for the 2 signals;
o Safe pedestrian refuge at the corners of each intersection in conjunction
with the City's recently installed bike lanes and parking lanes on Verdugo
• Replacement of two (2) intersections corners on the west side of Keystone Street at
Verdugo Avenue to provide ADA -compliant pedestrian ramps in conjunction with the
traffic signal modifications
TrafElks 9PSIJFibQr-Optic Interconnect Improvements:
• Installation of new signal poles, conduit, conductors, vehicle/bicycle DLC and five -
section signal heads
• 233 Bi -Trans Full Version program with Battery Back-up System (BBS) within
existing 332 traffic signal cabinet
Installation of 3" HDPE conduit, 12-48 strand Single Mode Fiber -Optic (SMFO)
Cable, and fiber-optic pullboxes (2'x3')
• Removal of existing Type 337 controller cabinet and installation of new 170
controller with Bi -Trans Full Version with BBS new
Installation of 2" conduit for power service to existing Type III -BF cabinets
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LOCATION
♦ Burbank, Los Angeles County, CA
SCOPE OF WORK
Field Observations and Identification/Inventory
of Existing Infrastructure and Deficiencies;
• Utility Conflicts (e.g., catch basins, overhead
power lines, fire hydrant, in -street water valve
covers, SD/SS manholes)
• Pullbox inspection
• Land/Control Survey
• Elevation Survey at BCR/ECR, '/<- and %-
deltas and 10 -ft stations of existing:
- Curb (TC)
- Edge of gutter (EP/EG)
- Back -of -walk (BW)
- Street centerlines (CL)
- Running/counter slopes on sidewalk; and
- Street grades
• Preparation of Plans, Specifications & Estimates
• As -built Signal Base Plans
• Preparation of Construction Plans:
- Traffic Signal Modification
- Fiber-optic Interconnect
- Signing, Striping and Roadway Improvements
■ Technical Specifications & Provisions
• Engineer's Cost Estimate
• Proposed Improvements:
• "Bulb -out" curb extensions at 4 corners
• ADA ramp upgrades with detectable warnings
• Traffic signal poles, pushbuttons and
vehicle/pedestrian head upgrades
• Replacement of traffic signal conduit,
conductors, and loop detectors
■ Traffic signal controller/cabinet upgrades
• Fiber-optic Traffic Signal Interconnect Conduit,
Cable, Splice Vaults and Pullboxes
• Install ladder -type SCHOOL crosswalks
■ Replace ADA ramps w/ detectable warnings
-0 Construction Advertisement Services
• Respond to Requests for Information (RFI)
• Prepare Bid Schedule of Construction Items
• Prepare Utility Notice(s)
CLIENT
City of Burbank
Michael Salvani
Public Works Department /
Traffic Engineering Division
(818) 238-3968
msalvani 6 Ci.burbank-ca.us
CURRENT STATUS CONSTRUCTION COST
▪ Complete $267,900
r23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
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• Prop. Signal Head/Phase ® Ex. Ped Flashing Beacon • Proposed sidewalk installation MIProposed 4' street widening �
BIKE LANE
giBurbank's Bike Lane Extension Project
(HSIP4) on Verdugo Avenue from
Clyboum Street to Victory Boulevard
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared a full Plans,
Specifications and Estimates (PS&E) package for the City of Burbank to provide traffic
signal modifications for bicycle video detection, and street widening roadway improvements
for extended Class II bikelanes at various locations on Verdugo Avenue, including at the
following segments and intersections:
Civil Improvements:
• Signage and striping Improvements (ladder -type crosswalk markings, bike/parking
lanes, reconfiguration of travel lanes to accommodate a "road diet' configuration and
the proposed CL2 bikeway) on Verdugo Avenue from Clyboum Street to Hollywood
Way, and from Olive Avenue to Victory Boulevard;
Street widening on Verdugo Avenue from Olive Avenue to Virginia Avenue
(Reconstruct P.C.C. curb & gutter 4' off ex. south CF; Reconstruct sldeWalk; Replace
parkway landscaping; Remove/install A.C. pavement, with maximum depth of
excavation at gutter of 10`; Relocate water meter boxes, irrigation lines and street
lighting equipment; Adjust utility covers In street to FG; Protect ex. fire hydrants, utility
poles, SD inlets and SS manholes);
Construct bulb -out and crosswalk at ex. pedestrian flashing yellow beacon
New sidewalk construction on the north side of Verdugo Avenue from Virginia Avenue
to 340' easterly (Remove parkway landscaping and trees; Protect utility poles and
boxes)
•
•
Traffic Signal/Electrical Imorovements:
• Traffic signal and electrical service modifications (traffic signal poles, bicycle detection
cameras, ped/bike pushbuttons, controllertcabinel upgrades and foundations. conduit,
wiring, pull boxes) on Verdugo Avenue at the following six (6) signalized intersections:
Hollywood Way, California Street, Catalina Street, Buena Vista Street, Virginia
Avenue, Victory Boulevard / Main Street;
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LOCATION
♦ Burbank, Los Angeles County, CA
SCOPE OF WORK
• Field Observations and Identification/Inventory
of Existing Infrastructure and Deficiencies;
• Utility Conflicts (e.g., BWP coordination for
removal of and/or connection to overhead
power lines; protection of fire hydrant, in -street
water valve covers, catch basins and SD/SS
manholes);
• Relocation of existing street lighting
equipment, trees/tree boxes, irrigation lines,
curb drains and replacement of ground cover
• Re -paving cross gutters and A.C. surfaces to
match proposed grade of widened street
4 Land Survey
• Elevation Survey at BCR/ECR, '/a- and '/z -
deltas and 10 -ft stations of existing:
- Curb (TC)
- Edge of gutter (EP/EG)
- Back -of -walk (BW)
- Street centerlines (CL)
- Running/counter slopes on sidewalk; and
- Street grades
• Control Survey Plans
4 Preparation of Plans, Specifications & Estimates
• As -built Signal Base Plans
• Construction Plans:
- Traffic Signal Modification (6 intersections)
- Roadway Profiles and Cross -Sections
- Signing, Striping and Roadway Improvements
• Technical Specifications & Provisions
• Engineer's Cost Estimate
4 Construction Advertisement Services
• Respond to Requests for Information (RFI)
• Prepare Bid Schedule of Construction Items
• Prepare Utility Notice(s)
CLIENT
City of Burbank
Michael Salvani
Public Works Department /
Traffic Engineering Division
(818) 238-3968
msalvani(a)ci.burbank, ca.uS
CURRENT STATUS CONSTRUCTION COST
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MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
CITY OF
CALABASAS --
Lalt Virgenag Rand FilEnr•Opiir.
Jrafflr, Signal Inh pili -Act
Calabasas Roar!
Fil�nr•f�l3llr.
Siarinl
Inl[NiYiullrrei
Upgrade of Calabasas Regional
Transportation Management Center
and Las Virgenes Road Corridor
Fiber -Optic Signal Interconnect
PROJECT DESCRIPTION
Minagar & Associates, Inc. completed the plans for the expansion, enhancement
and upgrade of the Calabasas Regional Transportation Management Center. The
Traffic Management Center monitors and controls regulate the traffic signals and
vehicle movements throughout the city.
The City houses the Regional Traffic Operations Center, which serves the Las
Virgenes Malibu Conejo Council of Governments including the cities of Agoura
Hills, Calabasas, Hidden Hills, Malibu and Westlake Village. The following tasks
were performed:
• Locations of Calabasas CCTV System
• Development of PS&E for the CCTV System
• Design of Expanded/Upgrade Calabasas TOC/Systems Architecture
• Systems Implementations
• Traffic Signal Interconnect
• Traffic Signal Synchronization along 3 Major Arterials at 22 City, Los
Angeles County and Caltrans signals
• Traffic Data Collection
• TMC/TOC Equipment Procurement
A PS&E package was developed for the communications network master gap
closure, construction management of video detection and surveillance,
implementation of an overall ATMS system with capabilities to communicate with
the City of Los Angeles ATSAC and synchronizing traffic signals along 3 major
arterials. PS&E plans were also prepared for Las Virgenes Corridor Signal
Interconnect Project.
These plans helped to complete a signal interconnect fiber-optic network that
linked all traffic signals to a central traffic control hub at City Hall. The project
included installation of conduit and fiber-optic cable along approximately 9,000
linear feet of Las Virgenes Rd. between US -101 interchange and Lost Hills Rd.
LOCATION
4 Calabasas, Los Angeles County, California
SCOPE OF WORK
4 Traffic Engineering & Design
♦ ITS Engineering
• Systems Engineering
4 Civil Engineering
♦ Electrical Engineering
CLIENT
• City of Calabasas
Robert Yalda, P.E., T.E.
Director of Public Works/City Engineer
100 Civic Center Way
Calabasas, CA 91302
(818) 224-1600
AGENCIES
i Metro (Los Angeles County
Metropolitan Transportation Authority)
Roger Martin
One Gateway Plaza
Mail Stop: 99-22-9 Metro
Los Angeles, CA 90012-2952
(213)922-1462
CONSTRUCTION COSTS
4 n/a
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
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Ceres' Advance Traffic Management System (ATMS) &
Closed Circuit Television Systems (CCTV) for 3 Major
Corridors and 29 Signalized City & State Intersections
PROJECT DESCRIPTION
Minagar & Associates, Inc. prepared a complete set of Plans, Specifications and
Estimates (PS&E) and bid documents for the subject project, which consisted of
installing a new ATMS and CCTV camera system in the City of Ceres, which allows the
City of Ceres' ATMS/CCTV System to interact and communicate with the neighboring
City of Modesto's ATMS/CCTV System. The City of Ceres will be using the system to
monitor the proposed CCTV cameras via Ceres ATMS/CCTV Operations Center located
at the City of Ceres City Hall. The project consisted of Planning, Designing, providing
Construction Engineering Management (CEM) and Inspection for the new ATMS/CCTV
system, which is composed of both wireless interconnect as well as a combination of
overhead and underground fiber-optic deployment along three (3) major east -west,
north -south and diagonal corridors through the City. The project was achieved through
the completion of the following major tasks:
• Preparing Environmental Documentation, including Preliminary Engineering Studies
(PES) and NEPA/CEQA Categorical Exclusion/Exemption technical support and
application work under Caltrans Local Assistance Procedures Manual (LAPM);
• Evaluating the existing closed-circuit television (CCTV) communications systems, and
recommending a system compatible with ATMS/CCTV systems in both the Cities of
Ceres and Modesto;
• Assisting in the development of detailed plans, specifications and cost estimates
(PS&E) for the implementation of the CCTV/ATMS system, as well as Traffic
Management Center (TMC) Design;
• Respond to Requests For Information (RFI) from bidding contractors, reviewing bid
submittals, and providing CEM and construction inspection services during the
installation of the CC I V/ATMS system;
LOCATION
i Ceres, Stanislaus County, California
SCOPE OF WORK
. Environmental Studies/Planning
- Caltrans Local Assistance Procedures
(LAPM) Technical Support and Application
Preparation
Preliminary Engineering Study (PES)
NEPA/CEQA Categorical Exclusion/
Exemption (CE/CE) Documentation
▪ Traffic Signal, Traffic Management Center
(TMC), ATMS/CCTV Systems, Electrical and
Interconnect Design Services and Fiber -Optic
Deployment
4 Preparation of Plans, Specifications &
Construction Cost Estimates (PS&E)
,► Construction Engineering Management
(CEM) and Inspection
CLIENT
4 City of Ceres, CA
Ann Herner, Project Manager
Public Works Department, Engineering Division
2220 Magnolia Street
Ceres, CA 95307
(209) 538-5776
ann.herne rAci .ceres. ea. us
AGENCY
4 Caltrans D-10 ai/6wv
Sinaren Pheng, P.E. District 10
1976 E. Charter Way / Dr. MLK Jr. Blvd.
Stockton, CA 95205
(209) 948-3689
Sinaren vhenc dot.ca.gov
PROJECT COST
4 $250,000.00
COMINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
WHITMORE 4
AVENUE
LE END
MAMMA] -""""CI^cQNItQ,
Qcolts CITY SOUFMRY
▪ •ITERSECTON LOCATION NUMBER
BYNCIIRONIZEO TRAF FIC SIGNAL
RETLEO TRAFFIC SIGNAL
C* Ceres' Citywide Traffic Signal Retiming &
arromv Synchronization Project for 3 Major Corridors and
District 10 29 City & State Signalized Intersections
♦ Achieved an Annual Savings of $1.3 Million in Fuel Consumption,
Reduced Energy Costs, and Mobility Benefits
.► Achieved a Benefit to Cost Ratio of 13 to 1
4 Average Citywide AM, Mid-day and PM Reductions in Travel Time (-16%),
Delays (-37%), Number of Stops (-37%) and Fuel Consumption (8%).
PROJECT DESCRIPTION
The City of Ceres selected Minagar & Associates, Inc. to develop more efficient traffic
signal timing plans along 3 designated major east -west, north -south and diagonal
corridors and streets through the City, including a total of 29 signalized intersections.
The project objective was to reduce unnecessary number of stops, vehicle delay
times, vehicle pollutant emissions as well as amount of fuel consumption via the
optimization & synchronization of traffic signal timing of major arterials and grid
network roadways and streets.
The signalized intersections under this study were spread across the City of Ceres,
with State Routes locations at SR -99 on- and off -ramp intersections. The project was
comprised of the following major tasks: field data collection, "before and after" study
travel time & delay studies and performance evaluation, model coding and
calibration, SimTraffic optimization, Synchro timing plans, optimized plan selection
and implementation, field timing deployment, fine tuning, and after study field
performance evaluation.
The collaboration among the City staff, Caltrans and the consulting team resulted in a
very successful implementation of the new optimized timing plans for this program.
During the AM, mid-day and PM peak hours, total travel time was reduced by an
average of 16%; total delays were decreased by 38%; and the total number of stops
was reduced by 37%. Fuel consumption decreased by approximately 8%.
LOCATION
♦ Ceres, Stanislaus County, California
SCOPE OF WORK
J Field Data Collection of 29 Signal Locations
AM/MD/PM Peak -Hr Intersection Counts
Lane Geometrics
Signal Timing & Phasing Parameters
4 Traffic Engineering
4 Computer Modeling, Coding, Calibration,
Optimization, Retiming & Simulation
4 Network/Subnetwork/Corridor Adjustments
4 TOD Timing Charts & Synchronization Plans
- 170 Controller Type Format Conversion on
BiTran 200SA Program
- Caltrans C-8 Timing Charts
4 Traffic Signal Timing Installation and
Field Implementation, Support & Fine -Tuning
# "Before & After" Caltrans D-10 Performance
Evaluation
CLIENT
4 City of Ceres, CA
Ann Herner, Project Manager
Public Works Department, Engineering Division
2220 Magnolia Street
Ceres, CA 95307
(209) 538-5776
a n n. h ern er(a7ci.ce res. ca. us
PROJECT IMPLEMENTATION COST
• $100,000.00
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Chino Hill,. Pkwy at
Carbon Canyon Rd.
Chino Hills. Pkwy at
Chine Ave. at Peyton Dr.
Grand Ave. at Peyton Dr.
Int& j • tu. Avr. at Parton Dr.
Chino Hint Pkwy. at Pipeline Ave.
Chino Hills P . at Ramona Ave.
!equal Canyon Pkwy at
Los Sorrento Country Club DrJ
Butterfield Randa Rd.
Sequel Canyon Pkwy &
Pomona !moon Rd.
Chino Hill, Pkwy.
at Peyton Dr.
Pipeline Ave. at
Woodvlaw Rd.
Legend:
® Signalized Study Intersection
OUnsignalized Study Intersecdon
Existing number of travel lanes
In each direction
Functional Classification:*
• ■ ■ t Corridor**
Stat. Route
Princ pal Arterial
Minor Arterial
Co ector
— Minor Co ector
- Local Street
CITY OF
CHINO
HILLS
tutt.rfleld Ranch Rd. at
Pine Ave.
Citywide Transportation/Circulation Element,
Traffic Impact Study & CMP Analysis for
Chino Hills' General Plan Update
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared a citywide
traffic impact study, and assisted City of Chino Hills' staff with preparing the
Transportation/Circulation Element for the City's 2012 General Plan Update.
The traffic study analyzed the existing citywide transportation and circulation
system, forecasted future travel demands and identified potential traffic
impacts under the Existing Year 2012 conditions, as well as those likely to
occur on city streets within future 15 -year (Year 2027 projection) and build -out
(Year 2037) scenarios. The study also provided various recommended short -
and long-term improvement measures to alleviate potential traffic impacts to
levels of insignificance on city streets and intersections.
Minagar staff provided roadway machine counts for fifty-four (54) citywide
segments and conducted turning movement traffic counts at twelve (12) major
signalized intersections on the City's arterial network. Together with field
observations and measurements, a citywide traffic model was developed to
analyzed existing and future levels of service (LOS) based on the latest
Highway Capacity Manual (HCM-2010) methods. The traffic study used future
development forecasts within the City to develop Future/Build-out Year 2027
and Year 2037 scenarios, and to determine intersections and streets which
would be significantly impacted by future traffic volumes. In compliance with
CEQA requirements, the traffic study also included a Congestion Management
Program (CMP) analysis of two (2) CMP intersections and several roadway
segments within the San Bernardino County CMP Network. The CMP analysis
identified potential impacts to the existing CMP network, and provided
recommendations for preventing the occurrence of these traffic impacts.
LOCATION
Chino Hills, San Bernardino County, CA
SCOPE OF WORK
i Inventory of Citywide Traffic Volumes
• Turning Movement Counts (12 Intersections)
• Roadway Machine Counts (54 ADT segments)
4 Field Observations to ID ex. Lane Geometry, and
Signal Timing/Phasing Parameters;
4 Development of SYNCHRO 8.0 Traffic Model
r Travel Demand Forecasting
• Aggregation of Citywide Development Projects
• Trip Distribution
• Trip Generation
• Trip Assignment
4 Traffic Impact Analysis
• Existing Year 2012
Future Year 2027 (With/Without General Plan)
Build -out Year 2037 (With/Without Gen. Plan)
4 Traffic Impact Analysis
4 Recommendation of Mitigation Measures
4 CMP Analysis
4 Project Reporting, Mapping & Documentation
• Functional Classification of Citywide Roadways
Narratives of Citywide Streets, and Physical
Condition of Existing Study Intersections
• Future Conditions: Summary of Ambient Traffic
Growth Factor(s), Anticipated/Programmed
Transportation Improvements, Local
Developments in Chino Hills
CLIENT
City of Chino Hills
Joe Dyer
Assistant City Engineer
Engineering Dept. – Traffic Section
14000 City Center Drive
Chino Hills, CA 91709
(909) 364-2771 - jdver a(7rxilnohills.orq
CURRENT STATUS
4 Complete
0
D
23 Years of Exceilenee
MINAGARR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
pt alynelWd
kS Intersection
d UnsIgnnllz.d
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Highway Safety Improvement Program
(HSIP) Project for the City of Coachella &
di)Caltrans District 8
Federal Project No. HSIP-5294(006)
* PS&E and CEM for Citywide Traffic Control Device, Street Name Sign and
Signing & Striping Upgrades
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared a complete PS&E
package for the City of Coachella and Caltrans District 8 for the City's Highway Safety
Improvement Program (HSIP) Cycle 2 Project. The project included 648 upgraded street
name signs at approximately 160 unsignalized intersections; twenty-four (24) 6- and 8 -foot
overhead LED Internally -Illuminated Street Name Signs (IISNS) at 6 signalized
intersections on SR -86; 224 regulatory, warning and guide signs on Harrison Street (SR -
86) and Grapefruit Boulevard (SR -111); 13,933 LF of thermoplastic traffic striping; 757
raised pavement markers (RPMs); and 9,625 SF of thermoplastic pavement markings at 27
intersections.
The proposed upgrades were designed to conform with the most recent Manual on Uniform
Traffic Control Devices in the State of California (2010 edition of CA-MUTCD). The project
included preparing a Preliminary Environmental Study (PES) for Caltrans Review with
NEPA/CEQA CE/CE environmental clearance documentation, preparing signing and
striping plans, construction cost estimates and quantities, providing technical specifications
and providing construction engineering management and inspection services.
0 Harrison xx'xxx
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LOCATION
• Coachella, Riverside County, California
SCOPE OF WORK
♦ Preparing PS & E Documents
- 6 Signalized Intersections
- 160 Unsignalized Intersections
• Traffic Engineering
Signage:
- 648 post -mounted Street Name Signs (SNS)
24 Internally -Illuminated SNS
224 Regulatory, Warning & Guide Signs and
Object Markers
Striping:
- 4" and 8" Yellow/White Thermoplastic Traffic
Stripes
- Types "D", "G" and "H" RPMs
- 12" Yellow/White Crosswalk, Limit Line,
Chevron, Zebra and Ladder -style
Thermoplastic Pavement Markings
Thermoplastic Arrow Pavement Markings
- Stop Legend Pavement Markings
i Environmental Services
- Preliminary Environmental Study (PES)
- NEPA/CEQA (CE/CE) Clearance
♦ Bid Administration Services
- Request for Authorization (RFA) Package
- Contract Administration Checklist
CLIENT
City of Coachella
Mark Chappell, PE, Project Manager
1515 Sixth Street, Coachella, CA 92236
(760) 398-5744
FUNDING AGENCY
✓ Caltrans D-8
Savat Khamphou arlaano
464 West Fourth Street, 6th Floor, M760District a
San Bernardino CA 92401-1400
(909)383-8368/(909)383-4030
savat.khamphcuadot.ca.cov
CONSTRUCTION COST
♦ $500,000
RIHe .YAA W,ecn sUMW
db
•
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
�^ Eleivrnlary"moor
(Asa. plarcx
Eremeri 73ctrtnl
r—�
City of Coachella
Safe Routes to School (SR2S)
Project Locations
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• School -Age Bk%+wMgNda.r,
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edw School
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Safe Routes to School (SR2S) Project for
the City of Coachella, County of Riverside &
Caltrans District 8
PS&E and CEM for Traffic Signal, Streetscape, Signing & Striping
Improvements
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared a complete
PS&E package for the City of Coachella and Caltrans District 8 for the City's Safe
Routes to School (SR2S) Cycle 8 Project, which included traffic signal,
streetscape, and signing & striping improvements for 7 elementary/middle/high
schools in the City of Coachella and Riverside County at 16 signalized and
unsignalized intersections. The project included design, preparation of construction
cost estimates and provisions for technical specifications for a range of roadway
improvements at various locations, including: bulb -out retrofitting and pedestrian
refuge islands to enhance pedestrian safety by providing safe zones for crossing
school children and reducing the crosswalk distance between corners; catch basin
and trench drain design related to the above curb extensions to address drainage
issues; high -visibility SCHOOL signage and zebra -type striping to increase driver
awareness of school zones and downstream school crossings, PUFFIN signals
and audible pedestrian signals (APS) to improve the accessibility of crossings at
signalized intersections, and other ADA -compliant civil improvements.
Fit.A
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4114 -,-
LOCATION
4 Coachella, Riverside County, California
SCOPE OF WORK
4 Preparing PS & E Documents
3 Signalized Intersections
- 13 Unsignalized Intersections
- 7 Schools (Elementary/Middle/High)
♦ Civil Engineering
- 8 Bulb-outs/Curb Extensions
5 Pedestrian Refuge Island Medians
Storm Drain/Catch Basin Design
- Sidewalks, Driveways, Curb & Gutter
Decomposed Granite (DG) Paths
- Bollards/Guard Posts
ADA Compliant Curb Ramps with High
Visibility Truncated Dome Detectable
Warning Surfaces
• Traffic Engineering
- In -Street Pedestrian Crossings
- SCHOOL Sign Assemblies A/B/C/D
Zebra -striped Thermoplastic X -Walks
Advance Stop Bars/Limit Lines
- Yield Lines and Signage
Painted median hatching
- SLOW-SCHOOL-XING markings
RPMs and Caltrans Std. Lane Striping
-# Electrical Engineering
Countdown Pedestrian Signal Heads
Audible/Accessible Pedestrian Signals
PUFFIN Pedestrian Crossing Signals
Rapid -Flash LED Pedestrian Beacons
- Overhead Crosswalk Task Lighting
• Environmental Services
CLIENT
City of Coachella
Mark Chappell, PE, Project Manager
1515 Sixth Street, Coachella, CA 92236
(760) 398-5744
FUNDING AGENCY
▪ Caltrans D-8
Savat Khamphou
464 West Fourth Street, 6th Floor, M760
San Bernardino CA 92401-1400
(909) 383-8368 / (909) 383-4030
savaLkhamphou(5 doLr .qoy
Ithr
atibunst
District 8
CONSTRUCTION COST
4 $490,000
23 Years of Excel once
MINAGAR & ASSOCIATES, SNC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
City Traffic Engineering & Transportation Planning
Consultant Services for the City of Colton
PROJECT DESCRIPTION - Minagar & Associates, Inc. has provided
contract city traffic engineering services to the City of Colton since
early 2013. Major traffic engineering tasks have included preparation
of traffic control device warrant studies in conformance with the latest
Calfornia Manual on Uniform Traffic Control Devices (2012
CAMUTCD), sight distance analyses, independent intersection
improvement recommendations, and review of developer traffic
studies. Representative list of completed task orders include:
• Traffic Control Device Warrant Assessment for La Cadena Drive and
Litton Avenue
• Truck Trip Generation Study and TIA review for the Agua Mansa
Warehouse/Distribution Center Development
• Traffic Control Device Warrant Analysis for the intersections of: Olive
Street at Redlands Avenue; Pennsylvania Avenue at Mill Street; Meridian
Avenue at Poema Drive; La Cadena Drive at D Street; La Cadena Drive
at E Street; Cooley Drive at Old Ranch Road; La Cadena Drive at M
Street; Congress Street at Pine Street; and Congress Street at Florez
Street
• Citywide Engineering & Traffic Survey (E&TS) for 44 Speed Zone
Segments
R.CnminyMsd Tripp Ganaranon RAMP
City of Cannel's Ayrla Mansa iatti6drs Can er'
I-.20 al.
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naak
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LOCATION
♦ Colton, San Bernardino County, California
SCOPE OF WORK
4 Traffic Signal Modification Plans
4 Temporary Traffic Control Detour Plans
4 Traffic Studies
- Truck Trip Generation Study
Review of Developer Traffic Impact Studies
Traffic Control Device Warrant Analyses
o Multi -way Stop Controls
o Flashing Warning Beacons
o Pedestrian Signals
o Signalized Intersections
o Marked Crosswalks
Sight Distance Analyses
Citywide Engineering & Traffic Survey (E&TS)
* Traffic Data Collection
- Intersection Turning Movement Counts
Roadway 24 -Hour Machine Counts
Radar Spot Speed Survey Counts
4 Municipal Traffic Engineering
- On -street parking zone ordinance evaluation
Speed hump policy study & recommendations
- Engineering Plan Check Services
Peer Review of Private Developer Traffic
Studies
CLIENT
City of Colton
Victor Ortiz
Engineering Manager
Public Works Dept. - Engineering Division
160 S. 10th Street, Colton, CA 92324
(909) 370-5065
vortiz{cci,colton.ca.us
CURRENT STATUS
4 On-going
j
100 •aO 400 WO 100 400 /00 10/1 NM nW 1100 Ipp
MAJOR STREET—Total of Both Approaches (vph)
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LA CADENA DI?1VF
0 MINAGAR & ASSOCIATES, INC.
j23 Years of Excellence
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TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
66
California Route 66 Adaptive Traffic
Control Systems PS & E
4 Caltrans' First A TCS Proiect
PROJECT DESCRIPTION
**0
Minagar & Associates, Inc. prepared a complete PS & E package for
the California Department of Transportation (Caltrans D-7). The
project was under the Governor Schwarzenegger's "Go California"
initiative.
The project's PS & E design was completed within 6 months and
was constructed within the 6 months thereafter. The construction and
design were completed on time and within budget. The project
encompassed approximately 5.5 miles of the Historic Route 66
traversing the Cities of La Verne, Pomona, and Claremont in the
eastern region of Los Angeles County.
The project included design of 4 new Closed Circuit Television
(CCTV) cameras strategically located along the famous Route 66,
design of fiber optic backbone system, provision of ATCS computer
software, as well as new 2070L traffic signal controllers at 18
signalized intersections.
aa•A•TaOIT OF TRAORPOOTATIOO
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LOCATION
4 Los Angeles County, California
SCOPE OF WORK
4 Preparing PS & E Documents
4 Civil Engineering
• Systems Engineering
4 ITS Engineering
4 Electrical Engineering
CLIENT
./ Caltrans District 7
Ajay Shah, P.E.
Senior Transportation Engineer
100 S. Main Street, Ste. 100
Los Angeles, CA 90012
(213) 897-0070
AGENCIES
4 Los Angeles County
Department of
Public Works
4 City of Claremont, CA
4 City of La Verne, CA
▪ City of Pomona, CA
e/bwr
District 7
(Th.
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CONSTRUCTION COST
4 $1.2 Million
AWARDS
ASCE
2009 Outstanding Private
Sector Civil Engineering
Protect
Caltrans'
2009 Excellence n
Transportation Award
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Culver City's 2010 Citywide Traffic Light
Synchronization Project (TLSP) Along 10 Major
Corridors with 102 Signals in Los Angeles County
PROJECT DESCRIPTION
Minagar & Associates, Inc. was selected by the City of Culver City to
synchronize and retime 102 traffic signals along 10 major regional arterials
south of 1-10 Santa Monica Freeway, east of 1-405 San Diego Freeway, and
both north and south of SR -90 Marina Freeway. Field traffic counts, geometries,
capacity, speed and travel time data were collected at 102 signalized locations.
The project also includes the following:
▪ Average Daily Traffic (ADT) counts at major "valve" points into the
system and Turning Movement Counts (TMC) at pivotal intersections;
▪ "Before" and "After" studies using a combination of the latest state-of-
the-art technology to simulate and model existing conditions on Synchro
computer, as well as field -verified "floating car" methods;
Optimized signal timings along 10 corridors during AM, midday, PM and
typical weekend periods; and Optimum traffic signal timing plans
developed to minimize delay, number of stops and overall travel times for
the regions' commuters;
102 final optimized signal timings converted to 170 controller formats in
accordance with the City's format;
• Signal timings input into BiTran 233CC and 233TH for the City's format;
• The preparation of comprehensive reporting to document the outstanding
MOEs for mobility, energy and environmental improvements
LOCATION
♦ Culver City, Los Angeles County, California
SCOPE OF WORK
J Field Data Collection of 102 Signal Locations
4 Traffic Engineering
i Computer Modeling, Optimization,
Retiming & Simulation
• BiTran 233CC & 233TH Timing Charts
- KITS System Update
- 170 Controller Type Format Conversion
J Traffic Signal Timing Installation
CLIENT / AGENCY
# City of Culver City, CA e„0} CITY
Gabe Garcia
V
PublicWorks Department
Division
9770 Culver Boulevard
Culver City, CA 90232-0507'
(310) 253-5633 District 7
CONSTRUCTION COST
,F $500,000.00
29% Average improvement
Mobility Savings
ANNUAL SAVINGS
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
ROSECRANS AVE4
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Legend:
- Existing Signalized Intersections
gmfr signal
of reiei (Project)
- Existing Rashing Beacons
y -t Ped. (lasting beacon
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1:1- City of Lawndale Boundary
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INE: - Park
Lawndale's Citywide Traffic Signal
Upgrades and Modifications Project at
Eighteen (18) Signalized Intersections
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared a full Plans,
Specifications and Estimates (PS&E) package for the City of Lawndale to
implement various citywide improvements at eighteen (18) signalized
intersections, aimed at establishing uniformity within the City's existing
infrastructure, as well as bringing it to a state-of-the-art/technology/practice.
Minagar staff performed an initial field survey of the 18 intersections to
determine areas of deficiency (e.g., identification of small vehicle heads
needing replacement with 12" plus backplates; obsolete, damaged and/or non-
uniform pedestrian pushbuttons (PPB); need for ped. countdown heads, ADA -
compliant curb ramps with detectable warnings; ladder -type SCHOOL zone
crosswalks; need for internally -illuminated street name signs (IISNS) at
unidentified intersection approaches; identification of warranted protected left -
turn phasing at existing two-phase signals; and any need for battery back-up
systems). A set of as -built base plans was prepared, submitted and approved;
and traffic signal modification plans were then prepared to identify the
proposed signal/electrical equipment upgrades, ADA ramp replacements, and
other signing/striping improvements. Technical specifications were prepared in
conformance with the latest Caltrans/APWA/L.A. County requirements.
LOCATION
♦ Lawndale, Los Angeles County, CA
SCOPE OF WORK
J Field Observations and Identification/Inventory
of Existing Infrastructure and Deficiencies;
Protected Left -turn Phase Warrant Analysis
• Preparation of Plans, Specifications & Estimates
• As -built Signal Base Plans
• Traffic Signal Modification, Signing & Striping
and Roadway Improvement Construction Plans
• Technical Specifications & Provisions
• Engineer's Cost Estimate
• Proposed Improvements:
• Replace ex. 8" signal heads with 12" RYG
• Install Pedestrian Countdown Heads
• Replace ex. PPBs with Polara Bulldog PPB
and Caltrans latest standard sign
• Furnish/Install Internally -Illuminated Street
Name Signs (IISNS)
• Install Battery Back-up Systems (BBS)
• Replace ex. traffic signal cabinets
• Replace ex. Type 15/1-A signal poles with new
mast arm standard
• Replace ADA ramps w/ detectable warnings
4 Coordination with L.A. County, and neighboring
Cities of Redondo Beach and Hawthorne
CLIENT
City of Lawndale
Miguel Alvarez, P.E.
Associate Engineer/PM
14717 Burin Avenue,
Lawndale, CA 90260
(310) 973-3265
Malvarez�a3lawnllaleclly ora
CURRENT STATUS
• Anticipated Completion: Early 2015
CONSTRUCTION COST
J $1.2 M
23Years of Excellence
MINAGAR St ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
immitima Metro's Interstate 210 Truck Origin and
Destination (O -D) Study over 20 miles of
Freeway through 7 Cities in L.A. County
PROJECT DESCRIPTION:
Minagar & Associates, Inc. Team was selected by Los Angeles County
Metropolitan Transportation Authority (MTA) to conduct a Truck Origin and
Destination (O -D) Study along the Foothill Freeway of Interstate 210 between
the interchanges with SR -134 on the west and SR -57 on the east, in Los Angeles
County. The project corridor consisted of 20 miles of freeway mainline and 100
square miles of local study area through 7 cities in the San Gabriel Valley.
The Study included the collection, archiving, data basing, data mining and
subsequent analyses of data for 13 distinct classes of commercial/heavy duty
trucks along the 1-210 corridor—including origin, destination, local and regional
routing, daily and hourly volumes, types of cargo transported, travel frequency,
truck classification type, route choice, gross weight, and areas for potential
improvements for truck freight transportation—in support of Metro's goal to gain a
working knowledge and statistical information on goods/freight movement
through the 1-210 corridor. The data was obtained through literature and historical
data reviews, traffic counts and field data collection, conducting in-person truck
driver intercept surveys and administering mail -in and fax surveys of
warehouses, distribution centers and fleet operators throughout the corridor. The
project also included developing and managing a comprehensive database of the
collected data for archiving, retrieving, analyzing and reporting origin -destination,
goods movement routes and other cross-reference queries.
LOCATION
• Los Angeles County, California
SCOPE OF WORK
✓ Traffic Counts & Field Data Collection
- Manual Turning Movement Counts
- 13 FHWA Truck Axle/Classification Counts
- Video Classification Counts
a Truck Operator Surveys
- 420 Truck Driver Intercept Surveys
- 3,831 Surveyed Trips via Fax Surveys of
Warehouses, Distributors & Fleet Operators
i Database Management and Analysis
CLIENT
4 Los Angeles County Metropolitan
Transportation Authority
Teresa Fong, Project Manager
One Gateway Plaza
Los Angeles, CA 90012-2952
(213) 922-2854 • E-mail: fongte( metro.net
12) Metro
PARTNER AGENCIES
• Caltrans District 7
J Southern California Association of
Governments (SCAG)
4 Cities of Pasadena, Arcadia, Monrovia,
Duarte, Irwindale, Azusa, Glendora
rte.
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Modesto's 121 Traffic Signals
Retiming Project Outside the
Central Business District Along 21
Major State, County & City Corridors
4 Achieved an Annual Savings of $9.4 Million in Fuel Consumption
4 Achieved a Benefit to Cost Ratio of 50 to 1
J Reduced number of stops by 46%, 51% and 50% during AM, MD &
PM, respectively.
PROJECT DESCRIPTION
Minagar & Associates, Inc. was selected by the City of Modesto & Caltrans District
10 in Northern California to synchronize and retime 121 traffic signals along 21 major
regional Caltrans', Stanislaus County and City of Modesto's arterials. Field traffic
counts, geometries, capacity, speed and travel time data were collected at 121
signalized locations.
"Before" study was conducted using the latest state-of-the-art technology to simulate
and model existing conditions on Synchro computer. Optimized all the signal timings
along the 21 corridors during AM, midday, PM and typical weekend periods.
Developed optimum traffic signal timing plans that minimized delay, number of stops
and overall travel times for the regions' commuters.
Utilized TRAF-NETSIM and Sim -Traffic computer models to simulate and validate
the optimized timing plans. Converted all the 121 final optimized signal timings to
170 controller formats in accordance with the City's and Caltrans formats. Utilized
QUICLOAD software to input the signal timings in BiTran 200 CA, 200 SA, 233 for
the City and C-8formats for Caltrans.
Conducted "After" Study travel time and delay field reconnaissance to evaluate
signal timing improvements and changes in the Measures of Effectiveness (MOEs).
Prepared a comprehensive report to document the outstanding MOEs for mobility,
energy and environmental improvements.
The project has won numerous awards from the local, state and national
organizations. The project success has reached the headline news of the print & TV
media in Northern & Central California.
LOCATION
4 Modesto, Stanislaus County, California
SCOPE OF WORK
▪ Field Data Collection of 121 Signal Locations
4 Traffic Engineering
d Computer Modeling, Optimization,
Retiming & Simulation
• BiTran 200CA, 200SA & 233 Timing Charts
- Caltrans C8 Timing Charts
- QuicNet System Updates
- 170 Controller Type Format Conversion
4 Traffic Signal Timing Installation
CLIENT
4 City of Modesto, CA MODESTQ
Mark Murphy, P.E., Project Mgr. a Q �r�
Engineering & Transportation Department
1010 Tenth St., Suite 4500
Modesto, CA 95353
(209) 577-5431
eft
AGENCY
afr
a
• Caltrans D-10 District 10
Clint Gregory, P.E., Chief Electrical Systems
1976 East Charter Way
Stockton, CA 95205
(209) 948-7154
CONSTRUCTION COST
a $145,000.00
AWARDS
4 Winner of the PTI's Best Transportation
Technology Solutions Award in the
United States
b Award of Excellence, Best California
Return on Investment Project, ITS -
California
J Top Nominee of California
Transportation Foundation's Best
Highway Management Program in the
State of California
•
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
0
frf
Modesto's 145 Traffic Signals
Retiming Project Outside the
Central Business District Along 22
Major State, County & City Corridors
♦ Achieved an Annual Savings of $1.126 Million in Fuel Consumption
♦ Achieved a Benefit to Cost Ratio of 35 to 1
♦ Reduced number of stops by 30%, 25% and 20% during AM, MD &
PM, respectively.
PROJECT DESCRIPTION
The City of Modesto selected Minagar & Associates, Inc. to develop more efficient
traffic signal timing plans along 22 designated corridors in the City. The project
objective was to reduce unnecessary number of stops, vehicle delay times, vehicle
pollutant emissions as well as amount of fuel consumption via the optimization &
synchronization of traffic signal timing of major arterials and grid network roadways
and streets. A total of 145 signalized intersections spread across the City of Modesto
were included in the project, comprising all of the City's major east -west, north -south
and diagonal arterlals and streets outside of the Central Business District (CBD), or
"downtown'. area. State Routes in the project area project included SR -108 McHenry
Avenue, SR -132 Yosemite Boulevard (and Maze Boulevard at the south end of
Carpenter Road), and SR -99 freeway ramps at the west ends of the Pelandale,
Standiford, Briggsmore and Kansas Corridors.
The project was comprised of the following major tasks: field data collections,
before -study travel time & delay studies, model coding and callbration, SimTrafftc
optimization Before and After performance evaluation, Synchro timing plans,
optimized plan selection and Implementation, field timing deployment, fine tuning,
and after -study field performance evaluation.
The collaboration among the City staff, Caltrans District 10 and the consulting team
resulted in a very successful implementation of the new optimized timing plans for
this important program for the citizens and motorists of Modesto and Stanislaus
County. The total benefits from delay savings, reduction in stops, and fuel
consumption reduction for the Modesto residents has been $10,199,838 annually.
Based upon an estimated project cost of $290,000, the overall benefits -to -cost (B/C)
ratio for this traffic signal synchronization project is 35 to 1.
LOCATION
♦ Modesto, Stanislaus County, California
SCOPE OF WORK
• Field Data Collection of 145 Signal Locations
J Traffic Engineering
J Computer Modeling, Optimization,
Retiming & Simulation
• BiTran 200CA, 200SA & 233 Timing Charts
Caltrans C8 Timing Charts
QuicNet System Updates
- 170 Controller Type Format Conversion
4 Traffic Signal Timing Installation
CLIENT
4 City of Modesto, CA MgQESTQ
Mark Murphy, P.E., Project Mgr. ,� n i -b. N
Engineering & Transportation Department
1010 Tenth St., Suite 4500
Modesto, CA 95353
(209) 577-5431
AGENCY Ifr
J Caltrans D-10 District 10
Clint Gregory, P.E., Chief Electrical Systems
1976 East Charter Way
Stockton, CA 95205
(209) 948-7154
CONSTRUCTION COST
4 $280,000.00
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23 Years of Excellence
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MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
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NEW CCTV (DOW)
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Palmdale's Avenue -R Traffic
Signal Fiber -Optic Interconnect,
CCTV and Video Detection PS&E
PROJECT DESCRIPTION
Minagar & Associates, Inc. prepared a complete PS&E package for the installation
of 4.1 miles of multi -duct and fiber-optic interconnect and communications
conduits; Video Detection System (VDS) for 4 intersections; 9 CCTV cameras; 4
Vaults; system communications equipment at the City's Traffic Operations Center
(TOC), NECCAMS software, workstation, video switching card, microprocessor
camera control system, multi -port serial cards; fiber-optic modems to transmit
video and data from the field elements (i.e., traffic signals, CCTVs and VDS) to the
City's TOC; and installation of spread spectrum radios for the connection of
CCTVs and signals over Metrolink and SP railroad tracks.
The following tasks were also performed: Utilities compilation, Left -turn phase
warrant assessment, traffic signal upgrade assessment, Turning Movement
Counts (TMC), Capacity assessment and Synchro timing.
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LOCATION
4 Palmdale, Los Angeles County, California
SCOPE OF WORK
4 Traffic Engineering & Design
♦ ITS Engineering
4 Systems Engineering
4 Civil Engineering
♦ Traffic Control Plans
CLIENT
4 City of Palmdale
Bill Padilla
City Traffic/Transportation Engineer
Public Works Department
38250 Sierra Highway
Palmdale, CA 93550
(661) 267-5363
feeeD
AGENCIES
♦ Metro (Los Angeles County
Metropolitan Transportation
Authority)
Roger Martin
One Gateway Plaza
Mail Stop: 99-22-9
Los Angeles, CA 90012-2952
(213) 922-1462
Metro
CONSTRUCTION COSTS
• $1,115,000
AWARDS
Winner ofAPWA's
Best Traffic Congestion
Mitigation Project of the
Year in Southern California
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
- ____ % PROJECT CORRIDOR CONDITIONS DIAGRAM
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Existing. Proposed and Future
TraRY Slinal Intef(eed Transportation System (RS) and
Systems Commlnkatbn hirskneure and Improvements
1[.1lhu Vim [ 6401[: rr1
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PS&E for Palmdale's North County Traffic
Forum: Phase 1 ITS Expansion Project —
Rancho Vista Boulevard and Avenue N
PROJECT DESCRIPTION
Minagar & Associates, Inc. prepared a complete PS&E
package for the installation of 3.25 miles of new HDPE
conduit (x3); Installation of 72 single -mode fiber-optic (SMFO)
interconnect cable; A new traffic signal at Avenue 0-8; Three
(3) new CCTV installations; Type 2070 controller upgrades at
six (6) locations; and various Traffic Operations Center (TOC)
hardware/software upgrades to modernize the City's existing
communication system and interface with the County of Los
Angeles' Information Exchange Network (LACDPW IEN).
LOCATION
4 Palmdale, Los Angeles County, California
SCOPE OF WORK
4 Traffic Engineering & Design
• ITS Engineering
♦ Systems Engineering
♦ Civil Engineering
4 Traffic Control Plans
4 Preparation of Traffic Signal, Fiber -
Optic and ITS Technical Specs
♦ Engineer's Cost Estimates
CLIENT
• City of Palmdale
Bill Padilla, P.E.
City Traffic Engineer
Public Works Department
38250 Sierra Highway
Palmdale, CA 93550
(661) 267-5363
AGENCIES
♦ Metro (Los Angeles County
Metropolitan Transportation
Authority)
Roger Martin
One Gateway Plaza Metro
Mail Stop: 99-22-9
Los Angeles, CA 90012-2952
(213) 922-1462
CONSTRUCTION COSTS
♦ $985,000
w
i
lltf W
—414/3
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
xAlessandro Blvd.
Temporary Traffic
Control Wilfpnstrucl,
• Traffic Control Plans (TCP) for MWD's
illyPerris Valley Pipeline North Reach
Construction in Riverside County
' Alessandro Boulevard Traffic Control Plans, Including Signing & Striping,
Temporary Traffic Control Zone Device and Traffic Signal Plans
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared traffic control plans for
the Metropolitan Water District (MWD) of Southern California's Perris Valley Pipeline
Project. In total, the project consists of 6.5 miles of 96 -Inch pipeline from Metropolitan's
Henry J. Mills Water Treatment Plant, east along Alessandro Boulevard, then turning south
to Oleander Street in the right-of-way paralleling the 215 Freeway. Our TCPs covered the
2.5-m€le span of Alessandro Boulevard from Mission Grove Parkway to the 1-215 Freeway.
Traffic control efforts throughout each construction phase were accomplished with the
cooperation of the Water District, the City of Riverside and Riverside County Transportation
Department.
A number of temporary traffic control zone devices were used in our plans, including signs,
delineators, changeable message signs, high-level warning devices, types I & III barricades
(with blinking lights), flaggers, sand -filled crash cushions, k -rails, and illuminated directional
arrow devices. Minagar & Associates, Inc. prepared 23 traffic control plan sheets for each
construction phase, including 12 signing & striping plans and 10 temporary traffic signal
plans Signage included the following signs: W6 -3,G20-2, C17(CA)(45), R3-2, R3-18, R11-
2, W3 -5a(45), W20-1, R4 -7a, C40(CA), C30(CA), W4-7, R3 -7(R), W23-1. Construction
activities external to the placement of traffic control devices included sandblasting
existing/conflicting striping; removing reflective pavement markers (RPMs), and installing
thermoplastic lane line striping, turn lane arrows, crosswalk lines, and bike lane lines. TCPs
were prepared per the CA-MUTCD and WATCH Manual -
1
SYCAMORE CANYON BLVD.
ALESSANDRO BLVD
r- a11
MERIDIAN PARKWAY
LOCATION
4 Riverside, Riverside County, California
SCOPE OF WORK
4 Preparing Traffic Control Plans (TCP)
- 23+ traffic control plan sheets
- 12 signing & striping plans
- 10 temporary traffic signal plans
- 8 signalized intersections
- 11 unsignalized intersections
CLIENT
4 Metropolitan Water District (MWD) of
Southern California
Tim Skrove
P.O. Box 54153
Los Angeles, CA 90054-0153
(951) 682-9066
4 City of Riverside
5950 Acorn Street
Riverside, CA 92504
(951) 351-6140
4 County of Riverside
Department of Transportation
4080 Lemon Street
Riverside, CA 92502
(951) 955-6800
FUNDING AGENCY
4 Metropolitan Water District (MWD)
CONSTRUCTION COST
$127,000,000
• Add
▪ ti..
~123 Years of Excellence r
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
joeSanta Clarita's Intelligent
Transportation Management
Systems (ITMS) & Thoroughfare
Signal Systems
4 CCTV, Fiber Optic, Video Detection, TMC, Interconnect, Signal
Systems Design, PS & E and CEM Assistance
r. =-a
illiIMSImMimi
MI
PROJECT DESCRIPTION
Minagar & Associates, Inc. as Prime Consultant prepared a PS&E package for
over 16 1/2 miles of 12 SMFO & 96 SMFO fiber optic systems communications
cables and 15 new Closed Circuit Television Cameras (CCTV). Integrated 8
existing Video Detection System (VDS) locations. Withdrew 58,240 LF of existing
Signal Interconnect Cable (SIC) and replaced new conductors with 27,506 LF of 3"
new conduits and 12,000 LF of new Maxcell dividers in conduits. Installed 2 Viper
8000 switches, 310 Fiber Optic Route markers, 193 new No. 6 pull boxes with
extensions and 40 new system detector loops. Designed a brand new Traffic
Operation Center (TOC/TMC) to monitor flow of traffic along 22 major regional
arterials in the North Los Angeles County sub -region with inter -ties to the Los
Angeles County's IEN system and Caltrans District 7's new RTMC.
LOCATION
# Santa Clarita, California
SCOPE OF WORK
•i Engineering:
Intelligent Transportation Systems (ITS)
Systems Engineering
Traffic Engineering
Construction Engineering Management
Assistance
CLIENT
4 City of Santa Clarita
Terry M. Brice, Project Manager
23920 Valencia Boulevard, Suite 300
Santa Clarita, CA 91355
(661) 286-4137
AGENCY
# Los Angeles County Metropolitan
Transportation Authority
Roger Martin
One Gateway Plaza
Los Angeles, CA 90012 Metro
(213) 922-1462
CONSTRUCTION COSTS
i $3.5 million
AWARDS
ASCE
Ana,/e•n Sod.ty of Civil EngMrn
Winner of ASCE Metropolitan Los Angeles 2007
Outstanding Public/Private Partnership Civil
Engineering Project of the Year.
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Santa Monica Freeway Smart Corridor Evaluation
Evaluation of Santa Monica (Interstate 10)
Freeway "Smart Corridor"
4 The First "Smart Corridor" Project in the United States
PROJECT DESCRIPTION
Minagar & Associates, Inc. performed a systems evaluation of the
Santa Monica (Interstate 10) Freeway, known as Smart Corridor
located in Los Angeles.
The project boundaries were between downtown Los Angeles &
Interstate 405. Over 420 state and local traffic signals' operations
were evaluated in the Cities of Los Angeles, Beverly Hills, Santa
Monica and Culver City.
ATSAC system of the City of Los Angeles (LADOT) and
responsiveness of California Highway Patrol (CHP) units to traffic
collision scenes along the Smart Corridor were also evaluated. The
existing system was modeled into the Synchro computer program
and it was then simulated for further assessments.
Four (4) main parallel regional arterials—Pico Blvd., Olympic Blvd.,
Adams Blvd., and Washington Blvd.—were also modeled, simulated
and evaluated as well. Operations of the CCTVs and other ITS
components were assessed for this nationally acclaimed project.
LOCATION
♦ Los Angeles County, California
SCOPE OF WORK
4 Computer Modeling & Simulation
4 Intelligent Transportation Systems (ITS)
4 Systems Engineering
4 Traffic Engineering
4 Transportation Planning
CLIENT
Booz 1 Allen 1 Hami'tton
J Booz Allen Hamilton, Inc.
Yonel S. Grant, Senior Associate
101 California Street
San Francisco, CA 94111
(415) 281-4962
4 Los Angeles County Metropolitan
Transportation Authority
Peter H. Liu, ITS Program Manager
One Gateway Plaza ID
Los Angeles, CA 90012
(213) 922-2813 Metro
AGENCIES
Federal Highway
Administration
# Federal Highway Administration
(FHWA)
4 California Highway Patrol (CHP)
4 Caltrans District 7 Ehr
• Los Angeles County Department
of Public Works
• City of Los Angeles, LADOT L T
♦ City of Beverly Hills, CA
4 City of Culver City, CA
4 City of Santa Monica, CA
CONSTRUCTION COSTS
$46 Million
23 Years of Excellence
IVIINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
ia3sArigeiss.,
1
2Q.
2 4 5. 1
EI em4c s< t9 t 3'
Oyer 1 11
26 25 28 11.5
Q�;r-Ei;� : 324 aok$ 11
I23 1& R *Inst• -
21 13 al,x at 0 .
` 18 12 _ 8 [iufttngtort Dr
Z.
•22 Mip4.44
As -Needed Consulting Traffic Engineering
Services for the City of South Pasadena
PROJECT DESCRIPTION - Minagar &
Associates, Inc. began providing contract
city traffic engineering services to the City
of South Pasadena in 2010. Major traffic
engineering tasks have included traffic
engineering studies, preparation of traffic
signal timing charts (e.g., BI -Tran 233),
fiber-optic backbone system evaluation,
ITS master planning, and preparation of a
grant application for a central traffic
management and central control system
citywide ITS project—including Project
Study Report Equivalent (PSRE) and
Operations & Maintenance (O&M)
manuals. Additional traffic engineering
traffic task order included CMP
intersection operations analysis, a traffic
calming recommendations study, stop sign
warrant and safety analyses at five (5)
intersection locations, corner sight
distance approach and departure analyses
at two stop -controlled intersections,
preparation of a local and regional truck
route study with improvement
recommendations, and numerous radar
speed, intersection traffic volume, queuing
and roadway machine counts field data
collection tasks.
LOCATION
4 South Pasadena, L.A. County, California
SCOPE OF WORK
4 Traffic Signal Timing Charts
4 Fiber-optic Backbone System Evaluation
4 ITS Master Planning
4 Grant Funding Application
- Metro Call -For -Projects Application Package
for a Central Traffic Management and Central
Control System ITS Project
PSRE Preparation
O&M Manual Preparation
Benefit/Cost (B/C) Forecast Analysis and
Signal System Modeling
Traffic Studies
- Stop Sign Warrant Analyses
- Before/After Traffic Simulation Analysis
- Sight Distance Analyses
Truck Route Traffic Analysis & Legal Study
- Traffic Calming Recommendations Study
4 Traffic Data Collection
- Intersection Turning Movement Counts (TMC)
Roadway 24 -Hour Machine Counts
Radar Spot Speed Survey Counts
Vehicle Queuing Measurement
- Vehicle Classification Counts
4 Traffic Operations Analysis
- CMP intersection Capacity Analysis
CLIENT
City of South Pasadena
Paul Toor, P.E.
Director of Public Works
1414 Mission Street
South Pasadena, CA 91030
(626) 403-7240 • •-•110
ptoor{�7ci.soutlh-❑asadena.ca.us
CONTRACT COST
i $60,000
CURRENT STATUS
J On-going
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
it California State Routes 57 (Orange)
Aik and 60 (Pomona) Freeways Interchange
MD Improvements Feasibility Study
♦ Traffic Engineering and Right -of -Way Assessment Services
PROJECT DESCRIPTION
Minagar & Associates, Inc. conducted a comprehensive existing baseline
operational analysis and right-of-way acquisition cost assessment for the SR 57/60
Interchange Improvements Feasibility Project, located at the junction of State
Routes 57 and 60 in the cities of Diamond Bar and Industry, Los Angeles County.
Included 1.34 miles of freeway interchange, a 5.5 -mile diameter study area for
local intersections, 4.34 miles of freeway, 1.5 million SF of projected right-of-way
acquisition, and computer modeling of interchange and freeway networks, utilizing
the latest computer modeling software, Synchro 7.0. Construction is on-going.
LOCATION
4 Los Angeles County, California
SCOPE OF WORK
J Traffic Engineering:
- 12 Signalized Intersections
4 Major Weaving Sections
19 Ramp Junctions
19 On/Off-Ramps
- 37 Mainline Freeway Segments
• Right -of -Way Assessment
CLIENT
♦
111. CH2MHILL
CH2M Hill +
Loren Bloomberg, P.E., Project Manager
3 Hutton Centre Drive, Suite. 200
Santa Ana, CA 92707
(714) 735-6020
AGENCIES
+ Los Angeles County Metropolitan
Transportation Authority
Ben Jong, Project Manager
One Gateway Plaza irk
Los Angeles, CA 90012
(213) 922-3053 144.7 Metro
♦ Caltrans D-7 gh
Ken Young, P.E. ado,,,,,
100 South Main Street, Ste. 100
Los Angeles, CA 90012
(213)897-6091
♦ City of Diamond Bar, CA
♦ City of Industry, CA
CONSTRUCTION COSTS
♦ $250 million
� LYnt • l.5
C" City al Industry
i Z3 Veare of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
0 M O W Sr m Stanislaus County's Traffic Operations Simulation
it ® Model (TOSM) and Development of CIF' improvements
for 49 Major Arterials & 108 Countywide intersections
PROJECT DESCRIPTION:
Minagar & Associates, Inc. provided the County of Stanislaus Public Works with traffic
engineering services to develop a countywide traffic signal operations model and
feasible capital improvement projects for 25 major arterials and 108 countywide
intersections in 7 cities and unincorporated Stanislaus County. The project included:
• Deployment of a large-scale data collection effort, including collection of vehicle,
pedestrian and bicycle intersection turning movement traffic counts during
AM/MD/PM periods; lane geometry, Intersection operational characteristics and
turn queue oversaturation Inventories, digital field photo logs; and AM/MD/PM
"floating car" field surveys of corridor travel time, delay, and number of stops.
• Development of a SYNCHRO/Simfroffic micro -simulation network model,
Preparation of synchronized/optimized AM/MD/PM tithing pians For Countywide
arterials, Including input of intersection and roadway geometries, peak -hour
volumes, vehicle/pedestrian timing chart parameters, storage lanes, taper
lengths, turning restrictions and other intersection operational characteristics;
• Traffic Warrants for Signal Installation & Protected Left -turn Phases (PLTP);
• Prepared a Feasibility Study and Alternatives Analysis for Stanislaus County's in-
house and contracted traffic signal maintenance services;
• Peak -hour Queue Length and Turn Lane Pocket Assessments;
• ICU assessments and development of feasible capital improvement projects
LOCATION
J Stanislaus County, California
SCOPE OF WORK
J Data Collection
- AM/MD/PM intersection turn movement counts
- Lane geometrics, queuing, traffic controls
- Corridor "floating car" survey runs
J SYNCHRO/SimTraffic Modeling
- Baseline model development and inputs
- Optimize signal timing and network runs
- Develop Bi -Tran peak -hour timing plan
• Traffic Engineering Analysis
- Intersection Capacity Assessments (ICU)
- Traffic signal installation & protected left -turn
signal phase (PLTP) warrant assessments
- Queue/storage length evaluation
▪ Traffic Signal Maintenance Feasibility Study
4 Development of Capital Improvements
CLIENT
Andrew Malizia, P.E.
Stanislaus County Public Works
Traffic Engineering Division
1716 Morgan Road ,w
Modesto, CA 95358 it
(209) 525-4130 Public Works
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
—a!•-ni-8.��
- 1046. .,.
TEMECULA VICINITY MAP
wa riut
Temecula's ITS Deployment and
CCTV/Communication System PS&E
•i Planning, Design & CEM for a New Traffic Operations Center
4 Master Plan Design and PS&E for 8 New Pelco Dome CCTVs along
1-15, SR -79 and Major Arterials
Design and PS&E for 8 Miles of Fiber -Optic Communications Systems
PROJECT DESCRIPTION
Minagar & Associates, Inc. was selected by the City of Temecula and Caltrans
District 8 to prepare Plans, Specification & Estimates (PS&E) for Temecula's ITS
Deployment Project. The project was divided into two phases. Phase I was to
provide PS&E plans to include all work necessary to complete the functional and
administrative tasks for the design, installation, construction and integration of the
City's CCTV systems and ATMS to a fully -operational final stage. The second
phase of the project called for preparation of PS&E and installation of interconnect
cable and conduit along three (3) miles of Winchester Road between Margarita
and Murrieta Hot Springs Road. The following tasks were completed:
Phase l: CCTV and TOC Design
• Identifying and Locating Eight (8) New CCTVs
• Develop PS&E for the CCTV System
• Design of Temecula's New TOC/Systems Architecture
• Systems Implementation
• Training for the City of Temecula
• Evaluation of System and Final Report Preparation for Caltrans & FHWA
Phase ll: Interconnect Design
• Design Field Survey
• Technology Assessment (Fiber -Optic, Twisted Pair & Spread Spectrum)
• Prepare PS&E for the New Interconnect System
LOCATION
4 Temecula, Riverside County, California
SCOPE OF WORK
4 Preparing PS&E Documents
ITS Engineering
4 Civil Engineering
4 Systems Engineering
4 Electrical Engineering
CLIENT
• Jerry Gonzales
Associate Engineer
City of Temecula
Public Works/Engineering Department
41000 Main Street
Temecula, CA 92590
(951) 694-6444
AGENCIES
♦ Caltrans District 8
Thomas Ainsworth
Chief Freeway Systems
464 West Fourth St., 6th Floor
San Bernardino, CA 92401-1400
(909) 383-4535
CONSTRUCTION COSTS
♦ $1,100,000
23 Years of Excellence
MI NAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
11
PROJECTi AREA BARBERRY
Safe Routes to School (SR2S) Project for
the Town of Yucca Valley, County of San
7?.'':=11 Bernardino & Caltrans District 8
PS&E and Caltrans Environmental Clearance to Construct a Pedestrian
Traffic Signal and New Crosswalk, AC Pavement Widening, and
Extension of Sidewalk, Curb & Gutter for Yucca Valley High School
PROJECT DESCRIPTION - Minagar & Associates, Inc. prepared a complete
PS&E package for the Town of Yucca Valley and Caltrans District 8 for the Town's
Safe Routes to School (SR2S) Cycle 10 Project, which included traffic signal,
streetscape, and signing & striping improvements for Yucca Valley High School on
a 1/2± mile roadway segment on Sage Avenue, in the Town of Yucca Valley in
Riverside County.
The project included design and preparation of construction plans (including
preparation of plans, details and typical cross sections), development of
construction cost estimates, technical specifications/provisions and
investigation/documentation of findings for Caltrans environmental clearance
(Categorical Exemption/Exclusion). Project features included roadway widening
and aligning to construct new curb and gutter (traversable AC and PCC), 5' wide
concrete sidewalks adjacent to the existing pavement, relocation of water meter
boxes, signage and striping improvements, installation of a new marked crosswalk
with pedestrian flashing beacon equipment, modification of the existing cross
gutter to provide for a depressed pedestrian sidewalk and handrail system to
traverse over the existing wash across Sage Avenue (including cutoff walls and
riprap rock slope protection design per Caltrans RSP requirements).
LOCATION
♦ Yucca Valley, San Bernardino County, California
SCOPE OF WORK
♦ Preparing PS & E Documents
Electrical Engineering
- Signalized Overhead Ped Flashing Beacon
- Solar -Powered Radar Speed Feedback Signs
Civil Engineering
- 3,000 LF of new Curb & Gutter, traversable
AC berms, PCC sidewalk, street pavement
replacement;
- Rock Slope Protection (riprap)
- ADA Curb Ramps, Commercial/Residential
Driveways, and
- Re -design of existing cross gutter into a
traversable (depressed) sidewalk with cutoff
walls, RSP along the edges, pedestrian
handrails, and matching PCC cross gutter
section to allow transmission of existing hydraulic
flows across the street into the adjacent channel
Traffic Engineering
Signing & Striping, pavement markers
High Visibility Truncated Dome Detectable
Waming Surfaces (cast -in-place and surface -
applied)
♦ Caltrans Environmental Clearance
- Preparation of PES Study (Initial Findings)
- Preparation of Categorical Exemption/
Exclusion (CE/CE) Forms
CLIENT
Town of Yucca Valley
Alex Qishta, P.E., Project Engineer
58928 Business Center Drive
(760) 369-1265
aei s hta Qyucca -va l lev, o rq
FUNDING AGENCY
Caltrans D-8
Sean Yeung (Acting LAPM)
464 W. 4`h Street, 6 Floor, M760
San Bernardino CA 92401-1400
Sean. Yeunc a(?.dot.ca.gov
23Years of Excefience •�j
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
KAMM OPT
■T
DEL µO ST
Average Daily
Traffic Volume
59000 - 69000
49000 - 59000
39000 - 49000
29000 - 39000
19000 - 29000
9000 - 19000
1000 - 9000
Redondo Beach
City Limit
` Redondo Beach's 2003 Engineering &
30 Traffic (Radar Speed) Survey for 34
Roadway Segments and Speed Zones
Along 12 Major Citywide Corridors
PROJECT DESCRIPTION
Minagar & Associates, Inc. was selected by the City the Redondo Beach to conduct an Engineering
& Traffic Survey (E&TS) for 12 major arterials and local roadways in 2003 to reestablish citywide
speed limit designations in compliance with the CVC, the 2003 California Supplement to the
Manual on Uniform Traffic Control Devices (CA-MUTCD), and the select sections of the 1996
Caltrans Traffic Manual pertaining to speed zoning. The E&TS Project consisted of an initial
classification and identification of roadway types and characteristics throughout the City,
including roadside development (e.g., "scattered business," "solid residential," etc.); schools
adjacent to each segment; presence of traffic signals, signs and markings; location of divided
highway segments and speed zone limits; and relative sight distance issues. Using the initial field
survey as a basis for the E&TS, a comprehensive analysis and report was prepared which included
the following:
Speed Zoning: Included radar measurements of prevailing speeds on each segment, and
determination of 85`h %-ile and other speed factors;
Analysis of Accident Records: Recent two-year collision record compared to average rates
for similar areas and roadway facilities in L.A. County; and
Identification/Evaluation of Conditions Not Readily Apparent to Motorists: Such as safe
stopping distance, shoulder conditions, intersection spacing and offsets, profile conditions,
driveway characteristics and pedestrian traffic.
LOCATION
i Redondo Beach, Los Angeles County, CA
SCOPE OF WORK
J Field Investigation of Roadway/Roadside Conditions
4 Identification of School Zones, Recommended Speed Zone
Limits, Adjacent Land Use Characteristics, and
Location/Presence of Traffic Controls Along each Roadway
Segment
4 Evaluation of Roadway Factors Not Readily Apparent (e.g.,
SSD, shoulder conditions, etc.)
4 Speed Survey Counts Along 12 Citywide Corridors
4 2 -Year Accident Rate Analysis
4 Preparation of E&TS (Speed Survey) Report
CLIENT/AGENCY REFERENCE
,i City of Redondo Beach, CA
John Mate, P.E., Project Manager
Engineering Department
415 Diamond Street
Redondo Beach, CA 90277
(310)318-0661, 1+2277
john.mate@redondo.org
redondo
BEACH
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
IRWINDALE
LOCATION
Baldwin Park, Los Angeles County, CA
SCOPE OF WORK
° J Update to Previous Citywide E&TS conducted by
Minagar & Associates, Inc. in 2004
4 Data Collection and Field Verification of Existing Posted
Speed Limits, School and Land Use Conditions, and Critical
Roadway Factors
♦ Machine Counts (ADT) for 54 segments
i Speed Survey Measurements for 54 Segments
2 -Year Accident Rate Analysis
i Preparation of Engineering & Traffic Survey (E&TS) Report
and Recommend Posted Speed Limits
45
LA
FUENTE
Baldwin Park's 2004 Citywide Speed Survey
for 54 Roadway Segments and Speed Zones
Along 22 Major Citywide Corridors
PROJECT DESCRIPTION
The City of Baldwin Park selected Minagar & Associates, Inc. to conduct a Citywide
Speed Survey (Engineering & Traffic Survey) for 54 roadway segments on 22 major
arterials, collectors and local streets. Citywide speed limit designations for each
roadway segments were established in accordance with standard traffic engineering
procedures prescribed by the Federal Highway Administration's (FHWA) Manual on
Uniform Traffic Control Devices (MUTCD), and Caltrans' guidelines contained within its
state -adopted supplement to the MUTCD (2003 CA-MUTCD) and select sections of its
most recent Traffic Manual (later superseded by the CA-MUTCD).
The City's 2004 Engineering & Traffic "Speed" Survey consisted of a citywide field
investigation of its transportation and circulation system, prevailing posted speed
limits, an evaluation of local roadway/roadside conditions and adjacent residential and
commercial development, and an inventory of other road factors not readily apparent
to motorists. Following the field data collection effort, Minagar & Associates, Inc.
assessed the City's recent collision rates along for segment using new machine counts
(ADTs) and a recent two-year history of citywide accidents provided by the City's Police
Department. A speed zoning analysis was also conducted in conjunction with the
preparation of a comprehensive E&TS Report to recommend updates to the City's
posted speed limits.
CLIENT / AGENCY
4 City of Baldwin Park, CA
David Lopez, Project Manager
Department of Public Works
Engineering Division: Traffic Engineering
14403 East Pacific Avenue
Baldwin Park CA 91706
(626)960-4011 x458
DLopez@baldwinpark.com
Ilr�:
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23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Santa Fe Springs' 2009 Engineering & Traffic
Survey (E&TS) for 115 Roadway Segments
and Speed Zones Along 40 Major Citywide
Corridors
PROJECT DESCRIPTION
The City of Santa Fe Springs retained Minagar & Associates, Inc to conduct a Citywide
Engineering & Traffic Survey (E&TS) for 115 roadway segments along 40 of the City's
major arterial streets, collectors and local roadways to reestablish speed limit
designations throughout the City, in compliance with the California Vehicle Code (CVC),
the 2006 California Supplement to the Manual on Uniform Traffic Control Devices
(MUTCD) and the 2009 version of the Federal MUTCD.
The E&TS included an initial field inspection of each of the 115 roadway segments
throughout the City, including identification of designated SCHOOL zones, local
roadway conditions and safety factors not apparent to drivers, existing posted speed
limits, available traffic (through) lanes, location of center medians and other divided
roadway segments, and special traffic considerations at boundary -line locations with
the Cities of La Mirada, Downey, Pico Rivera, Whittier, and unincorporated L.A. County
neighborhoods.
The project also included a detailed set of radar speed survey measurements, 85th/50`h
percentile speed and pace determinations, an evaluation of local three-year local
collision rates (from Santa Fe Springs Police Department records); radar spot speed
measurements; recommendations for updates to the posted speed limits on project
roadway segments; and the preparation of an Engineering & Traffic Survey (E&TS)
Report, complete with a summary of current laws and regulations, a scope of work for
the project, speed zone and collision maps and tables, and 24"x36" wall maps for use
by the City's Public Works Department.
LOCATION
Santa Fe Springs, Los Angeles County, CA
SCOPE OF WORK
J Field Inspection of Citywide Roadway Conditions, School
Zones, Boundary Segments, Traffic Lanes and Medians
J Machine Counts (ADT) for 115 Segments
'1 Spot Speed Surveys for 115 Segments
J 3 -Year Accident Rate Analysis
i 50`h/85`h %-ile Speed Analysis and Preparation of E&TS and
24"x36" Speed Zone & ADT Wall Maps
CLIENT / AGENCY
J City of Santa Fe Springs, CA
Thomas R. Lopez, Assistant Director
Public Works Department
11710 Telegraph Road
Santa Fe Springs, CA 90670
(562)868-0511 x7342
tomlopez@santafesprings.org
California
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Z3 Years of Excallcnce
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
CRT OF MANHATTAN BEACH
MOF CIIT.W. F+ wing i Tr.Nk Bunny and T.wlk Volum Counts
Proposed Speed Zones
for 57 Roadway Segments on 15 Streets
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Manhattan Beach's 2010 Engineering & Traffic
Survey (E&TS) for 51 Roadway Segments and
Speed Zones Along 15 Major Citywide
Corridors
PROJECT DESCRIPTION
The City of Manhattan Beach selected Minagar & Associates, Inc. to conduct an
Engineering & Traffic Survey (E&TS) for major arterials and local roadways to
reestablish citywide speed limit designations in compliance with the California Vehicle
Code (CVC), the 2006 California Supplement of the Manual on Uniform Traffic Control
Devices (CA-MUTCD), and the 2009 version of the Federal MUTCD, updated by FHWA.
The project commenced in 2009 and was completed in 2010.
Field staff conducted initial field visits and video observations across all of the 51
project segments to investigate the existing roadway and roadside conditions. Data
collection and field investigations included street classifications and characteristics
such as number of lanes, presence of roadway dividers, commercial driveway spacing,
and the presence and frequency of traffic control devices. Other observed included
visibility of pedestrians and the local residential land use and density, pedestrian
activity near the downtown area, narrow street widths, on -street parking and
horizontal and vertical curvature and alignments in the "hilly" areas of the City.
The E&TS also included a comprehensive analysis local collision rates (requiring
machine counts for each segment and a study of the recent 33 -month SWITRS collision
history), speed zone analysis (requiring spot speed surveys at each segment), and the
preparation of an Engineering & Traffic Survey (E&TS) Report, complete with a
summary of current laws and regulations, a scope of work for the project, segment
narratives, and appropriate maps, tabulations and supporting appendices documenting
speed measurements, ADTs and collision reports.
LOCATION
J Manhattan Beach, Los Angeles County, CA
SCOPE OF WORK
4 Field Survey and Video Observations of
Roadway/Roadside Conditions, School Zones, Senior
Center Zones, Horizontal/Vertical Curvature, On -street
Visibility, Adjacent Land Use Density, Traffic Controls and
Pedestrian & Bicycle Activity
4 Machine Counts (ADT) for 51+ Segments
4 Speed Survey Counts for 51+ Segments
4 3 -Year Accident Rate Analysis
4 GIS Mapping of Speed Zones and 2009/10 ADT
4 Prepare Engineering & Traffic Survey (E&TS) Report
CLIENT/AGENCY REFERENCE
4 City of Manhattan Beach, CA
Gwen Eng, General Services Manager
1400 Highland Avenue
Manhattan Beach CA 90266
(310)802-5567
geng@citymb.info
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
tip•
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Spot Speed Survey
measurements:
25 MPH
c' 30 MPH
35 MPH
40 MPH
L.1'
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South Pasadena's Pine Street Traffic and
Safety Study, including 12 Radar Speed
Surveys and Machine Counts on 6
Arterial and Local Roadway Segments
PROJECT DESCRIPTION
LOCATION
4 South Pasadena, Los Angeles County, CA
SCOPE OF WORK
i 6 (x2) Passenger Vehicle, Heavy Vehicle and Pedestrian
Turning Movement Intersection Counts
i 6 (x2) Radar Speed Survey Counts
4 6 (x2) Average Daily Traffic Machine Counts
i Field Survey of Traffic and Safety Conditions, including
Roadway/Roadside Factors, Pedestrian Connectivity and
Presence of Traffic Controls
i Delay Analysis for Signalized Intersection (in -field)
i SYNCHRO Modeling and Queuing Analysis
4 Recommendation for Traffic Calming Measures
CLIENT / AGENCY
City of South Pasadena
Paul Toor, P.E., Director of Public Works
1414 Mission Street
South Pasadena, CA 91030
(626) 403-7240
Ptoorfacl.south-oasadena.ca•us
Minagar & Associates, Inc. was retained by the City of South Pasadena to conduct a "Before and
After" analysis for the City's Pine Street Traffic Study to assess the traffic and safety impacts of a
newly -installed stop sign at the intersection of Pine Street and Dos Robles Place, located on the
border line between the Cities of South Pasadena and Alhambra. The installation of the stop sign
and associated striping modifications were approved in accordance with Minagar & Associates,
Inc.'s previous study which analyzed the potential effects of implementing the improvements. The
objective of the proposed action sought to discourage the use of Pine Street as a cut -through
route between Huntington Drive and Atlantic Boulevard by interrupting uncontrolled traffic from
eastbound Huntington Drive.
The field data collection effort included a survey of existing traffic operations and safety
conditions on Huntington Drive and Pine Street, including machine counts and radar speed
surveys in November 2009 and October 2010 for each of the six (6) roadway segments, as well as
vehicle and pedestrian turning movement counts at six (6) nearby major stop -controlled and
signalized intersections. The benefits of installing the stop sign included a reduction in measured
speeds (radar based) along Pine Street, a reduction in daily cut -through traffic volumes (ADT -
based), an improvement in Pine Street's proper functional use as a residential street, and an
overall improvement in the level of traffic safety to Pine Street's residents and local road users.
1
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23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
CITY OF SAN MARINO
CITY OF
PASADENA
CITY OF
PASADENA
CITY OF
PASADENA. '1
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COUNTYOP
- LOS ANGELES
CITY OF
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PASADENA
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CITY OF
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CITY OF
SAN GABRIEL
MINAGAR & ASSOCIATES, INC.
SPEED
LIMIT
30
San Marino's 2011 Engineering & Traffic
Survey (E&TS) for 59 Roadway Segments
and Speed Zones Along 40 Major Citywide
Corridors
PROJECT DESCRIPTION
Minagar & Associates, Inc. was selected by the City of San Marino to conduct an
Engineering & Traffic Survey (E&TS) for arterial streets and local roadways within the
city to reestablish citywide speed limit designations in compliance with the current
California Vehicle Code (CVC) and the 2010 California Supplement of the Manual on
Uniform Traffic Control Devices (CA-MUTCD).
The project required an initial comprehensive field survey of roadway conditions which
required video surveying, observation, data collection and documentation of project
roadway segment lengths, FAU classification, street width, number of lanes, median
types, adjacent land use/zoning, traffic controls, on -street parking activity, presence of
bike lanes, description of horizontal/vertical alignments, visibility and lighting
conditions, and the existing condition of nearby crosswalks, driveways and sidewalks
The E&TS also entailed a complete of project segment traffic volumes (ADT, pedestrian
and truck traffic); an evaluation of local three-year local collision history and rates;
radar spot speed measurements; a speed zoning analysis (50th %-ile, 85 %-ile and 10 -
MPH pace) with recommendations for updates to the posted speed limits on project
roadway segments; and the preparation of an Engineering & Traffic Survey (E&TS)
Report, complete with a summary of current laws and regulations, a scope of work for
the project, segment narratives, and appropriate maps, tabulations and supporting
documentation for radar speed measurement sheets and SWITRS accident reports
obtained from CHP.
LOCATION
♦ San Marino, Los Angeles County, CA
SCOPE OF WORK
J Field Survey and Video Observations of
Roadway/Roadside Conditions, School Zones,
Visibility, Adjacent Land Use/Zoning, On -street
Parking, Traffic Controls and Pedestrian and Truck
Volume Activity
• Machine Counts (ADT) for 59 Segments
i Speed Bin Counts for 59 Segments
J 3 -Year Accident Rate Analysis
♦ Prepare Engineering & Traffic Survey (E&TS) Report
and Recommend Posted Speed Limits
CLIENT / AGENCY
4 City of San Marino, CA
Mara! Lazarian, Administrative Analyst
Parks and Public Works Department
2200 Huntington Drive
San Marino, CA 91108
(626)300-0792
pubwks@cityofsanmarino.org
1
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
C_ !
S.tmt.nt ltI,
haven Avenue
Harriman Ave. to
Hanscom Dr.
15 MPH
Segment #5:_
Illinois Drive
Hanscom 1), (5) to
Hanscom Or. (N)
25 MPH
SPEED
� MIT South Pasadena's 2012 Radar Speed
25 Survey and Engineering & Traffic
ENrnI Survey (E& TS) Project
PROJECT DESCRIPTION - Minagar & Associates, Inc. provided contract city
traffic engineering services to the City of South Pasadena from 2010 to 2012.
Major traffic engineering tasks included Radar Speed Surveys, Traffic
Engineering and Transportation Planning Studies, Engineering & Traffic
Survey (E&TS) Reports, Field Traffic Data Collection, Intersection and
Roadway Traffic Operations Assessments and CMP Intersection Capacity
Analyses.
The City requested for Minagar & Associates, Inc. to conduct an E&TS Study
for several local roadways within the city to reestablish speed limit designations
in compliance with the current California Vehicle Code (CVC) and the 2012
California Supplement of the Manual on Uniform Traffic Control Devices (CA-
MUTCD). The project required a comprehensive field survey of roadway and
roadside physical conditions, radar speed data collection, ADT machine
counts, and documentation of roadway features such as segment length, street
widths, lane utilization, traffic controls, on -street parking activity, descriptions of
horizontal/vertical alignments, visibility and lighting conditions, driveway
frequency, and residential frontage density in support of developing any
justifiable reasons for an increase or decrease to the initially set posted speed
limits by speed surveying.
The E&TS entailed a complete assessment of segment traffic volumes,
evaluation of recent local three-year local collision history and rates, speed
characteristics, speed zoning analysis (50th %-ile, 85 %-ile, 10 -MPH pace,
etc.) development of recommendations for validation of the posted speed limits
on the project roadway segments, and preparation of an Engineering & Traffic
Survey (E&TS) Report complete with a summary of current laws and
regulations, a scope of work for the project, segment narratives, and
appropriate maps, tabulations and supporting documentation for radar speed
measurement sheets and SWITRS accident reports obtained from CHP.
LOCATION
South Pasadena, Los Angeles County, CA
SCOPE OF WORK
4 Field Survey of Roadway/Roadside Physical
Conditions, Visibility, Calculation of Residential
District Density, On -street Parking, Traffic Controls,
and Horizontal Curvature & Vertical Grade
Considerations
4 Field Radar Speed Traffic Counts
4 Machine Counts (ADT)
4 3 -Year Accident Rate Analysis
4 Preparation of Engineering & Traffic Survey (E&TS)
and Recommend Posted Speed Limits
CLIENT
City of South Pasadena
Paul Toor, P.E.
Director of Public Works
1414 Mission Street
South Pasadena, CA 91030
(626) 403-7240
CURRENT STATUS
4 Complete
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23 Years of Excellence
MINAGAR
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VEHICLE CODE
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
ROSECRANS AVE
Cif) .y 1far.lhor.r
City of
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SPMA ° Lawndale's 2013 Citywide Engineering and
40 Traffic Survey (E&TS) for 21 Roadway Segments
and Speed Zones Along 10 Major Citywide
E o coo
I Corridors
PROJECT DESCRIPTION - Minagar & Associates, Inc. was selected by the
City of Lawndale to conduct an Engineering and Traffic Survey (E&TS) for
arterial streets and local roadways within the city to re-establish citywide speed
limit designations in compliance with the current 2013 California Vehicle Code
(CVC) and the latest update to the California Manual on Uniform Traffic Control
Devices (2012 CAMUTCD). Minagar staff performed an initial field survey of
roadway conditions consisting of corridor "drives" and observing the existing
speed zone segment in both directions, and surveying and documenting
various roadside/roadway and traffic factors such as street width, number of
lanes, median types, adjacent land use/zoning, traffic controls, on -street
parking activity, presence of bike lanes, description of horizontal/vertical
alignments, visibility and lighting conditions, and the existing condition of
nearby crosswalks, driveways and sidewalks.
Certified radar operators collected the speed data in the field and submitted the
post -processed data to Minagar staff, who then organized and tabulated the
data for analysis in the E&TS. An evaluation of local three-year local mid -block,
speed related collisions history and rates was compared with radar speed
analyses of 50th %-ile, 85 %-ile and 10 -MPH pace data, and recommendations
for updates to the posted speed limits on project roadway segments were
made. An Engineering & Traffic Survey (E&TS) Report was then submitted in
draft and final versions, complete with a summary of current laws and
regulations, a scope of work for the project, segment narratives, tabulations
and supporting documentation for radar speed measurement field counts.
LOCATION
♦ Lawndale, Los Angeles County, CA
SCOPE OF WORK
♦ Field "Drives" to survey roadway/roadside physical
conditions and traffic controls; Inventory of
pedestrian and bicyclist factors; Calculation of
Residential District Density;
• Coordination with L.A. County Sheriff and adjacent
cities for boundary line speed zones
./ Radar Speed Counts for 22 Segments
J Machine Counts (ADT)
♦ 3 -Year Accident Rate Analysis
♦ Preparation of Engineering & Traffic Survey (E&TS)
and Recommend Posted Speed Limits
CLIENT
City of Lawndale
Miguel Alvarez, P.E.
Associate Engineer / Project Manager
14717 Burin Avenue
Lawndale, CA 90260
(310)973-3265
CURRENT STATUS
. Complete
!AWOL,
-114
LAWN DALE
SHERIFF
2010 Collision Data
on California State
Highways (road miles,
travel, collisions,
collision rates IN
CAM umra A4nwl rn Uniwss,
Trahl[Control Derisas
0 r
2013
23 Years of Excellence I r
MINAGAR 8c ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
art OF
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CITY OF
COLTON
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SPE
LIMIT Colton's 2013-14 Citywide Engineering and
45 Traffic Survey (E&TS) for 44 Roadway Segments
and Speed
RADAR
`ENFORCED Corridors
PROJECT DESCRIPTION - Minagar & Associates, Inc. was selected by the
City of Colton to conduct an Engineering and Traffic Survey (E&TS) for arterial
streets and local roadways within the city. The E&TS updated served as a
record of existing conditions on the selected roadways, provided a basis for
updating and validating the City's currently posted speed limits on major
thoroughfares. and re-established citywide speed limit designations in
compliance with the current 2013 California Vehicle Code (CVC) and the latest
update to the California Manual on Uniform Traffic Control Devices (2012
CAMUTCD). Minagar staff conducted an investigation of existing conditions
along each of the surveyed segments, including an inventory of the various
physical roadway and traffic factors not readily apparent to motorists.
The project team's certified radar operators collected a total of fifty (50) speed
measurement data points per direction (i.e., 100 bi-directional data points for
each segment) and submitted the post -processed data to Minagar staff. The
speed data was then compiled and analyzed along with a comprehensive
evaluation of mid -block traffic rates on each segment, and used to develop a
set of recommended posted speed limits for updating the City's formally
adopted speed zoning designations. The Engineering & Traffic Survey (E&TS)
Report was submitted to include a full-color map of proposed speed limit
zones, Year 2013 Average Daily Traffic (ADT), and included narratives
describing the latest updates to the current traffic laws and regulations (2013
CVC), the scope of work, summary tables and list of recommended posted
speed limits, and supporting documentation of the field collected data.
LOCATION
♦ Colton, San Bernardino County, CA
SCOPE OF WORK
♦ Investigation of roadway segments: roadway,
roadside, adjacent land use and traffic factors
conditions not readily apparent to motorists;
4 Boundary line speed zone inspection;
4 Radar Speed Counts for 44 Segments
♦ Machine Counts (ADT) for 44 Segments
4 3 -Year Accident Rate Analysis
Preparation of Engineering & Traffic Survey (E&TS)
and Recommend Posted Speed Limits
CLIENT
City of Colton
Victor Ortiz, P.E.
Engineering Manager
160 S. 10th Street
Colton, CA 92324
(909) 370-5065
vortizfrb,ci,colton.ca.l,Es
CURRENT STATUS
4 Complete (Adopted April 2014)
33.
..r
Z3 Years of e=xcellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Los Angeles County MTA's RSTI: Evaluation of Old Town
Road Improvements in the City of Calabasas
Addition of Throughput Arterial Lane
on Calabasas Road
PROJECT DESCRIPTION
Minagar & Associates, Inc. evaluated the addition of lane miles and
throughput realized by the implementation of this project, as well as
the increased benefit to transit users provided by widening the
roadway to accommodate buses temporarily pulling out of traffic to
the curb.
Any vehicles traveling behind these buses would experience delay
reduction as they would no longer have to wait for transit users to
board the buses. This also is an added safety benefit to transit
users in the area.
Calabasas Rd. AM
PM,
Utilization EB
WB
EB
WB
Before
508
275
725
322
After
533
289
762
338
LOCATION
4 Calabasas, California
CLIENT
i Los Angeles County Metropolitan
Transportation Authority
John Grace
One Gateway Plaza
Los Angeles, CA 90012
(213) 922-4848
OTHER AGENCIES
• City of Calabasas
Robert Yalda, P.E., T.E.
Director of Public Works/City Engineer
100 Civic Center Way
Calabasas, CA 91302
(818) 224-1600
CONSTRUCTION COSTS
4 $500,000
Metro
Los Angeles County MTA's RSTI: Evaluation of Normandie
Avenue Improvements in the City of Los Angeles
Realignment and Reconstruction of Normandie Avenue
PROJECT DESCRIPTION
Minagar & Associates, Inc. evaluated the results of the
improvement project, which spanned from Pico Blvd. to Olympic
and included the realignment of Normandie at Olympic Boulevard.
In addition, a larger radius at the SW corner of Olympic &
Normandie was provided plus a northbound left -turn lane. The
realignment and improvements to Normandie resulted in smoother
passage for buses and overall improved transit facilities, traffic
mobility and safety around the Koreatown commercial district. Due
to the built -out condition of the area and the difficulty of the lane
additions, transit use was highly encouraged.
Normandie Ave./Pico BI.
Intersection Utilization
Before
After
AM
2675
PM
3197
7279
7806
Normandie/Olympic AM
Intersection Utilization
1:11
Before
4786
5844
After
10665
11324
LOCATION
•i Los Angeles, California
CLIENT
i Los Angeles County Metropolitan
Transportation Authority
John Grace
One Gateway Plaza
Los Angeles, CA 90012 Metro
(213) 922-4848
OTHER AGENCIES
City of Los Angeles
CONSTRUCTION COSTS
i $155,000
23 Years o! Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Los Angeles County MTA's RSTI:
Evaluation of SR -14 /Avenue L Corridor in the City of Lancaster
Addition of 2 signalized ramp intersections
PROJECT DESCRIPTION
Minagar & Associates, Inc. evaluated the results of the subject
project, the benefits of which included primarily interchange
improvements and ramp signalizations. The addition of lane
miles is significant because the length of the arterial that was
improved is only 1/2 mile. The five additional lanes were added by
constructing another bridge next to the old two lane bridge and
tying the two together. Also, the signalization of the two ramps
greatly reduced delay for traffic exiting State Route 14 in
Lancaster. This arterial is a major route in and out of Lancaster
and serves several bus routes as well. Transit benefits
experienced by 2 AVTA fixed routes, 3 AVTA commuter routes, 1
Santa Clarita commuter route, and Dial -a -Ride.
Avenue L Utilization
AIM
PM
EB
WB
EB
WB
Before 873
644
909
1048
After 1317
749
1884
1218
LOCATION
Lancaster, California
CLIENT
4 Los Angeles County Metropolitan
Transportation Authority
John Grace
One Gateway Plaza 13)
Los Angeles, CA 90012 Metro
(213) 922-4848
OTHER AGENCIES
4 City of Lancaster
Los Angeles County MTA's RSTI:
Evaluation of Pearblossom Highway Widening
Bridge widening, elimination of
Clover Leaf & connector road
PROJECT DESCRIPTION
Minagar & Associates, Inc. evaluated the benefits of the widening
of State Route 138 near Barrel Springs Road. This project
significantly increased lane miles, and as a result of the high
growth in the area, throughput also increased considerably.
Intersection improvements were also made; however, the main
goal of the project was primarily the addition of lane miles.
It should be noted that while this project added the most lane miles
for the least investment, this is most likely due to the relative
location of the project (compared to, for example, a dense urban or
downtown setting). Delay reduction was less noticeable than
expected. The rapid growth of the area is largely regarded as the
reason for this, inducing traffic that "swallows up" delay reduction
benefits relatively quickly.
Pearblossom
Highway
Utilization
LOCATION
4 Palmdale, California
CLIENT
4 Los Angeles County Metropolitan
Transportation Authority
John Grace
One Gateway Plaza 12)
Los Angeles, CA 90012
(213) 922-4848 Metro
OTHER AGENCIES
4 City of Palmdale _•k•
.
Bill Padilla
City Traffic/Transportation Engineer
Public Works Department
38250 Sierra Highway
Palmdale, CA 93550
(661) 267-5363
CONSTRUCTION COSTS
J $1.2 Million
23 Years of Excellence
MINAGAR & ASSOCIATES, iNC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Los Angeles County MTA's RSTI: Evaluation of Sepulveda
Boulevard in the Cities of Manhattan Beach and El Segundo
Addition of 4 lane miles, landscaped median islands, drainage
improvements and undergrounding of overhead utilities
PROJECT DESCRIPTION
Minagar & Associates, Inc.
evaluated an extensive arterial
widening project with right-of-way
in two cities. The area was
already built out when the project
began and most of the costs were
incurred by right-of-way acquisition
required to complete such a
project. A four mile stretch of
Sepulveda Boulevard was
widened by one lane in each
direction as well as all of the
intersections in the project area
receiving another left turn lane in
the north and southbound
directions, making this the most
extensive project, including the
most signalized intersection
improvements, that was analyzed
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LOCATION
• Manhattan Beach, California
4 El Segundo, California
CLIENT
✓ Los Angeles County Metropolitan
Transportation Authority
John Grace
One Gateway Plaza
Los Angeles, CA 90012
(213) 922-4848
42) Metro
OTHER AGENCIES
a City of Manhattan Beach
4 City of El Segundo
CONSTRUCTION COSTS
J $6.8 Million
Sepulveda Blvd.
AM
PM
Utilization
NB
SB
NB
SB
Before
3039
909
1209
3146
After
3259
1055
1296
3652
Los Angeles County MTA's RSTI: Evaluation of SB
1-710/Firestone Interchange in the City of South Gate
Bridge widening, elimination of
Clover Leaf & connector road
PROJECT DESCRIPTION
Minagar & Associates, Inc. evaluated the improved ramp facilities
and interchange. Signalization of the SB 1-710 off -ramp was both a
mobility benefit to users of the ramp and a safety benefit to those
merging right onto the Firestone Blvd. arterial from the 1-710. Prior
to the signalization/WB lane addition over the LA River Bridge, this
movement needed to wait for sufficient gaps on Firestone Blvd. to
turn. The ramp signal introduced more delay on Firestone (now
Firestone traffic has to stop for ramp traffic), but was a significant
improvement for ramp traffic, allowing for the removal of the
cloverleaf ramp and less confusion in this heavily congested area.
Firestone & 1-710 SB Ramps
Intersection Utilization
Before
After
PM
6200
8108
Firestone Boulevard
Utilization
Before
After
PM
EB
3482
WB
3150
2709
3344
LOCATION
J South Gate, California
CLIENT
4 Los Angeles County Metropolitan
Transportation Authority
John Grace
One Gateway Plaza GD
Los Angeles, CA 90012 Metro
(213) 922-4848
OTHER AGENCIES
• City of South Gate
Mr. M. Mostahkami, P.E.
8650 California Avenue
South Gate, CA 90280-3075
(323) 563-9582
CONSTRUCTION COSTS
J $4.8 Million
gem nmalmaama
road enema mann.
23 Years of Excellence
MINAGAR & ASSOCIATES, INC.
TRAFFIC ENGINEERING • TRANSPORTATION PLANNING • INTELLIGENT TRANSPORTATION SYSTEMS (ITS) • HOMELAND SECURITY
Los Angeles County MTA's RSTI: Evaluation of Anaheim
Street Grade Separation in the City of Long Beach
• Addition of 2 % lane miles and Elimination of
6 conflicting intersections with Anaheim Street
Minagar & Associates, Inc. evaluated the impacts of the
subject grade separation street improvements project. The
project's benefits were increased goods movement potential;
the grade separation allowed for future expansion of the Port
of Long Beach by addition of eleven (11) more tracks under
the grade separation with each train removing approximately
600 truck trips from LA area freeways.
Another major benefit was the substantial delay reduction and
safety improvements due to the removal of the at -grade
crossing. Previously, vehicles traveling this corridor would
encounter 1 to 2 trains per hour causing 10 minutes of delay
each. Prior to the improvements, the delay not only decreased
the efficiency of the Port's operation, but contributed to
increasing delays for transit and local business patrons.
Anaheim St. & Il9m St. AM
MD
PM
Intersection Utilization
EB
WB
EB
Before
1800
3500
3500
After
2400
2500*
2900*
Anaheim Street AM
MD
PM
Utilization EB WB
EB
WB
EB
WB
Before
_
610 900
1230
1350
1280
1180
After
850 1170
1150*
920*
1230*
1090*
* Due to network and travel pattern changes, volumes at this time decreased
• Trains doubled since project inception and rail yard
expansion for 10 more tracks made possible by the grade
separation
• Transit benefits experienced by LACMTA Bus Route #232
(15 min. headway)
LOCATION
• Long Beach, California
CLIENT
' Los Angeles County Metropolitan
Transportation Authority
Jon Grace
One Gateway Plaza
Los Angeles, CA 90012
(213) 922-4848
OTHER AGENCIES
• Port of Long Beach
Mr. Kerry Cartwright, P.E.
Manager of Transportation
925 Harbor Plaza
Long Beach, CA 90802
(562) 590-4155
4 City of Long Beach
CONSTRUCTION COSTS
'► $3.9 Million
Metro
WIIG MACH
Planning
Anaheim St. facing east at Pennington Grade Sep.
Anaheim St. facing west at Rte. 103 Grade Sep.
23 Years of ExcellanGe
RfMINAGAR & ASSOCIATES, INC.
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• Stop Sign Installation Warrant Assessment Rancho Santa Margarita, CA I •• • I
Garden Grove, CA 1
• Traffic Control Plans Preparations for Harbor Blvd. & Westminster Blvd. i Santa Ana, CA
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Project Location
• Traffic Control Plans for Castaic Lake Water Company's Main Station & Pipelines Santa Clarita, CA
Baldwin Park, CA
Baldwin Park, CA
Baldwin Park, CA
Palmdale, CA
Lancaster, CA
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Rialto, CA
San Clemente, CA
Baldwin Park, CA
Long Beach & Lakewood, CA
Laguna Niguel CA
Baldwin Park, CA
Moreno Valley, CA
Yorba Linda, CA
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Baldwin Park, CA
Baldwin Park, CA
Diamond Bar, CA
• Stop Sign Installation Design for Olive/Phelan/Blecker
• 2004 Citywide Radar Speed Survey (Engineering & Traffic Survey) for 54 Locations
• Warrant Assessment for the Installation of a New Traffic Signal at Willow Ave/Badillo St.
• Traffic Signal Installation Warrant Assessment for a Private Driveway at 47th St. E.
• Warrant Assessment for a Left -Turn at Ave. K & 32nd St. West for Fieldstone Communities
• Investigating Traffic Signal Operations Malfunctions for 2 Signals along Reche Canyon
• City of Irvine's FY 2004-2007 On -Call Consulting Services
• Traffic Control Plans for the Sandhi!! 30" Raw Water Conveyance Pipeline
▪ ♦ Signing & Striping and Traffic Control Plans for 1 New Signal & 2 Signal Modifications
• Traffic Signal Warrant Assessment for Stewart at Baldwin Park Blvd.
• Signing and Striping and Traffic Control Plans for Boeing's Douglas Park Development
▪ • Signing & Striping Plans, Speed Humps & Speed Limit Assessment, Palmilla Gated Community
• Traffic Control Device Design for City's Transfer Station & Signal Warrant Assessment for Puente at Cummings
• Signing & Striping Plans for 1,300' on Heacock Street
• Signing & Striping and Traffic Control Plans for VTT # 16595 at Lake View & Bastanchury
• Restriping Plan for the Traffic Signal Modification of Protected Left -turn Lane
• Traffic Control Plans for the Ultimate Street Improvements of Perris Valley 96" Pipeline
• Interstate 10 FRWY & Baldwin Park Blvd. Queuing & Traffic Analysis
• Traffic Signal Timing Chart for Baldwin Park Blvd. & Foster
• Traffic Control Plans Preparations for Brea Canyon Road
Sheet 1 of 4
January 1. 2016
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Project Location
• Truck Route Feasibility Study for Vulcan Materials Plant Baldwin Park, CA
La Habra, CA
South El Monte, CA
Moreno Valley, CA
Baldwin Park, CA
Baldwin Park, CA
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Newport Coast, CA
Riverside County, CA
Lancaster, CA
Newport Beach, CA
Moreno Valley, CA
Baldwin Park, CA
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Riverside County, CA
Riverside & Riverside County, CA
Rancho Santa Margarita, CA
Rancho Santa Margarita, CA
Rancho Santa Margarita, CA
Rancho Santa Margarita, CA
Rancho Santa Margarita, CA
Santa Ana, CA
Redondo Beach, CA
• Sight Distance Assessment for the Proposed Sign Installation at Hacienda Rd. & Whittier Blvd.
• Left -Turn Lane Feasibility Assessment for Garvey & Lee for a New Starbucks
• Restriping Plans for a New AutoZone at Sunnymead Blvd. and Graham St.
• Conducting 2 Stop Signs Installation Assessment at Olive/Center & CenterlBenbow
• Traffic Signal/Stop Sign/Flashing Beaecon Warrant Assessment for Maine/Ohio
• U -Turn Feasibility Assessments for 2 Locations along Valley Blvd. at Rancho & 3rd
• Crystal Cove/Newport Coast's Stop Sign Assessment for Reef Point Dr. at Canyon Club Dr.
• Signing & Striping Plans for 18,000 LF of Roadways for 500 New Pulte Homes
• Ave. L & 10th St. W. Signing & Striping and Traffic Control Plans
• Traffic Control Plans for Newport Coast Community Center at Newport Coast Drive
• Perris Valley 48" Water Pipeline Traffic Control Plans along 13,000' of Cactus Ave. for MWD & EMWD
• Traffic Signal Warrant Assessment for Olive St. & Landis Ave.
• Traffic Design Investigation for Barton/La Cadens
• Signing & Strping Plans for 1,400 LF of Lake Forest Dr. Extension
• Signing & Striping Plans for 1,400 LF along State Highway 111 for Desert Cities Industrial Park
• Traffic Control Plans for MWD's 96" Perris Valley Pipe Line between 1-215 & Mission Grove
• Citywide Speed Survey II
• Via Regresso & Via Arribo Traffic Evaluation
• City of Rancho Santa Margarita Speed Limit Sign Inventory
• Engineering & Traffic Survey for Los Flores
• Crosswalk Assessment at the City of Rancho Santa Margarita Beach Club
• Traffic Control Plans for Irvine Water Ranch District's Dyer Road Facility
• Redondo Beach's Engineering & Traffic Survey for 12 Corridors
Sheet 2 of 4
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• Traffic Study for Press -Telegram's Magnolia Ave./ 6th St. ] Long Beach, CA
• Internal Signing & Striping Plans for Irvine Company's Planning Area -18 North Development 1 Irvine, CA
• Signing & Striping Plans for Irvine Company's Panning Area 18 South Development Irvine, CA
• Traffic Control Plans for Cactus Ave. 48" Feeder Pipeline under 1-215 Interchange Moreno Valley, CA
• Hawaii's Queen Kaahumanu Highway (19) & Kohanaiki Way's Guard Rail Assessment North Kona, HI
• Traffic Control Plans for WMWD's Meridian Sewer Pipes along Alessandro Rd. & Sycamore Canyon Blvd. Riverside & Riverside Cty., CA
• Traffic Control Plans for Sandhi!! Water Treatment Plant for the Proposed 8" Sewer Lines Rialto, CA
• Traffic Control Plans for WMWD's Riverside -Corona Feeder 54" Water Pipeline on Van Buren Blvd. Riverside, CA
• Consulting Traffic Engineering for Avenue R & 5th Street East Intersection Improvement Palmdale, CA
San Clemente, CA
Santa Monica, CA
Huntington Beach, CA
Baldwin Park, CA
Redondo Beach, CA
Los Angeles County, CA
• Govemors Island Ferry Stacking for the U.S. Coast Guard Manhattan, NY
• Interstate 80/River Drive Interchange Preliminary Engineering 1 Northern NJ
• Cross Westchester Expressway (1-287) From Route 120 to 1-95 Westchester County, NY
• Traffic Evaluation of the Causeway-Earhart Interchange 1 New Orleans, LA
• Capital Beltway (1-495) Springfield Interchange Traffic Improvements Washington, DC
• I-287/New York Thruway/Route 17 Interchange Design Improvements New York & New Jersey
• Broadway Final Design Traffic Evaluation for NYCDOT New York , NY
• Virginia Beach's Atlantic Anenue Traffic Study T Virginia Beach, VA
• Traffic Control Plans for Vintage Shores Sr. Apartments on Camino De Estrella
• Traffic Control Plans for Neilson Way for Water & Sewer Lines Repair
• Traffic Control Plans for Huntington Beach's Central Park & Sports Complex
• Traffic Signal & Stop Sign Warrant Assessment for 11 Locations
• Engineering & Traffic Survey Including 9 Radars for 3 Corridors
• Preparing Signing & Striping Plans for Alta Vista & Copper Hill
Sheet 3 of 4
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Rancho Santa Margarita, CA
Chino Hills, CA
Palmdale, CA
Santa Ana, CA
Los Angeles County, CA
Baldwin Park, CA
Baldwin Park, CA
Chino Hills, CA
Chino Hills, CA
Santa Monica, CA
Santa Monica, CA
Costa Mesa, CA
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Rancho Santa Margarita, CA
Lynwood, CA
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Corona, CA
Project
• City Traffic EngineeringlMunicipal Engineering Services
• City Traffic EngineeringlMunicipal Engineering Services
• City Traffic EngineeringlMunicipal Engineering Services 1
• City Traffic EngineeringlMunicipal Engineering Services
• Caltrans District 12's Interstate 5 & State Route 55 Flyover TMP & TCP
1 • MTA's Evaluation of RSTI Projects for 7 Agencies
• Conducting Signal & Stop Sign Warrant Assessments for 16 Locations
• Assessment of Right -Tum -On -Red for Baldwin Park Blvd. & Dalewood Avenue
♦ Peyton Avenue Restriping & Resigning Plans Preparation
• Ruben Ayala High School Internal Circulation Study
♦ Traffic Control Plans for PCH Sewer Lines Repair & Permit Application for Caltrans D-7
• Santa Monica Pier's Parking Striping Plans
• Experian Corporation HQ Signal Warrants & Queue Studies- Anton Avenue
• City of Tustin's Main Street Water Facility- Traffic Control Plans J
• On -Call Traffic Engineering/Traffic Control Plans for Anaheim Water Department
• St. Nicholas Parish Traffic Signal Warrant Study
• Citywide Speed Survey for 5 Major Arterials- Phase!
• Long Beach Freeway (710) NB Off -ramp at Imperial Highway Traffic Signal Warrant Assessment
• Traffic Signal Modification Assessment for 7th St. & La Cadena
• San Bemardino Freeway (1-10) WB Off -ramp at 9th SU Valley Traffic Study
• McBean Parkway & Baywood Lane Signing & Striping Plan
♦ Corona Industrial Park Traffic Signal Warrant & Trip Generation Assessment
Sheet 4 of 4
SPEED
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MINAGAR & ASSOCIATES, INC. 'S1114
Engineering and Traffic Survey (E&TS) Project Experience
Roadway
Agency Year Segments
1. City of South Pasadena 2014-15 60
2.' City of Santa Fe Springs 2014 1 1 r
3. ; iL:w City of Colton 2013-14
. ;� ; City of Culver City 2013 70
5. City of Lawndale 2013 22
6. 111.44 City of South Pasadena 2012
7. 4. City of San Marino 2011
City of South Pasadena 2010 Z.
.q City of Manhattan Beach 2010 51
1 0. fir_ City of Santa Fe Springs 2009 115
1 I. ,M City of Baldwin Park 2009 54
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12. Ilik City of Rancho Santa Margarita 2004 11
71
3. Iii City of Baldwin Park 2004 54
4. - L --iii City of Redondo Beach 2003 57
15. City of Rancho Santa Margarita 2000 36
759 Total Radar Speed Zone Segments Surveyed
15 Engineering and Traffic Surveys (E&TS) Completed
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♦ Massachusetts Bay Transit Authority's Red Line Transit Computer Modeling Boston, MA
♦ Drew University Campus Expansion Development Los Angeles, CA
• North San Diego County Future Urbanizing Area Traffic Study San Diego, CA
• Paularino Medical Center, Parking Study, CUP & Variance Applications Costa Mesa, CA
• Crown Valley PKWY DEIR Across the Arroyo Trabuco In Orange County J Orange County, CA
1 • Traffic Circulation & Parking Assessment for Margaret Landell School Cypress, CA
▪ • Los Angeles Grand Sports Arena/Concert Hall for Los Angeles Clippers ` Los Angeles, CA
1 • Interstate 10 FRWY & Baldwin Park Blvd. Queue & Traffic Analysts Baldwin Park, CA
1 • Lockheed Martin Aircraft Facility Plant Traffic Study Palmdale, CA
• Lockheed Martin Master Plan EIR Palmdale, CA
• Modesto's "J" Street Traffic Improvements Including Roundabouts Computer Modeling Modesto, CA
▪ • Woodbridge Development's Heath Terrace Parking Study & Variance Application 1 Anaheim, CA
1 • Chrysler Corporation's Countywide Auto Dealership & Service Center 1 Garden Grove, CA
▪ • Honali Plaza Parking Study, Variance & CUP Applications J Laguna Hills, CA
• Washington Mutual Bank's El Toro Site Parking Study, CUP & Variance Applications Laguna Hills, CA
• Washington Mutual Bank's El Toro Site Parking Study, CUP & Variance Applications Laguna Woods, CA
• Sunshine Bookstore Parking Inventory & Study ] Mission Viejo, CA
♦ Experian Corporation HQ Development Traffic Impact Study l Costa Mesa, CA
• Serra Catholic School Traffic Impact Report Review Rancho Santa Margarita, CA
1 • The Gallery Traffic Impact Report San Clemente, CA
1 • Calabasas Volvo Dealership Traffic Impact Study Calabasas, CA
• Review of Draft Traffic Impact Report for the Port of Los Angeles' West Basin I Los Angeles, CA
• Los Angeles World Airports' Palmdale Airport Master Plan Traffic Englneertng & System Planning 1 Palmdale, CA
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Santa Clarita, CA •
Long Beach, CA •
Los Angeles County, CA •
Laguna Hills, CA •
Corona, CA •
Los Angeles County, CA •
Palmdale, CA 1 •
Santa Clarita, CA • •
Palmdale, CA I
• Providing Traffic Monitoring for Rye Canyon Business Park Santa Clarita, CA
• Wal-Mart Corporation's Traffic Impact Report for Rye Canyon Business Park Santa Clarita, CA •
• Assessment of Fair Share Traffic Impact Fees for West Corona Business Park Corona, CA
• Chrysler Corporation's Dodge Dealership Traffic Impact Lompoc, CA •
• Caltrans AB -680 Highway 118-126 Toll Road Los Angeles/Ventura, CA
• Leisure World/Laguna Woods Village Access Control Gate 16 Traffic Study Laguna Woods, CA •
• Chevron South Pasadena Gas Station & Convenience Store Traffic Study South Pasadena, CA •
• Identification of Funding STIP & CIP Programs for Metrolink) SCRRA Southern California, CA
• City of Villa Park Parcel Map No. 97-232 Sight Distance Evaluation Villa Park, CA •
• Palmdale Airport Plaza Traffic Impact Report Palmdale, CA • •
• Village Court Yard at Camino Real Shopping Center Traffic Impact Report San Clemente, CA •
• City of Chino - State Surplus Property Disposition at College Park Chino, CA •
• Lockheed Martin Traffic Impact Analysis J
• Rye Canyon Business Park North Campus TIR
• First Congregational Church of Long Beach Parking & Circulation Study
• Tesoro Development's Traffic Analysis & Signal Warrant
• Bodies -In -Motion Parking Study & CUP Application
• Trammell Crow Company's Development in Corona
• SunCal's Tesoro Development Impact Fee Assessment
• Quartz Hill Traffic & Fee Impact Studies
• Legacy's Tentative Tract # 51828- South Campus
• Consulting Services for Metrolink Railroad Crossings & Signal Pre-emption
Sheet 2 of 7
Parking Analysis for Proposed 2024-2025 Ventura Blvd. Development
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Baldwin Park, CA
Palmdale, CA
Palmdale, CA
Lake Elsinore, CA
Bell Gardens, CA
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Lake Forest, CA
Lancaster, CA
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South Pasadena, CA
Lake Forest, CA
Irwindale, CA
Palmdale, CA
Santa Monica & Los Angeles, CA
Riverside, CA
Lake Forest, CA
Camarillo, CA
City of Irvine's FY 2004-2007 On -Call Transportation Services
Metrolink's Application, Railroad Pre-emption & Signal Timing for Garvey & Franclsquito
Rite-Aid Shopping Center 1 Halferty Development Traffic Impact Study
Vallarta Shopping Center Traffic Impact Study at NEC of State Route 138 and Ave. R
Lake Elsinore View Estates 70 -Acre, 174 Homes Traffic Impact Analysis
Los Jardlnes Shopping Center & Market Place Traffic Impact Analysis
ABT -Haskell Blosolids & Green Waste Composting Facility at Agua Manza Rd. Traffic Impact Study
Tom's Restaurant #27 Shopping Center Traffic Impact Study at SWC of State Route 138 and Ave. R
Traffic Analysis for Lake Forest Center's New Retail Center with Starbucks & Subway Restaurants
Corona Industrial Park Trip Generation & Traffic Signal Warrant Assessment
Technical Memo for WB Left -Tum Allowance on Imperial Hwy. & Duncan
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Sycamore Canyon Business Park Traffic Impact Report
Left -Tum Vehicle Queuing Analysis & Computer Modeling for Forest Plaza Center
Sheet 3 of 7
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Glendora, CA
Lake Forest, CA
Santa Ana, CA 1
Castaic, CA
Desert Hot Springs, CA 1
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Riverside, CA
Colton, CA
Laguna Niguel, CA
San Bernardino County, CA
San Diego County, CA
Lancaster, CA
Diamond Bar & Industry, CA
Chino Hills, CA
Ridgecrest, Kern County, CA
Palmdale, CA
Whittier, CA
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• Lone Hill Plaza 1 Route 66 Promenade Center Parking Survey for Bank of America, Del Taco, Starbucks & etc.
• Starbucks Coffee & Subway Stores Left -Tum Pocket Analysts at Dimension & Lake Forest Dr.
• New Advance Beauty College Parking Utilization Study
• ARCO Convenience StorelServlce Station & Truck Stop Traffic Impact Study for Caltrans & Los Angeles County
• Parking Study for Proposed Village at Mission LakeslParadise Springs
• 500,000 -SF Palmdale Gateway's Home Depot & Target Shopping Center TIS & EIR for Caltrans & Clty of Palmdale
• Starbucks Left -Tum Lane Feasibility Assessment at SR -19 & Rosemead Blvd. & Garvey
• Traffic Engineering/Transportation & Parking Planning Services for New Kiddie Academy
• Traffic Engineering Services for Sunshine Canyon Landfill EIR
• New DMV Traffic Assessment at Sycamore Canyon Blvd. & Siena Ridge
• Traffic Study for 1-10 Freeway at Pepper Ave. & Valley Blvd.
• Review of Gateway Speclftc Plan Report for Laguna Niguel Mayor & Clty Council
• Loma Linda Korean Seventh Day Adventist Church Traffic Impact Study
• Mountain Meadowsll-15 Regional Shopping Center Traffic Analysts & TIF for McMillin Commercial
B. Lancaster Baptist Church & West Coast Baptist College Traffic Study
• SR -57160 Interchange Improvement Feasibility Study Traffic/Transportation/ROW Engineering
• Hanaro Church Development Traffic Study & Parking Study at English Rd. & Peyton Drive
• Traffic Study for 136 Tract Homes for APN # 510-010-08 & -07
• Rancho Vista Blvd. (Ave. P) Grade Separation Computer Modeling & Traffic Analysis
• Friendly Hills Association Traffic Study & Survey for 16107 Aurora Crest Drive
• 1-10 Freeway 1 Valley Blvd. I Mt Vernon Queue Lengths Traffic Investigation
• 56 Sycamore Canyon 316,225 -SF Industrial Park Traffic Impact Study
• Sole Technology's 20161 & 20162 Windrow Dr. and 26921 Fuerte Dr. Parking Study & Survey (3 Buildings)
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• State Route 33 Diamond Rock Sand/Gravel EIR Transportation Planning Study & Review Ojai / Ventura County, CA
• West Palmdale Residential Complex Traffic Study for Palmdale & L.A. County at 10th St. W. 1 Auto Center Dr. Palmdale, CA
San Juan Capistrano, CA
San Diego, CA
Long Beach, CA
Palmdale, CA
Los Angeles, CA
Palmdale & Lancaster, CA
Glendora, CA
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Lynwood, CA
La Habra, CA
Palmdale, CA
Santa Fe Springs, CA
Palmdale, CA
Glendora, CA
Delano, CA
Denver, CO
New Jersey State, NJ
Raleigh, NC
Tampa, FL
Huntington Beach, CA
• City of Sacramento's Local Area Transportation/Parking Supply/Demand Studies Sacramento, CA
• SR-74lOrtega Highway Widening MND & Traffic Study Revlew
• Bethel University/Seminary Traffic Study; CUP # 88-0277 at 6116 Arosa St.
• Press -Telegram Mixed -Use High Rise Lofts Development Traffic Study
▪ • May Center's Plaza Vallarta Development Traffic Study for Caltrans D-7 & City of Palmdale
• Griffith Park's Autry National Center DEIR Review of Traffic Section
• Longs Drugs Retail Center Development Traffic Study for CUP# 07-11 at 20th St. W. & Ave. K
• Grand Plaza 87,560 -SF Retail Center Traffic Impact Study
▪ • Hilton Hotel Traffic & Parking Study at 17662 Armstrong Avenue
• Martin Luther King Jr. Shopping Center Traffic Study for 3831-3825 Martin Luther King
• Child Day Care Traffic & Parking Study at 1700 West La Habra Blvd.
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• Rite-Aid Development Traffic Study for Caltrans D-7 & City of Palmdale
• Korean Presbyterian Church of America & Theological Seminary Traffic Study
• Vallarta Shopping Center 107,360 SF Development Traffic Impact Study for Caltrans D-7 & City of Palmdale
• Lone Hill Plaza Traffic Queuing & Circulation Assessment for a New Starbucks
▪ • Randolph Village Shopping Center Parking Survey & Study
• Denver 470 Toll Revenue Study for Engineer 470 Partnership
• New Jersey Turnpike Widening Transportation & Toll Plaza
• North Carolina State University Campus Expansion
• Tampa's Ybor City Historic District Parking Study
• Peter's Landing- Huntington Beach Parking Study
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• Somerset County's Landfill & Bellemead Development Montomery Township, NJ
• Rils Park Aquatic & Athletic Complex- National Recreation Area NY & NJ New York, NY
• Port Liberte (Caven Point) Traffic Impact Study New York Harbor, NY
• Crossroads Park Shopping Center Raleigh, NC
• Loehman's Shopping Plaza Long Island, NY
1 • Packard/Bambergers Traffic impact, Cost Estimating & Alternatives Studies Hackensack, NJ
• North Carolina State University Campus Expansion Raleigh, NC
I♦ North Main Street Grade Separation Draft Traffic Analysts & Preliminary Conceptual Design Los Angeles, CA
• California Plaza Office Development Sacramento, CA
• Arden -Arcade LATS Parking Alternatives for Exposition Center Sub -Area Sacramento, CA
♦ Local Area Transportation Study Forecast Model for Arden -Arcade I Sacramento, CA
• Califomla Exposition Center Expansion Draft EIR & Traffic impact Study I Sacramento, CA
• Arden -Fair Mall Expansion: Fourth Anchor Tenant Traffic impact & EIR Sacramento, CA
• Transportation Improvement Program for Arden -Arcade LATS 1 Sacramento, CA
♦ Columbia River Salmon Flow Measures Draft EIS Walla Walla, WA
♦ 10 Million SF Hunters Point Waterfront Development EIS New York City, NY
• Evaluation of the Causeway-Earhart interchange for Greater New Orleans Expressway Commission New Orleans, LA
1 • U.S. Army Depot TMP Preparation Including Reg. XV Implementation I Sacramento, CA
• Los Angeles County's Municipal Court EIR Los Angeles, CA
• Los Angeles County's San Gabriel Reservoirs Environmental Study Los Angeles, CA
• Columbia University's Audubon Research Park's PDEIS ` New York, NY
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• Metrolink Commuter Rall System's Traffic Engineering & Design Los Angeles, CA
• Metrolink's Traffic Engineering & Design for Chatsworth Train Station & Lassen Grade Crossing Chatsworth, CA i
• Metrolink's North Main Street Grade Separation Traffic & Preliminary Design Los Angeles, CA
• Metrolink's Maintenance Facility Access Road Traffic Analysis Los Angeles, CA
• Metrollnk's Upland & San Bernardino Train Stations Local Street Improvements I Upland & San Bernardino, CA
• Port of Long Beach's SCARMD Emission Control Improvement at Port's Roadway Long Beach, CA
• City of Palmdale's Traffic Impact Fee Assessment & TRANPLAN Modeling Palmdale, CA
• Route 24 Expansion Traffic Study Utilizing UTPS Computer Model Morristown, NJ
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• Perris Valley 48" Water Pipeline TCP along 13,000' of Cactus Ave. for MWD & EMWD Moreno Valley, CA
♦ TCP for MWD's 13,000 Feet Perris Valley 96", 98" & 109" Water Pipeline between 1-215 & Mission Grove l Riverside City & Riverside County, CA
• TCP for WMWD's Riverside -Corona Feeder 54" Water Pipeline on Van Buren Blvd. Riverside, CA
• TCP for Cactus Ave. 48" Feeder Pipeline under 1-215 for Caltrans District 8 I Moreno Valley, CA
• Caltrans District 12's Interstate 5 & State Route 55 Flyover TMP & TCP Santa Ana, CA
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• Signing & Striping and Traffic Control Plans for 1 New Signal & 2 Signal Modifications San Clemente, CA
• Traffic Control Plans for PCH Sewer Lines Repair & Permit Application for Caltrans District 7 Santa Monica, CA
• Signing & Striping and Traffic Control Plans for Boeing's Douglas Park Development Long Beach & Lakewood, CA
• TCP for WMWD's Meridian Sewer Pipes along Alessandro Rd. & Sycamore Canyon Blvd. Riverside City & Riverside County, CA
• TCP for Sandhill Water Treatment Plant for the Proposed 8" Sewer Lines Rialto, CA
• City of Tustin's Main Street Water Facility- Traffic Control Plans 1 Tustin, CA
• TCP for Huntington Beach's Central Park & Sports Complex 1 Huntington Beach, CA
♦ Restriping Plan for Traffic Signal Modification & Street Improvements at Bastanchury Rd./Lakeview Ave. Yorba Linda, CA
Diamond Bar, CA
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♦ TCP for Castaic Lake Water Company's Station & Pipelines
♦ TCP for the Sandhill 30" Raw Water Conveyance Pipeline
• Traffic Control Plans Preparations for Brea Canyon Road
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• Irvine Ranch Water District's Dyer Road Facility TCP Santa Ana, CA
• Governor's Island Ferry Stacking for the U.S. Coast Guard Manhattan, NY
Garden Grove, CA
• Traffic Control Plans for Harbor Blvd. & Westminster Blvd.
Santa Ana, CA
• TCP for Vintage Shores Senior Apartments on Camino De Estrella San Clemente, CA 1
• TCP for Neilson Way for Water & Sewer Lines Repair 1 Santa Monica, CA
• Temporary Traffic Signal Modification Design for MWD & WMWD's Perris Valley Pipeline Construction 1 Riverside, CA
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Review of Draft Traffic Impact Report for the Port of Los Angeles' Berth 100-102 Container Terminal Facility West Basin
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Construction Engineering Management for SR 14 & Avenue S Ramps' Signals
Plan Check Services for a Signal at Mount Vernon & Cooley Drive
Signal Inspection Services for Ramona Blvd./ Merced Avenue and Romona BlvdJ Badillol Lozano
Work Scope Development for MTA's Signal Operations & Maintenance Training
Widening of Avenue P - Grant Application for LACMTA
Consulting Design Services for Avenue R & 5th Street East Intersection Improvement
Expert Witness Services - Paularino Medical Group
Villa Pacifica's Tract # 15870 Street Lighting Plan Check
City of Baldwin Park Merced Avenue, Bridge Widening
Plan Checking for Signal & Striping at Peyton Drive & Olympic View Drive
Long Beach Community College's Program Development for Traffic Signal Technicians
Caltrans TSM Grant Application Preparation
Interstates 5 & 405 Confluence "El Toro Y" TSM & Construction Engineering Management
Traffic Signal Inspections for 3 New Locations
Los Angeles County MTA - Scope of Work Development for Traffic Signal Training Program
Massachusetts Bay Transit Authority's Beacon Hill Computer Modeling
Traffic Signal CEM & Inspection for Earl/ Frazier, Merced/ Market Place & Merced/ Vineland
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Santa Monica & L.A., CA 1
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Baldwin Park, CA 1 •
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Ojai, Ventura County, CA
San Juan Capistrano, CA
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• Metro/LA County MTA On -Call FY 04-08 A & E Bench Contract for Electrical Engineering
• Evaluation of the Westchester Luthem School Traffic Study for Litigation
• Litigation Support for the Fourth Cause of Action of the Lawsuit on Mar Vista Community
• On -Call Traffic Engineering Design Plan Checking Services for the City of Irvine
• Construction Engineering Management of a New TOC/TMC In Santa Clarita
• CEM/Inspection/Installation of Timing Charts for Metrolink's RR Grade Crossings at Garvey/Francisquito
• CEM Support Services for ITMS & Traffic Signal Interconnect Projects
• Professional Traffic Engineering Expert Services for Sunshine Canyon Landfill EIR
• CEM for a New Traffic Signal at Maine St & Ohio AveJHallwood Dr.
• CEM for 3 Signals along Los Angeles St. at Bresee, Center & Stewart
• CEM for Traffic Signal Modification & As -Built for Alameda/Lake
• Expert Traffic Engineering Services for SR -33, Review of FEIR for Diamond Rock Sand & Gravel
• Expert Traffic Engineering Services for Lower SR-74/Ortega Highway Widening's MND & Traffic Study
• Expert Traffic Engineering Services for Griffith Park's Autry National Center DEIR
• Hawaii's Queen Kaahumanu Highway 19 Guard Rail Runout Length Assessment for the Shores at Kohanaiki
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Modeseto, Stanislaus Cty, CA 121 • • • • • _
Stanislaus County, CA 95 • tt • • _•
Los Angeles County, CA 420 • •
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Modesto, CA
Palmdale, CA
Baldwin Park, CA
Santa Clarita, CA
Santa Clarita, CA
Los Angeles County, CA
Santa Clarita, CA
Palmdale, CA
Irvine, CA
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Los Angeles Countywide, CA
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Los Angeles Countywide, CA
Project
• Traffic Signal Synchronization of 145 City & Caltrans D-10 Signals along 22 Arterials Outside the CBD - FY 2007
• Traffic Signal Synchronization, Implementation & Fine Tuning for City of Modesto & Caltrans D-10
•Traffic Signal Synchronization, Implementation & Fine Tuning for City of Modesto, Stanlslaus County & Caltrans D-10
L. Los Angeles County MTA's Evaluation of SMARTISanta Monica FRWY ITS Systems on 420 Multljurlsdlctional Signals
I• Traffic Signal Synchronization, Implementation & Fine Tuning for City of Ceres & Caltrans 0-10
• Traffic Signal Synchronization, Implementation & Fine Tuning for Downtown Modesto & Caltrans D-10
I• Palmdale Traffic Signal Coordination, Retiming & Fine Tuning for City of Palmdale, LA County & Caltrans D-7
♦ Traffic Signal Retiming, Installation & Fine Tuning for City of Baldwin Park & Los Angeles County
I• Traffic Signal Synchronization along McBean Pkwy, Valencia Blvd., Magic Mtn. Pkwy & San Fernando Road
• Santa Clarita Thouroughfare Signal Interconnect for 30 Miles
• Los Angeles County MTA's Evaluation of Regional Surface Transportation Improvement (RSTI) Projects
1 • Rye Canyon Business Park/Legacy Partners' Traffic Signal PS&E for City of Santa Clarity
1 • On -Call Traffic Signal Timing & Design Services for City of Palmdale
• PS&E Preparation for SR-133/Laguna Canyon Rd. & Lake Forest Drive 1
♦ Ave. R. Traffic Signal Interconnect & CCTV Design
• Baldwin Park's Master Interconnect Design and PS&E
1 • Upgrade of Calabasas Regional Traffic Operations Center, Interconnect, CCTV & Signal Timing
1 • Los Angeles County MTA's Signal Systems Training of 88 Cities, LA County & Caltrans D-7
1 • Los Angeles County MTA's Traffic Signal Operation & Maintenance Training Workshops of 90 Agencies
♦ Los Angeles County MTA's Traffic Signal Timing Training Workshops of 88 Cities, LA County & Caltrans D-7
• Los Angeles County MTA's Video Detection & Surveillance Training Workshops of 88 Cities, LA County & Caltrans 0-7
1 • Los Angeles County MTA's Type 170 Controller Training Workshops of 88 Cities, LA County & Caltrans D-7
• Los Angeles County MTA's Systems (Data, Video & Audio) Communications Training Workshops of 90 Agencies
Sheet 1 of 5
TRAFFIC SIGNAL TIMING, DESIGN, OPTIMIZATION, COMPUTER MODELING, SYSTEMS & INTERCONNECT DESIGN PROJECTS
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Costa Mesa, CA
Ceres, CA
Long Beach & Lakewood, CA
Baldwin Park, CA
Burbank, CA
Riverside County, CA
Riverside County, CA
La Veme/Pomona/Claremont, CA
Project
• Pacific Coast HighwaylEl Camino Real & Camino Capistrano Traffic Signal for City of San Clemente
♦ Traffic Signal Inspection & Construction Engineering Management for City of Baldwin Park
♦ McBean Parkway & Baywood Lane Signal Design & Preliminary Civil Design
• Kaufman & Broad Coastal's Villa Pacifica Traffic Signal & Interconnect PS&E
• On -Call Traffic Signal Plan Checking Services for City of Colton
• Signal Plan Preparation & Design for the City of Lancaster
• On -Call Traffic Signal Construction Inspection Services for City of Colton
• PS&E Package for New Signals for City of San Bernardino
• PS&E for Signal Design Packages for City of Baldwin Park
• PS&E Packages for Traffic Signals
• Consulting Design & PS&E Services for Railroad Pre-emption at Sierra Highway and Ave. P & R for Metrolink
• PS&E Preparations for 3 Traffic Signal Modifications at Locust AveJ6th17th and Pine/7th
• State Route 14 & Ave. S Signal & Striping PS&E Preparation for City of Palmdale, Los Angeles County & Caltrans D-7
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• Boeing's Douglas Park Traffic Signal, Signing & Striping, and TCP
♦ Review of LA. County's Traffic Signal Synchronization Program along Baldwin Park Blvd., Calais to Tracy (TSSP)
• PS&E Preparation for Burbank Blvd. 3 New Traffic Signals
• KB Homes - PS&E Preparations for 3 New Traffic Signals Modifications along Murrieta Rd.
• Pulte Homes 500 New Homes Development - PS&E Preparation for 5 New Traffic Signals
• Caltrans State Route 66 Advanced Traffic Control Systems (ATCS) CCTV & Fiber Optic PS&E
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• PS&E Preparation for Mt. VemonlColton & La CadenalAvenue C Traffic Signals
• PS&E Preparation for Tentative Tract Map 954157 - Avenue KI32nd Street West
• Reche Canyon/Shane Dr. & Topanga Canyon Traffic Signal Operations Assessment
• Metro/L.A. County MTA FY 04-08 On -Call A & E Electrical Engineering Bench Contract
• On -Call Traffic Engineering Design Services for City of Irvine FY 2004-2007
• Metro/LA. County MTA On -Call FY 04-08 A & E Traffic Engineering Bench Contract
• Traffic Signal Synchronization & liming Charts for I-10IGarvey, Merced, Puente, & Marketplace
• Avenue R Extension Traffic Signal Interconnect & CCTV Design with 72 SMFO
• Clinton Keith Rd. & Vista Murrieta High School Traffic Signal Design Modification
• PS&E for Ave. Vaquero & Via Casadita; 2 Signal Modifications at El Camino Real & Avenida Pico, Cam. Capistrano
• Metrolink's Application, Railroad Pre-emption & Signal Timing for Garvey Rd. at Francisquito
• Construction Engineering Management for SR 14 and Ave. S for City of Palmdale & Caltrans D-7
• U.S. Traffic Corp. LED Countdown Technical Feasibility for the City of Los Angeles Evaluation
• Ramona Blvd. & Earl Ave. Traffic Signal Timing Charts and Construction Engineering Management
• PS&E Package for 3 New Signals along Rancho Ave. at Citrus, Johnston & Laurel
• Chino Hills Traffic Signal Plan Check Services
• Reche Canyon Rd. & Topanga Way Traffic Signal Timing Charts
• Rancho Ave. & Valley Blvd. (Southeast Corner) Traffic Signal Modification
• Construction of Ramona Blvd. & Maine Ave. Signal - Preparation of Traffic Signal Timing Charts
• Review of Caltrans Timing Plans at 3 Locations along Puente, Merced &I-10
• Metrolink Railroad Grade Crossing (Garvey & Francisquito) - Final Timing Charts installation!Review/CEMIInspection
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Baldwin Park, CA
Norwalk, CT
Hackensack, NJ
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Irvine, CA
Colton, CA
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• PS&E Preparations for Conversion of 2 Flashing Signals to Pedestrian Signals along Burbank Blvd.
• U.S. Route 27 Traffic Signal Progression for OKI Regional Council of Governments
• Construction Support Services for ITMS & Traffic Signals Interconnect Projects
♦ PS&E Preparation for Traffic Signal Modification for Protected Left -Tum Phases at Mt. Vernon & Rancho
• PS&E Preparations for 2 New Traffic Signals along Los Angeles St. at Center & Bresee
• PS&E Preparation for Traffic Signal Modification of Auto Zone at Sunny Mead & Graham
• PS&E Preparation for Traffic Signal Modification for New 5 -Story Building at Spruce St. & Iowa St
• PS&E Preparation for 2 New Traffic Signals at Maine/Ohio & Olive/Stewart
• Timing Charts & CEM Preparation for 3 Signals along Los Angeles St
• Timing Charts & CEM Preparation for 1 New Signal at Maine & OhiolHallwood
• U.S. Route 7 Relocation Study, Signal Design & Capacity Analysis for Connecticut DOT
• Packard!Bambergers Development Traffic Signals Cost Estimating
• PS&E Preparation for Traffic Signal Modification at Ave. L & 10th St. W.
• PS&E Preparation for 3 New Traffic Signals at Baldwin Park Blvd. & Stewart, L.A. Street/Phelan & PuentelChanning
• SR -133 1 Laguna Canyon - PS&E Preparation for Traffic Signal Modification
• PS&E Preparation for Traffic Signal Timing Chart for New Traffic Signal at La CadenalBarton
• Traffic Signal liming Charts Modification for Ahern/Merced & VinelandlMerced
• PS&E Preparation for Traffic Signal Modification & As -Built for Alameda/Lake
• Traffic Signal Timing Charts for Mt. Vernon/Colton Ave.
Sheet 4 of 5
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♦ Traffic Signal Operations Assessment for Fowler Rd. & Mitchell Rd.
• PS&E Preparation for a New Signal at W. Artesia Blvd. & Dalton 1
• Desert Cities Industrial Park - PS&E Preparation for a New Signal along State Highway 111 & "A" St.
♦ Tustin Field 1I - Harvard at Moffett Traffic Signal Modification
• Traffic Signal Modification Design for 20th St West & Ave. K
• Traffic Signal Modification Design for 60th St. West & Ave. K
• 2 Traffic Signal Modification Designs for I-10Nalley/Mt Vernon & Washington/Mohave
• PS&E Preparation for a New Mid-Block/Pedestrian Traffic Signal at Mt. Vernon & Palm
• Virginia Beach's Traffic Signal Cost Estimating
• Traffic Signal Timing Charts for Colton Ave. at 10th Street/G Street 1
I. ♦ Traffic Signal Modification for Reche Canyon Rd. at Topanga
• PS&E Preparation for Traffic Signal Modification at AlamedaNictory Blvd.
• PS&E Preparation for a New Traffic Signal at La Cadena Dr. & La Loma Ave.
• Traffic Signal Modification for El Camino Real & Barcelona
• Newport Blvd. Traffic Signal System Improvement for City of Costa Mesa
♦ Temporary Traffic Signal Modification Design for MWD & WMWD's Perris Valley Pipeline construction
• Temporary Traffic Signal Modification Design for Alessandro Blvd. at Meridian Parkway
• Temporary Traffic Signal Modification Design for Alessandro Blvd. between Sycamore Canyon BI. & Mission Grove
• Orange County EMA's Traffic Signal Design & Study of Melinda Road & Las Fieras
Sheet 5 of 5
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• City of Temecula's Evaluation of ITS Deployment Project Temecula, CA
• City of Santa Clarita's Automated Red Light Photo Enforcement Proposal Evaluation Santa Clarita, CA
• City of Santa Clarita's Corridors Traffic Signal Synchronization Evaluation 1 Santa Clarita, CA
• City of Santa Clarita's Thoroughfare Signal Interconnect Santa Clarita, CA
• City of Modesto & Caltrans 0-10 Traffic Signal Synchronization Evaluation Modesto, CA
• City of Ceres Traffic Signal Synchronization Evaluation Ceres, CA
• City of Calabasas Upgrade of Traffic Operations Center Calabasas, CA
• City of Palmdale, Los Angeles County & Caltrans D-7 Traffic Signal Coordination & Retiming Evaluation Palmdale, CA
• City of Modesto, Stanislaus County & Caltrans D-10 Traffic Signal Synchronization Evaluation Stanislaus County, CA
• City of Baldwin Park & Los Angeles County Traffic Signal Retiming Evaluation Baldwin Park, CA
• City of Modesto & Caltrans D-10 Downtown Traffic Signal Synchronization Evaluation Modesto, CA
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• Los Angeles County MTA's Traffic Signal Timing Training Workshops
• Los Angeles County MTA's Video Detection & Surveillance Training Workshops
• Los Angeles County MTA's Systems Comunication Training Workshops
• Los Angeles County MTA's RSTI-Port of Long Beach's Evaluation of Anaheim St. Grade Separation
• Los Angeles County MTA's RSTI-City of South Gate's Evaluation of SB 1-710/Firestone Interchange
• Los Angeles County MTA's RSTI-City of Los Angeles's Evaluation of Normandie Ave. Improvements
• Los Angeles County MTA's RSTI-City of Burbank's Evaluation of North & South Front Street Improve/nenta�
• Los Angeles County MTA's RSTI-City of Calabasas' Evaluation of Old Town Road Improvements
• Los Angeles County MTA's RSTI-City of Palmdale's Evaluation of Pearblossom Highway Widening Ij
• Los Angeles County MTA's RSTI-City of Lancaster's Evaluation of SR14/ Ave. L Corridor
Sheet 1 of 2
SYSTEM EVALUATION PROJECTS and "BEFORE" & "AFTER" STUDIES
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• Metro/LA County MTA FY 04-08 On -Call Bench Contract for Electrical Engineering
• City of Ceres Citywide & Caltrans D-10 Traffic Signal Synchronization
• Technical Evaluation of U.S. Traffic Corp. LED Countdown for the City of Los Angeles
• Preparing B/C Assessment for Proposed Rancho Vista (Ave. P) & Railroad Grade Separation
• Modesto's 145 Traffic Signal Synchronization along 22 Corridors
Sheet 2 of 2
PLANNING, DESIGN & IMPLEMENTATION PROJECTS
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Los Angeles, CA
Modesto, CA
Temecula, CA
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Extension of Ave. R Traffic Signal Interconnect & CCTV Design for 72 SMFO b/w Division & 40th E.
Preparing Signal Systems PS&Es for Boeing's New Douglas Park Development
Management of Architectural Design for New TOC/TMC in Santa Clarita
Providing Construction Support Services for ITMS, Traffic Signal Interconnect, ITS & TMC/TOC
Caltrans State Route 66 Advanced Traffic Control Systems, CCTV, Fiber -Optic PS&E
Traffic Signal Synchronization for 145 City & State Locations Outside the CBD -FY 2007
Los Angeles County MTA/Metro's Santa Monica FRWY ITS Systems Evaluation
Los Angeles County MTA/Metro's Systems Communications Training Workshops
Los Angeles County MTAIMetro's Video Detection & Video Surveillance Training Workshops
Los Angeles County MTAIMetro's Homeland Security Training Workshops
Los Angeles County MTA/Metro's TMC Tour of Regional Centers Training Workshops
Caltrans Santa Monica FRWY I-10 ITS/CCTV
City of Modesto CCTV Systems Expansion
Temecula's ITS Deployment: TOC, CCTV & Fiber Optic PS&E Design
ITS & Traffic Signal On -Call Design Services
Southern California ITS Showcase Program Evaluation for Caltrans HQ I
City of Modesto CCTV Systems
City of Ceres ATMS Project
Upgrade of the Calabasas Regional Traffic Operations Center/Las Virgenes Interconnect PS&E
Santa Clarita Intelligent Transportation Management System f
Santa Clarita Thoroughfare Signal Interconnect for 30 miles
Sheet 1 of 3
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Los Angeles County, CA
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Caltrans TSM Grant Application Preparation
Caltrans' Interstates 5 & 405 Confluence "El Toro Y" TSM & CEM
Santa Clarita's Automated Red Light Enforcement Proposal Evaluations
Evaluation of the Red Light Camera System Deployment]
Los Angeles County MTA Traffic Signal Timing Training Workshops
Modesto's Traffic Signal Retiming & Coordination Project
City of Modesto Traffic Signal Systems Network
City of Modesto & Caltrans Downtown Signal Systems Network
City of Palmdale/Caltrans & LA County Signal Systems Retiming
City of Ceres & Caltrans Traffic Signal Systems Network
City of Baldwin Park Master Interconnect Design
City of Baldwin Park Master Traffic Signal Network
Los Angeles County MTA Type 170 Controller Signal System Training Workshops
Caltrans HO/SCAG AHS/M Work Scope Development
Sheet 2 of 3
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FHWAINAHSC AHS Operations & Maintenance for State DOTs
FHWA/NAHSC AHS Outreach & Focus Group for State DOTs
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EXHIBIT "2"
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M I NAGAR & ASSOCIATES, INC.
ITS - TrafficlCivil/Electrical Engineering - Transportation Planning - Homeland Security - CEM Consultants
August 3, 2021
Mr. Bruce T. Bauer, Esq.
Of Counsel
Slovak Baron Empey Murphy & Pinkney LLP
1800 E. Tahquitz Canyon Way
Palm Springs, CA 92262
Subject: Expert Review of Traffic Report (Appendix L.1), VMT (Appendix L.2), Trip
Generation Comparison (Appendix N) & Draft EIR (Section 4.13 Transportation)
for the Coral Mountain Resort Specific Plan, SCH#2021020310, in the City of La
Quinta, CA
Dear Mr. Bauer,
On behalf of Minagar & Associates, Inc., I welcome this opportunity to present to you
our technical review comments of the traffic/transportation/circulation related sections
and appendices of the proposed subject project in the City of La Quinta, Riverside
County, California. Subsequent to our review of the entire technical document, we have
the following salient comments:
Traffic Report (Appendix L.1), June 2021
1. Page 1/140, Section 1.1, & Page 139/140 References, the City of La Quinta's
Traffic Study Guidelines (Engineering Bulletin #06-13, dated October 13, 2017)
should also be included.
2. Various available General Plan Circulation Element documents prepared by Iteris
and by Terra Nova for the City of La Quinta (prepared July 2012 and adopted in
2013) refer to La Quinta 2035, while the General Plan Buildout 2040 is used in
the subject DEIR. What is the source of 2040 GP Circulation data in the reports?
3. Page 9/140, on Table 1-5: Summary of Phased Intersection Operations, for the
Intersection #9, under Phase 2 (2023) "Without Project" scenario, the intersection
delay values cannot be lower than Phase 1 (2021) during the AM peak hour.
4. Page 10/140, on Table 1-6: Summary of General Plan Buildout (2040)
Intersection Operations, for the Intersection #16, under "With Project" scenario,
the intersection delay values cannot be lower than "Without Project" during the
AM peak hour.
5. Page 11/140, on Table 1-7, there are missing results for Phases I (2021) & II
(2023).
6. Page 11/140, on Table 1-7, LOS results need to be shown for each segment in
order to easily determine level of significance.
7. Page 11/140, on Table 1-7, a column needs to be added to show potential
impact/level of significance.
8. Page 26/140, on Exhibit 3-1, for the Intersection #1, southbound approach, per
the existing geometry, one shared thru-right, one thru and one left turn lanes
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configuration should be used rather than one right, two-thru and one left turn
lanes.
9. Page 26/140, on Exhibit 3-1, for the Intersection #4, eastbound approach, per the
existing geometry, one shared thru-right, one thru and one left turn lanes
configuration should be used rather than one right, two-thru and one left turn
lanes.
10. Page 26/140, on Exhibit 3-1, for the Intersection #7, for all approaches of the
roundabout, per the existing geometry, one exclusive right and one shared thru-
left configuration should be used rather than one shared thru-right and one
shared thru-left lanes.
11. Page 29/140, Traffic Volumes and Conditions: While in overall the Traffic Impact
Study has conformed with the City of La Quinta TIA Guidelines EB#06-13, the
fact that for this very sensitive mega project various historic traffic volumes from
Thursday, August 15, 2017, Tuesday, April 9, 2019, Tuesday, May 7, 2019 and
Tuesday, September 10, 2019 have been used, is troublesome! The cost
associated with collecting fresh counts for 17 intersections right after the
approval of the Scoping Agreement on February 12, 2020 (Appendix 1.1, Page
1.1-1) was very low prior to the start of COVID-19 pandemic on March 15, 2020.
Traffic volumes are the foundation of each traffic impact study. Furthermore, for
this mega project, the traffic volumes for 9 major intersections were estimated
while they could have been freshly counted! In order to establish public trust, the
most current traffic volumes ought to be used. Since the City of La Quinta is a
growing dynamic city (per Table 4-4, Page 56/140 there are 41 ambient new
developments within the project boundaries), therefore, the overall validity of the
traffic volumes is questionable!
12. Page 38/140, on Table 3-4, LOS results need to be shown for each segment in
order to easily determine level of significance.
13. Pages 41-43/140, Tables 4-1, 4-2 & 4-3, percentages and source(s) of each
of internal and pass -by (in some cases) reduction should be shown for each land
use category.
14. Page 43, Table 4-3, at the bottom, the last row, the totals for AM In and AM Out
ought to be 143 & 304 rather than 147 & 300 respectively.
15. Page 60/140, why wasn't SCAG's 2020 RTP utilized?
16. Page 109/140, on Table 7-2, LOS results need to be shown for each segment in
order to easily determine level of significance.
17. Page 111/140, on Table 7-4, LOS results need to be shown for each segment in
order to easily determine level of significance.
18. Page 114, Table 7-5, for Intersections #20, 21 & 22, why the exact Storage
Lengths are not shown while the 95th Percentage Queue Lengths are?
19. Page 115/140, Section 8.2, while it is understandable that for the Special Events,
the ITE Trip Generation Manual does not provide the weekend rates, how come
a survey or data of a similar facility wasn't used as opposed to estimating?
Where is the source of 2.4 vehicle occupancy?
20. Page 118/140, Table 8-3, Trip Generation Results for 2,500 Guests for Wave
Basin Facility, are those AM & PM estimated traffic generation numbers realistic?
23282 Mill Creek Drive, Suite 120, Laguna Hills, CA 92653
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21. Page 127, Table 8-5, for the Intersection #20, show the exact Storage Length for
NBL/NBR for the Departure.
22. Page 128/140, for the special events, in addition to the preparation of Traffic
Management Plan, an additional Traffic Control Plan must be prepared and
signed by a registered Traffic and/or Civil Engineer in California to assure public
safety and smooth traffic navigation when 2,500 guests show up at the Wave
Basin Facility during special events during weekends.
23. Page 139/140, ITE Trip Generation, 10th Edition, 2017 ought to be cited not 9th
Edition, 2012!
Draft EIR, June 2021
24. Page 1-6, why only 12 acres of the Wave Facility has been used for trip
generation purposes, while the Proposed Land Use Summary does list quite
different acreages?
25. Page 1-30, TRA -9, line 4, the word "not" should not be there!
26.There should be an additional condition/clause/TRA listed for the subject project,
stipulating that upon the completion of the last phase of the project (6- 12 months
later), the City of La Quinta at the expense of the project developer, should
monitor the traffic conditions surrounding the project site for any potential
abnormality during a random weekend special event and assess the traffic Level
of Service and propose appropriate mitigation measures.
27. Page 3-17, why only 12 acres of the Wave Facility has been used for trip
generation purposes, while the Proposed Planning Area Summary does list quite
different acreages?
28. Page 4.13-2, Proposed Project, why only 12 acres of the Wave Basin has been
used for trip generation purposes, while in the Proposed Project description does
list quite different acreages?
29. Page 4.13-18, Table 4.13-10 Trip Generation Summary, why are there
discrepancies for the quantities for Shopping Center, Wave Basin Facility, Wave
Village and The Farm as compared with the similar tables in the Traffic Study?
30. Page 4.13-21, Table 4.13-13 Trip Generation Rates, why are there discrepancies
for the quantities for Wave Basin Facility and Wave Village as compared with the
similar Table 4-3 in the VMT Report (Appendix L.2)?
31. Page 4.13-41, Table 4.13-24 Project Phase 3 Fair Share Contributions, why are
locations #16 & 17 missing? (not the same as Table 9-1 the Traffic Report)?
32. Page 4.13-26 Weekend Special Event Trip Generation, show percentages and
source(s) of reductions for the internal and pass -by trips.
33. Page 4.13-59, the growth factors for traffic volumes for the Horizon Year 2040 for
with and without project conditions ought to be documented.
34. Page 4.13-62, TRA -9, line 3, the word "not" should not be there!
35. Page 4.13-62, a new TRA to be added to state that the TMP and TCP must be
signed by a registered Traffic and/or Civil Engineer in California.
23282 Mill Creek Drive, Suite 120, Laguna Hills, CA 92653
Tel: (949)707-1199, Web: www.minagarinc.com
MINAGAR & ASSOCIATES, INC.
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VMT Evaluation, June 2021
36.The TAZ and low VMT maps for the subject project should be included in the
VMT report.
37. Page 4 of 9, Table 1, why is the title different than the corresponding Table 4.13-
30 in the DEIR document?
38. Why does the City of La Qunita's VMT Guidelines categorizes Hotel Land Use as
Retail, while other cities in California assume as Service?
39. Project Service/Retail VMT Calculations need to be explicitly shown in the VMT
report.
40. Page 6 of 9, Table 4: the title needs to be clarified, Base Year or Base Year
Model or Base line or Cum Year Model?
41. Page 7 of 9, for the three (3) sources of VMT reductions of 3%, 2% & 1% each
corresponding source from CAPCOA must be documented.
42.Table 4-3, Project Buildout (2026) Trip Generation Summary, percentages and
source(s) of each of internal and pass -by (in some cases) reduction should be
shown for each land use category.
43.Table 4-3, Project Buildout (2026) Trip Generation Summary, why is the Farm
Land Use missing?
44.Table 4-3, Project Buildout (2026) Trip Generation Summary, why is this table
different than Table 4.13-13on Page 4.13-21of the DEIR?
45. For the Wave Pool Facility, since the ITE Trip Generation Manual, 10th Edition
2017, does not provide any rates, SANDAG's Manual for Recreation Park
(Developed) from April 2002 has been used for the VMT, DEIR & Traffic Report.
The aforementioned source is from over 20 years ago, how come surveys of two
similar facilities were not used?
Should you have any questions, regarding this proposal, please don't hesitate to contact
me at (949)707-1199, Extension 2# or more conveniently via e-mail at
minagarfc minagarinc.com.
Thank you.
Sincerely,
MINAGAR & ASSOCIATES, INC.
(A California Corporation)
r
Fred Minagar, MS, RCE, PE, FITE
President/Senior Project Manager
23282 Mill Creek Drive, Suite 120, Laguna Hills, CA 92653
Tel: (949)707-1199, Web: www.minagarinc.com
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M I NAGAR & ASSOCIATES, INC.
ITS - Traffic/Civil/Electrical Engineering - Transportation Planning - Homeland Security - CEM Consultants
August 2, 2021
Mr. Bruce T. Bauer, Esq.
Of Counsel
Slovak Baron Empey Murphy & Pinkney LLP
1800 E. Tahquitz Canyon Way
Palm Springs, CA 92262
Subject: Expert Lighting Review of DEIR & Appendix B for Coral
Mountain Resort, SCH#2021020310, in the City of La Quinta, CA
Dear Mr. Bauer,
On behalf of Minagar & Associates, Inc., I welcome this opportunity to present to you
our technical review of the lighting section of the proposed subject project in the City of
La Quinta, Riverside County, California. Subsequent to our Principal Electrical
Engineer's review of the entire lighting section, we have the following salient comments:
Manufacturers use fewer, higher output LEDs to cut fixture costs. Also, it provides a
very high lumen output from a small source to obtain a better efficacy (lumens/watt). In
this EIR LED lighting has been proposed. Glare is one of the most common and
annoying lighting problems. Glare occurs when the contrast between dark and light is
accentuated. Because the proposed light sources use a bunch of little, tiny LED
sources. And that causes glare. In essence the same amount of light out of a LED
source in a much smaller space which causes a greater glare impression than a
standard LPS or HPS lighting source.
LED light sources typically emit too much light which causes light pollution. Like all
pollution, this can have a negative and adverse impact on the human body. It can lead
to stress, exacerbates mental health issues, cause headaches, sleep patterns issues,
that can affect well-being of the person(s) and nocturnal animals subject to this type of
pollution.
In open field disability and discomfort glare-- basically disability glare limits your ability
to see something, so you're disabled that way. How this works is, as the light goes
through your eye, it hits all the medium of your eye-- so the cornea, the lens, the
vitreous humor, all those things-- and it scatters. So, every time it hits something, it
scatters. And it keeps scattering. And so, it basically casts a veil of light across your
retina.
Discomfort glare is causing discomfort or irritation in the person. There is also nuisance
glare which there is no good matrix of measurement for it. It's just sort of a light source
that's kind of bugging you but really not causing you any discomfort or pain.
23282 Mill Creek Drive, Suite 120, Laguna Hills, CA 92653
Tel: (949)707-1199, Web: www.minagarinc.com
MI NAGAR & ASSOCIATES, INC.
ITS - TrafficlCivillElectrical Engineering - Transportation Planning - Homeland Security - CEM Consultants
The area surrounding the proposed high intensity LED lighted sight is dark in respect to
the lit area which causes more glare due to the wide-open space that gives as a person
walks through. One of the fundamental things about glare is that it's dependent on your
adaptation limits and especially annoying and dangerous for older people because the
ability of the eye to adjust to light and dark conditions is drastically reduced.
Providing the right lighting solution for an exterior application should take into
consideration glare, along with the specific site requirements for spacing, efficiency, and
visual comfort. Current means of measuring glare in exterior applications are not fully
defined or comprehensive. Ways to is by the following: Shielding, diffusion, selection of
warm CCTs, and reducing contrast of the Effective Luminous Area. Reducing glare may
reduce the efficiency of the luminaire and the spacing, height which were not addressed
in this DEIR report nor in Appendix B due to cost and potential redesign of the project.
We have to bear in mind that, the level of glare that an individual experiences is highly
subjective. Therefore, the designers should install mock-ups in order to confirm
adequate performance and visual comfort of the concerned parties affected by such
installation. Shielding and Diffusion in LED Luminaires has not been explored in the
DEIR report nor in Appendix B. There is no alternative solution/ study provided for the
intensity from the luminaire, the number of luminaires, the size of the luminaire, and the
height or the angle of the luminaire.
Should you have any questions, regarding this proposal, please don't hesitate to contact
me at (949)707-1199, Extension 2# or more conveniently via e-mail at
minaciarf(a�minagarinc.com.
Thank you.
Sincerely,
MINAGAR & ASSOCIATES, INC.
(A California Corporation)
Y
Fred Minagar, MS, RCE, PE, FITE
President/Senior Project Manager
23282 Mill Creek Drive, Suite 120, Laguna Hills, CA 92653
Tel: (949)707-1199, Web: www.minagarinc.com
Comments regarding DEIR Section 4.15 Utilities and Service Systems
In the CVWD Water Assessment, Coral Mountain surf pool replenishment is listed at 39 million gallons yearly.
CVWD_does not have knowledge of coefficients to account for evaporation due to Wave Action at the time of their
Water Assessment. In addition, the increasing number of days of wind action in the Coachella Valley will cause
additional evaporation. (If required, Alena Callimanis can provide additional information on the number of high wind
days in Coachella Valley). Water evaporation calculations by CVWD are based on a standard factor of 1.2 for moving
water and pan evaporation numbers from 2005. In 2005, when these calculations concluded, we only had 99 days
over 100 degrees.
Therefore, in order to determine the amount of water required, the DEIR must look at the following
information:
1) The World Surf League, which purchased Kelly Slater wave technology, wrote that on very hot days at Lemoore
Surf Ranch, the pool lost 250,000 gallons a day. It is valid to accept this as a minimum number to be used for La
Quinta, because Lemoore is in Kings County where the evapoTranspiration rate is lower than our area. Since the La
Quinta evapoTranspiration Rate would dictate a higher rate of evaporation than Lemoore, we are actually looking at
higher than 250,000 gallons per day of evaporation.
Lemoore had 27 days over 100 degrees in 2020 with hottest temperature of 107 degrees. La Quinta had 143 days
over 100 degrees in 2020. The first part of a new calculation can use 250,000 gallons a day times 143 hot days. This
equals 36 million gallons lost to evaporation in 143 days. This does not account for an additional 222 days of the
year. But considering we had 56 days over 110 degrees in 2020, it should be reasonable to expect that on the days
over 110 degrees, evaporation should be higher than 250,000 gallons. Should we calculate that at 300,000 gallons?
Especially considering our ETo is higher than Lemoore.
What about the rest of the 222 days of the year? We had 51 days over 90 degrees as part of that 222 days.
The DEIR must use numbers that reflect actual wave pool evaporations and not outdated evaporation methods. It
must include calculations based on known evaporations from wave pools.
2) The DEIR must account for the additional windy days which add to evaporation. Many sites on line provide ways
to account for actual wind evaporation. This must be included.
Respectfully,
Alena Callimanis
81469 Rustic Canyon Drive
La Quinta, CA 92253
919 606-6164
acallimanis@gmail.com
We have been told that there will be no "light pollution". However, this picture
was taken from 58th Street and shows the light impact from Bagdouma Park in Coachella,
over five miles from the Coral Mountain site. Due to the nature of fine sand particles in the air in the Desert,
light will always appear like this. And since the residents are significantly closer to Coral Mountain than
Bagdouma Park we will have significant light pollution from the seventeen 80 feet light poles. By the way, the
poles at the Park are only 60 feet height. So the light impact will be significant to the surrounding
developments
In addition, please also provide information on wind tunnel tests that have been performed on the lights to
ensure that during our wind events, the poles will not snap or bend and cause injuries.
Lisa Castro, the resident adjacent to the surf basin, has stated for the record to the City Council that
Coral Mountain causes a wind tunnel effect in this area. She has recorded significant wind events
and can provide that information if requested.
Respectfully,
Alena Callimanis
81469 Rustic Canyon Drive
La Quinta, CA 92253
919 606-6164
acallimanis@gmail.com
Section 4.6 Geology and Soils
A full study must be completed on this site due to the fact that the surf lagoon has a still water level that is as
much as 9 ft (2.75 m) deep in the center. 9 ft of water weighs 562 pounds per square foot (psf), which is a
very heavy load (a uniform freeway load is only 250 psf, as comparison). The load will fluctuate with the wave
and will cause a dynamic loading. A geotechnical engineer needs to provide an analysis to determine
the potential impact of this loading on the soil at this site.
The site is located in relatively close proximity of potentially active seismic faults and pressures due
to seismic forces. The geotechnical engineer needs to address equivalent fluid pressure for lateral seismic
forces at this site, and to be added to the geology and soils discussion.
Meriwether has discussed that they recorded the Kelly Slater wave pool in
Lemoore for seismic information and found no impact. This is not what is required here at
the Wave Basin site in La Quinta. An independent geotechnical engineer, who has not worked with
Meriwether in the past and has been vetted by us, must provide the information requested above that is
required to be included in the EIR due to this location, not Lemoore.
Alena Callimanis
81469 Rustic Canyon Drive
La Quinta, CA 92253
919 606-6164
acallimanis@gmail.com
Section 4.5 states that the project would be .19 percent of IID's total estimated demand in
2031. We are not interested in the demand in 2031. We are interested in the demand when the Wave Park
is operating 7AM to 10pm, 365 days a year, in 2023. Please provide information from IID that states that
power will be available at that rate required for the wave machinery in 2023. In addition, with IID's
aggressive peak demand energy efficiency programs, we would like to see incorporated into the EIR that IID
understands that the Wave Park's peak hours of energy demand will be 6pm to 10pm, especially in the
summer during our extreme heat and how IID and the Coral Mountain project plans to address that.
In addition, section 4.7 Greenhouse Gas Emissions, references greenhouse gas credits but bypasses the actual
discussion of the significant amount of greenhouse gas emissions as the result of the huge amount of
electricity that is required to be produced to generate waves by the Wave Pool machinery, from 7AM to
10PM, 365 days per year. We want a full accounting in the EIR of the greenhouse gas emissions, both from
electrical power creation, and from the cement production required for the 16.7 acres wave basin.
Alena Callimanis
81469 Rustic Canyon Drive
La Quinta, CA 92253
919 606-6164
acallimanis@gmail.com
With regards to the project noise levels, Section 4.11, we demand a noise evaluation to be conducted on the Coral
Mountain site, in order to determine the actual noise impact of the project. There has been a significant amount of
La Quinta City Council Public Hearing Comments on noise that is propagated currently throughout the communities
that are around Coral Mountain, including hikers conversations, shooting noises from the Lake Cahuilla Police
Shooting range, car noises, and numerous other examples. The Urban Crossroads Noise Memo, dated April 20,
2020, states that Coral Mountain is likely to absorb, rather than reflect noise. This is an
Environmental Impact Report. A speculative comment like that has no place in the EIR.
The new noise evaluation must be made directly on site so that the noise impact can be properly evaluated, both
during the day and during the hours of 8pm to 10pm. There must be an independent sound advisor available
during the study so that we are comfortable with the results.
The importance of this cannot be brushed aside by an evaluation that is determined by computer simulations.
Even though sensors were placed around the Coral Mountain site to record pre-existing sound conditions,
that cannot be used to predict the actual noise levels on site.
Please inform me when this is scheduled so that we make sure an independent noise consultant will
be able to join the analysis.
Respectfully,
Alena Callimanis
81469 Rustic Canyon Dr.
La Quinta, CA 92253
919 606-6164
acallimanis@gmail.com
have significant concerns about the undercalculation of the use of chlorine at the Wave
Basin. With our excessively high temperatures, the risk of warmer water means more
chlorine demand. Both living and non -living contaminants are more prevalent in warmer
water. Algae, bacteria and brain -eating amoebas,
for instance, are living contaminants that chlorine must kill. Warmer water means those
microorganisms can reproduce more rapidly, therefore problems like algae and bacteria are
more prevalent in the summertime. To kill any living organism, chlorine needs a certain
amount of contact time (CT). Hotter days mean more non -living organics in the water, like
sunscreen and body oils. Between these organics and the living contaminants like algae
and bacteria, warm water has a higher chlorine demand than cold water.
For example, dosing at 5ppm/day, chlorine consumption could be 1,100Ibs/day of 68%
briquettes.
This is a significant amount of chlorine that needs to be kept on site. What are the
precautions that are being taken to safely house this significant amount of chlorine? To
keep it cool?
am concerned that the filtration systems will not be able to circulate the water an adequate
amount. In our excessive high temperatures, if full pool circulation through the filtering
system takes significantly longer than once per day, there is a high risk of not properly
removing all contaminants. This poses a danger to the health and safety of surfers and
people in the pool.
would like to understand more fully in the EIR how the developer will address the chlorine
and filtration required at the excessively hot water temperatures found here (pool
temperatures have been between 93 and 97 degrees, with no cooling relief overnight). This
is a big risk to the health and safety of all surfers/people in the water, that must be
addressed.
Respectfully,
Alena Callimanis
81469 Rustic Canyon Dr
La Quinta, CA 92253
919 606-6164
August 06, 2021
The City of La Quinta
78-495 Calle Tampico
La Quinta, CA
92253
Attention: Ms. Nicole Sauviat Criste
Delivered Via Email
Dear Ms. Sauviat Criste:
Re: Response to Draft EIR
Coral Mountain Resort
Following please find my response to the DRAFT EIR (the "DEIR") for the Coral Mountain
Resort (the "Project'). I anticipate that a number of other concerned residents will prepare
responses commenting upon zoning, aesthetics, noise and lighting so I will focus my response to
two issues where analytic review can provide support to my comments.
In general, my concerns lie in three areas that will be detailed further in my report. A short
summation of these issues follows:
• MSA Consulting Inc. failed to disclose what I believe to be a conflict of interest in their
engagement as prime consultant in the preparation of the DEIR which results in bias in the
conclusions contained within the DEIR.
• The calculated water consumption determined by MSA Consulting Inc. did not take into
consideration the City of La Quinta's Maximum Applied Water Allowance for this project.
The calculated outdoor water consumption is at 99.98% of the City of La Quinta's legislated
maximum consumption for this site leaving no additional capacity for emergency or
maintenance use.
1 ors
• The increased vehicular traffic loads will result in significant reductions in levels of service
necessitating roadway and signalization upgrades for which the Project developer will only
pay a small percentage of the associated costs.
1. MSA Consulting Inc's Engagements
I would like to commence this response by commenting on the DEIR prepared by MSA
Consulting Inc. ("MSA"). During my reading of the Notice of Proposal in March of 2021, I
reviewed a number of grading and site layout drawings for the project which had MSA's logo on
them leading me to understand that they had been prepared by MSA. Clearly, MSA had been
retained to act in the role of a civil engineering consultant by the developer several years ago and
was engaged well before the preparation of the DEIR commenced. MSA was subsequently
engaged to act as the prime consultant in the preparation of the EIR. In my view, this is a serious
conflict of interest which results the calling into question the credibility of the entire DEIR and
any of the conclusions presented in the DEIR by MSA.
The National Society of Professional Engineers ("NSPE") has issued a Code of Ethics that all
practicing Professional Engineers are expected to understand and follow. MSA, in my opinion,
has contravened the Code of Ethics by not addressing their retainer as the design engineer in the
DEIR. Without this disclosure, readers of the report are given the impression that MSA is acting
as a neutral independent party in preparing the DEIR for the lead Agency, The City of La Quinta.
Following is Cannon 5 taken from the NSPE's Code of Ethics and it states:
5. Engineers shall not be influenced in their professional duties by conflicting interests.
MSA is not a neutral party in the preparation of the DEIR as MSA has and may continue to
receive financial gain as the civil engineering consultant for the Project in the event the Project
receives regulatory approval. Without clear disclosure, the average reader of the DEIR will
assume that MSA, acting in their professional capacity, is entirely neutral and that the
conclusions they present are statements of fact and are not influenced by past or future financial
gain. This undisclosed Conflict of Interest causes any conclusions made in the report to be called
into question. Even the perception of a possible conflict of interest should be sufficient reason
for MSA to include in the DEIR their prior engagement as the design engineer by the developer
to ensure full disclosure is provided to all readers of the DEIR which is a public document issued
through the city of LA Quinta.
2 of 5
2. Water Consumption and the Water Servicing Agreement
Appendix M to the DEIR is the Water Servicing Agreement (the "WSA") between the Coachella
Valley Water District ("CVWD") and the developer of the project. The updated water demand
was prepared by MSA and submitted to the CVWD in a letter dated September 28, 2020. The
updated WSA indicates that the Project's calculated outdoor water demand is 810.47 acre feet.
I have reviewed the City of La Quinta's Municipal Code with respect to the annual Maximum
Applied Water Allowance ("MAWA") for new developments. The Municipal Code defines
MAWA as follows:
"Maximum applied water allowance" means for design purposes, the upper limit of
annual applied water for the established landscaped area, as specified in Division 2, Title
23, California Code of Regulations, Chapter 7, Section 492. It is based upon the area's
reference evapotranspiration, the ET adjustment factor, and the size of the landscaped area.
The estimated applied water use shall not exceed the maximum applied water allowance.
In the following comments, I refer to Article 8.13 of the La Quinta Municipal Code and
specifically, section 8.13.030. It is my understanding that MAWA applies to the aggregate
annual amount of water which is available for use by a project outside of the buildings. This
procedure is consistent with the MAWA calculations provided by CVWD in the WSA.
The City of La Quinta's MAWA calculation equation from section 8.13.030 of the Municipal
Code is reproduced following:
MAWA = ( ETo X 0.45 X LA X 0.62 ) / 748
Inserting an ETo (reference evapotranspiration) of 75 inches per year which is specified by the
City of LA Quinta in section 8.13.030 and an outdoor landscaped area of 12,656,401.56 square
feet (taken from table 2.0-3 of the WSA) into the referenced equation results in a MAWA for this
site of 354,057.76 hundred cubic feet or 812.81 acre feet of water. The estimated outdoor
consumption calculated by MSA of 810.47 acre feet is therefore 810.47/812.81 or 99.8% of
MAWA. The total estimated consumption as determined by CVWD is for evapotranspiration
only and does not include for extraordinary irrigation or for filling or refilling of the wave pool,
swimming pools or the lakes and ponds located within the project.
3 of 5
If the wave pool evaporation calculated by MSA is even marginally greater than what has been
estimated, or, if maintenance requires the emptying and refilling of any of the ponds, pools or the
surf/wave basin, then the project's water consumption will exceed the Iegislated MAWA for the
site. It is my understanding that a development cannot consume more water than that
determined using the MAWA equation in the City of La Quinta. The DEIR is silent on this
important issue and, in my view, does not portray an accurate representation of the true impact
the water consumption will have relative to the La Quinta Municipal Code specified MAWA.
The NSPE Code of Ethics addresses the honesty of an engineer's work as follows:
3. Engineers shall avoid all conduct or practice that deceives the public.
a. Engineers shall avoid the use of statements containing a material misrepresentation of
fact or omitting a material fact.
The important material fact that was not included in the MSA Report was that the estimated
water consumption on this site is essentially already at MAWA without the demand for additional
water in the event that evaporation or maintenance demands are higher than what was allowed
for by MSA in their estimates.
3. Traffic Changes caused by the Project
Once the Tourist Commercial aspect of Project is "up and running" there will be resulting traffic
loads that will significantly impact our day to day lives as we know them. In my opinion, the
traffic study included in the DEIR is flawed as it was conducted during COVID when many
seasonal residents chose not to return to the valley. The base traffic volumes used in the analysis
are therefore likely an underestimation of the actual volumes. The study shows that levels of
service in some of the affected areas will be reduced to level F. The DEIR recommends that
changes be implemented to reduce the impacts on the Level of service. The developer has stated
that they will pay for "their proportional share". The citizens of LQ Quinta are then stuck with
the remainder of the costs, a very unreasonable expectation for citizens of La Quinta.
Additionally, the study finds that the so called "special events" will further increase the
anticipated traffic loads on the exiting transportation infrastructure. Once again, the burden for
these traffic loads will be borne by the citizens of La Quinta with increased travel times, delays
in commutes resulting in significant green house gas emissions. The report does not address
these environmental impacts on the quality of life for residents in the adjoining neighbourhoods.
4 of 5
In closing, the DEIR for the Project appears to have been prepared by a consultant who is
conflicted in their professional capacity without adequate disclosure of the conflict to readers of
the report. Furthermore, the DEIR contains language that is repetitive, subjective and attempts to
obfuscate that facts. Engineers are to prepare reports based on facts and not to include overly
descriptive language or superlatives in an attempt to sway readers to a proponent's proposal.
This DEIR is short on objective facts and burdened with opinion and superlatives.
In my view, the DEIR is in need of significant rewriting bearing in mind the obligations that
Professional Engineers are required to adhere to in work that will be relied upon by City
Officials and members of the public. Any conclusions presented in the current DEIR are
therefore called into questions regarding their objectivity given the MSA's prior engagement with
the Project's developer on this matter.
I may be contacted at the number below with any questions that you may have.
Yours truly,
Anast Demitt, P.Eng., FEC, FGC (Hon), MASCE
60149 Honeysuckle Street
La Quinta, CA, 92253
403-870-2109
copies to:
La Quinta Planning Commission via Email: cdd@la-quinta.org
Ms. Cheri Flores, Planning Manager, City of La Quinta via Email: clflores@laquintaca.gov
La Ouinta City Council
Ms. Linda Evans. Mayor via E-mail: ievans(a7laquintaca.gov
Mr. Robert Radi, Mayor Pro Tem via E-mail: rradi@laquintaca.gov
Ms. Kathleen Fitzpatrick, Council Member via E-mail: kfitzpatrick@,laquintaca.gov
Mr. John Pena, Council Member via E-mail: jpena@laquintaca.gov
Mr. Steve Sanchez, Council Member E-mail: ssanchez@laquintaca.gov
5 of 5
Friday, August 6, 2021 at 15:02:00 Pacific Daylight Time
Subject: Coral Mountain Resort - WavePark - Response/Comments to the EIR
Date: Friday, August 6, 2021 at 2:51:09 PM Pacific Daylight Time
From: Mary Greening
To: consultingplanner@laquintaca.gov
CC: Dan Greening, Mary Greening
Thank you for the opportunity to provide commentary on the EIR for the Coral Mountain Wave Project. As 15 year
homeowners at Andalusia CC, we have enjoyed the serenity of this part of La Quinta, and believe the proposed
waterpark development is not in sync with other developments in the area.
We support the following alternative considered for evaluation, in order of preference:
Alternative #2 — No Project/Existing Entitlements
Alternative 4—The Golf/Resort Hotel Alternative
Alternative 5 — The lake amenity/No Hotel
Alternative 3 — Reduced Density Alternative
If the project continues, we would like to voice the following issues/concerns:
Visibility/Lighting:
We are very concerned about the lights that will be visible from the top viewing levels of the hotel. A 4 -story
structure is significantly above the predominantly single level only housing in the area, and the top of the building
and its lights would be visible from adjacent neighborhoods.
We are even more concerned about the 80' proposed lights over the wave park. These towers would not only be
visible from a distance, even unlight, but would also impact views of the mountain and the night sky.
Noise
This neighborhood is very quiet. We can hear the cars from the Thermal Club, which is much further away than the
proposed project. Our concerns are:
- Traffic noise on Madison
- Noise from the filtering and heating system for the wave park (which we couldn't find
addressed in the EIR). The waterpark will need to be heated much of the year, and filtering will
be constant
- Noise from the announcers
- Noise from spectators
- Noise from special events
Traffic
We believe there should be 2 main entrances into the development — one as proposed, which would serve only
residents, and a second, which would be off Madison in the south end of Sec. II, which would serve the hotel, wave
park, tourists.
We are very concerned about the increased traffic levels, particularly during special events.
We also do not want traffic light(s), now or in the future, on Madison at 58th, 60th, or inbetween
Hours of Operation
The hours of operation should be reduced. We would propose an opening no earlier than 8 am, with a closure from
Page 1 of 2
October through February no later than 7 pm, and from March through September of 8 pm. With lights doused at
the wavepark and on the viewing area of the hotel at these hours, there would be much less impact of lights on
nearby communities.
Special Events
We would prefer no special events, but if they are to be allowed, we would propose that they never be held during
any concert, art, or other main event at the polo grounds, and not during athletic events like the bike tour,
triathalons, etc.
Operations during Wind Events
Cancel operations if winds are > 20 mph or gusts > 25 mph. We have high gust rates in this area even when winds are
in the 20's due to the currents coming down the mountains
Border Wall and Landscaping
A wall higher than normal would help reduce noise. Planting of large trees such as palms, tipuana's, etc. on the
exterior and interior would reduce visibility of the hotel, lights, etc.
Thank you. We look forward to receiving updates on the review and approval process. Please add us to your mailing
list.
Dan Greening - dan@dmgreening.com
Mary Greening - mary@dmgreening.com
58385 Mijas
La Quinta, CA 92253
Mary Greening
mary@dmgreening.com
760-777-1831 (home)
760-238-1911 (cell)
Page 2 of 2
Mail - Consulting Planner - Outlook https://outlook.office.com/mail/deeplink?popoutv2=1&version=202107...
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Coral Mountain Resort DEIR
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J
J <Iqtampico@yahoo.com>
Fri 8/6/2021 2:32 AM
To: Consulting Planner
** 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. **
Attn:
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
It is with great dismay I begin this letter in response to the DEIR on the proposed Coral
Mountain Resort.
I really don't know where to begin. The DEIR is way too long for the La Quinta average
citizen to read which I believe is by design.
There are so very many things wrong about this project but when speaking specifically
about the DEIR, I am seeing way too many statements of the impact in any given category
being unknown or only being projected based on years old data.
The drought situation alone should be enough to stop this project.
Farmers will not have enough water to grow food in CA. This translates to hunger,
unemployment, and a tanked economy. Why approve a project that will leave a hole in
the ground when there is no water to be had? Will LQ residents need to conserve and
thirst, not bathe, so we can have a recreational wave park?
Everything is wrong about this proposed project, everything.
From water waste to increased noise to a horrendous number of STVRs, which are already
a huge problem for La Quinta, this project cannot go forward.
What about the 2035 La Quinta report, written and approved by the Mayor and Council,
that states good use of valuable resources as a prime goal?
This project would not comply with any good use of resources, especially water.
Sincerely,
Carol Jensen
La Quinta Homeowner
1 of 1 8/6/21, 8:00 AM
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Re: Wave Park Development
0 You replied on Fri 8/6/2021 12:40 PM
SK
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Suzanne Kahn <suzanne@coral-zone.com>
Fri 8/6/2021 11:56 AM
To: Consulting Planner
** 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. **
On Fri, Aug 6, 2021 at 11:54 AM Suzanne Kahn <suzanne@coral-zone.com> wrote:
Please do not approve the Wave Park development. Increased use of water, increased
traffic resulting in increased emissions will simply increase the stress on an environment
that is already growing drier and hotter.
Please plan for being responsible and sustainable in the long term.
Suzanne Kahn
56885 Mountain View
La Quinta, CA 92253
Reply Forward
1 of 1 8/6/21, 12:41 PM
Friday, August 6, 2021 at 13:36:25 Pacific Daylight Time
Subject: Re: Coral Mountain Resort DEIR
Date: Friday, August 6, 2021 at 1:35:16 PM Pacific Daylight Time
From: FRANCINE Roy
To: Consulting Planner
Hi,
I am making a correction to my letter. I erroneously referenced the IID ... I meant the
Coachella Valley Water District.
Sorry about that.
Francine Roy
On 08/06/2021 12:54 PM Consulting Planner <consultingplanner@laquintaca.gov> wrote:
Ms. Roy,
Thank you for your comments.
Nicole Sauviat Criste
Consulting Planner
City of La Quinta
From: FRANCINE Roy <fmroy@comcast.net>
Sent: Friday, August 6, 2021 11:01 AM
To: Consulting Planner<ConsultingPlanner@laquintaca.gov>
Subject: Coral Mountain Resort DEIR
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.
Dear Planning Commission,
I am writing this letter to you because I am in a state of shock....
Why would you even CONSIDER changing the current zoning to allow a project
Page 1 of 2
that goes against ALL COMMON SENSE? The residents who purchased homes
near this project site BELIEVED that the "worst case scenario" they would ever
have to deal with was what the current zoning allows: "LOW-DENSITY residential
use, as well as a golf course and some commercial use." The proposed change to
allow "tourist commercial" zoning violates the 2035 general plan for La Quinta.
So, tell me, what was the point of spending all of the time, money and effort to
come up with the 2035 general plan if you were going to be tempted to go against
that plan when a project came along that dangled a couple of million dollars of tax
revenue in front of you that doesn't make any sense on MANY levels! We all
choose to live here because we enjoy the night sky, the quiet, the nature, the
landscape, the small amount of traffic we have, etc. But, the reality of climate
change is that we are all very concerned about how long we will have drinking
water available to us. The IID has asked us all to conserve water and I know I am
doing my share to USE LESS than their recommended amount. This wave park
will require 18,000,000 gallons of DRINKING WATER JUST TO FILL IT UP. This
does not include "topping it off" every day because of evaporation Toss. This does
not sound like "conserving water" to me.
Since I moved here, I have been reading about the issues with Short Term
Rentals. This project is planning on making all 600 homes available as Short Term
Rentals!!!! How can you justify allowing this? At the very least, 600 homes does
not sound like "low density" to me!.
What this beautiful parcel of land needs is a developer who wants to put in some
beautiful energy efficient homes, some hiking and biking trails that WE CAN ALL
ENJOY, maybe a beautiful park with drought tolerant natural landscaping (no golf
course .... there are already too many golf courses that are using up water
resources) and a small commercial area where there could be a market, a cafe, a
restaurant, etc. for the residents that live in that part of La Quinta since it's a drive
just to get groceries.
Please, please realize that this developer is "slick." He seems to have an answer
for everything. The project doesn't make sense for our community nor do I think it
even makes sense for him but that's a different discussion ...
Last but not least, I'm very confident that the City of La Quinta would be "featured"
on the CBS Evening News if this project is approved. I can hear it now ... "City of
La Quinta approves a private wave park project in the midst of a historical drought
and climate change!" Do we really need that kind of negative publicity??? I'd
rather we be admired for spearheading energy-efficient projects and protecting our
decreasing natural resources.
Page 2 of 2
This is not the right place nor the right time for this project.
Respectfully,
Francine Roy
80028 Silver Sage Lane
La Quinta, CA 92253
Page 3 of 2
Friday, August 6, 2021 at 13:44:33 Pacific Daylight Time
Subject: RE: Response to Draft EIR Coral Mountain
Date: Friday, August 6, 2021 at 1:41:59 PM Pacific Daylight Time
From: Cheri Flores
To: Carolyn Winnor
CC: Nicole Criste, Linda Evans, Robert Radi, Kathleen Fitzpatrick, John Pena, Steve Sanchez, Danny
Castro, Jon McMillen
Attachments: image001.png
Hello Ms. Winnor,
Thank you for your comments. They will be included with the materials provided
for the Planning Commission and the City Council when the project is scheduled
for public hearings. Have a wonderful day.
4Q
CALIFORNIA
Cheri L. Flores 1 Planning Manager
City of La Quinta
78495 Calle Tampico La Quinta, CA 92253
Ph. 760-777-7067
www.laquintaca.gov
PLEASE NOTE: City Hall is now open to the public during normal business hours:
Monday through Thursday from 7:30 a.m. to 5:30 p.m. and Friday from 8:00 a.m. to
5:00 p.m. (Counter closes at 4:30 p.m. daily), with the exception of nationally
observed holidays. Please follow all CDC and State recommended guidelines as they
pertain to COVID-19 safety and awareness. All public services continue to be available
via phone, email or online web portal and the public is encouraged to utilize these
services when possible. Thank you.
From: Carolyn Winnor <cwinnor@dc.rr.com>
Sent: Friday, August 6, 2021 1:22 PM
To: Cheri Flores <clflores@laquintaca.gov>
Cc: cdd@la-quinta.org; Linda Evans <Levans@laquintaca.gov>; Robert Radi <Rradi@laquintaca.gov>; Kathleen
Fitzpatrick <kfitzpatrick@laquintaca.gov>; John Pena <jpena@laquintaca.gov>; Steve Sanchez
<ssanchez@laquintaca.gov>
Subject: Response to Draft EIR Coral Mountain
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.
August 6, 2021
Sent VIA Email
Cherri Flores, Planning Manager
clflores@laquintaca.gov
Page 1 of 4
Response to Draft EIR Coral Mountain
Dear Ms. Flores
My name is Carolyn Winnor and my husband and I have lived in Trilogy La Quinta, for 16 years. Moved to La
Quinta after we retired to get away from the congestion of Los Angeles County, having lived in Santa Clarita
for 24 years.
I am strongly Opposed to the rezoning of Coral Mountain from low density residential to Tourist/Commercial.
I have read portions of the DEIR and I believe the City needs to do additional research regarding the Lighting,
Noise and Water Usage that a project of this magnitude requires.
I am sure you are aware of the La Quinta General Plan 2035. Below are some excerpts from the plan and you
may consider my opinions as NIMBY; not sure how they couldn't be, when the developer wants to have the
property rezoned to Tourist/Commercial in the middle of a Low Density Residential area. I understand the
need for the City to look for additional tax dollars, but I think consideration is required on how this will affect
your constituents and even you, if you lived in or near South East La Quinta.
The DEIR considers the items below: Significant and Unavoidable (Executive Summary Page 1-15)
Table 1-3. These are admitted faults that cannot be addressed or mitigated.
4.1 Aesthetics
1. Adverse effect on scenic vistas
2. Degradation to the visual character or quality of the site.
3. Light and Glare
La Quinta General Plan 2035 Land Use
Zoning Consistency To assure consistency and compatibility between the General Plan and the Zoning
Ordinance Table II --2 shows the Zoning districts that correspond to each land use designation.
Tourist Commercial This land use designation is specifically geared to tourism- related land uses, such
as resort hotels, hotels and motels, and resort commercial development, such as conference
centers, restaurants, resort-- supporting retail and services (including day spas and similar personal
services). Time share, fractional ownership or similar projects may also be appropriate in this
designation, with the approval of a Conditional Use Permit.
For this project to be built on the land purchased by Meriwether it will need to be rezoned to Tourist
Commercial. The developments surrounding this land are zoned Low Density Residential. Based on LQ 2035
Land Use, there is no consistency or compatibility between T/C & Low Density Residential.
Lighting Page 4-1-54 Table 4-1-8 PA
The lighting for this project is consistent with commercial property located on Highway 111. Lights left on
during nighttime hours, height, in the Resort 25', Wave Club 25', Farm 40' and Back of House 40'. The only
lights currently addressed that will be on until 10 pm, are the 80' Wave lights. The LQ Municipal Code for
Lighting, pole height 8'. Is this consistent or compatible with Low Density Residential Property? NO. The DEIR
considers, this is significant and unavoidable.
Building Heights Page 4-1-54 Table 4-1-8 PA
The Resort 4 stories at 40', Wave platform 4 stories at 45', Wave Club 3 stories at 40' E &.W Resort Residential
3 stories at 30 ; Farm 3 stories at 40' and Back of House 2 stories at 30'. The LQ Municipal Code 2 stories at
28'. Is this consistent or compatible with Low Density Residential Property? NO. The DEIR considers, this is
significant and unavoidable.
Page 2 of 4
Noise — The DEIR used the dBA recorded at the Kelly Slater Le Moore Wave Pool, not on the proposed
property, next to Coral Mountain. The DEIR states the surface of Coral Mountain is soft and sound will not
travel (totally erroneous). I live in Trilogy, La Quinta and I can hear gun shots from the shooting range near
Lake Cahuilla. On Sunday mornings I can hear the cars on the track at the Thermal Race Track. Sound carries
in the desert and especially during the evenings and at night. I believe the City needs to address how the
sound will carry near Coral Mountain. Not just the sounds that make the Wave, but record the dBa of jet skis,
music at the volume they plan on using, any announcements from loud speakers, etc. I have watched many
videos of Wave Pools and they put music on the videos, or voice overs, people making commentaries but
NEVER do you hear the actual sounds at the Wave Pool and its surroundings. Why?
Appendix K.2 Noise Memo Report Urban Crossroads See Page 76
Table 10-1 Reference Noise Level Measurements.
Please read where and when these noise levels were measured. Why hasn't the noise levels been measured
on the proposed site?
Noise Level Chart:
4/13/2020 Surf Ranch Lemoore, Ca
10/8/2014 Founder's Park in County of Orange
3/16/2005 Westin Hotel Rancho Mirage, CA
4/18/2018 Ramon Commercial Center
See Page. 93-94 9.100.210 La Quinta Municipal Code Non Residential Noise Regulations
The quiet low density residential neighborhoods, will now have to live with NON Residential Noise
standards?
Water Usage — I believe the evaporation of water needs to be addressed by the City, so we will actually know
the water consumption of the Wave. The developer claims Los Angeles is only 2 hours from La Quinta, who
then will be coming to La Quinta during the summer months where the temperature ranges from 110-120
degrees and the lows are between 85-95 degrees at night? Individuals can go surfing at the beach with water
and air temperatures between 65-70, actually closer than 2 hours from Los Angeles. What happens if the fad
of the Wave is over in 3 to 5 years or financially without summer usage the Wave fails? What is La Quinta and
the residents of South East La Quinta left with? Who will be responsible to rehab the land? If this project
goes forward, it will forever change South La Quinta from a quiet residential area to a bustling Tourist area,
with lights 25' to 80' tall, unnecessary water usage, additional traffic, 600 STVR, 150 Hotel Rooms, noise (Jet
skis, music, loudspeakers and alarms) 24/7/365 days a year, not to mention a minimum of 4 Special Events,
did I say additional traffic?
Please listen to the Residents that will be forced to live in this constant festival like environment and say NO
to rezoning the property to Tourist/Commercial.
Thank you,
Carolyn Winnor
81134 Barrel Cactus Rd.
La Quinta, CA 92253
La Quinta Planning Commission E-mail: cdd@la-quinta.org
La Quinta City Council
Linda Evans. Mayor E-mail: levans@laquintaca.gov
Robert Radi, Mayor Pro Tem E-mail: rradi@laquintaca.gov
Kathleen Fitzpatrick, Council Member E-mail: kfitzpatrick@laquintaca.gov
John Pena, Council Member E-mail: jpena@laquintaca.gov
Steve Sanchez, Council Member E-mail: ssanchez@laquintaca.gov
Page 3 of 4
Page 4 of 4
Thursday, August 5, 2021 at 08:54:38 Pacific Daylight Time
Subject: Coral Mountain Resort DEIR
Date: Thursday, August 5, 2021 at 8:47:46 AM Pacific Daylight Time
From: Brian Levy
To: Nicole Criste
To: Ms. Nicole Criste
City of La Quinta - Planning Department
This email is from Brian and Gail Levy - we live in Trilogy at Avenue 60 & Madison. We retired to live here in
2014 to enjoy the beautiful, quiet, and peaceful La Quinta neighborhood in and about Trilogy. We previously
spent many years as part-time Palm Springs vacationers, and have owned property there since 1979. Having
spent decades vacationing in and about Palm Springs, we decided to retire to live in our beautiful and quiet
La Quinta neighborhood. We are vehemently opposed to the proposed wave park for a number of reasons,
which are summarized below:
1: We are living in a critical drought situation while experiencing increasing wildfires. Water for firefighting
and sustaining life is in an increasingly short supply. We believe that building a wave park during an
increasing water shortage while experiencing increasing wildfires is irresponsible and self-serving to the
financial interests of a few, rather than the greater good of the La Quinta community;
2: We believe that the additional noise and added traffic will negatively impact our residential neighborhood
forever. Can our neighborhood tolerate more traffic and noise? Maybe. Is additional traffic and noise from a
commercial resort within our residential community a good idea? NO. Residents frequently walk and bike
ride on Madison between Avenue 60 and the fire department. More traffic from the proposed commercial
wave park is not a good idea for this residential neighborhood. Further, the proposed size of this wave park
in this specific mountain location is unlike any other in existence, and as a result, reliable and predictable
noise patterns hypothecated in the pending DEIR are extremely speculative and therefore unreliable. The
DEIR in and of itself was not well written, and the assumptions utilized were not clearly spelled out;
3: What if the developers are wrong, and the wave park is not a financial success? What if the project
cannot be financially sustained long term, and the wave park shuts down? What then? What will be left
behind will be a blight on our community, and a regretful legacy for this city who valued proposed additional
revenue over quality of life for its residents;
4: When we purchased our home in Trilogy, we intended to spend our retirement living in this community
and enjoying the many benefits that our La Quinta neighborhood has to offer. The approval of the
commercial wave park project will be a permanent change to our residential neighborhood and signal to us
that we should no longer continue to live in La Quinta because La Quinta no longer values the quality of our
lives and this neighborhood. It is our belief that the only good that can come from the commercial wave park
will be the potential financial gain for the developers and investors. This may be a good commercial project
for the investors, but this residential neighborhood is the wrong location for a commercial development such
as this wave park.
Given the variables, the misuse of our precious water resources, and the high financial risks associated with
putting this commercial development in our residential neighborhood, when you consider this proposal,
please ask yourselves the following questions:
What is the legacy that I want to leave for this community?
What is the downside to the community if the project is approved, goes forward, and then fails to pan out
financially?
Does this project represent a wise use and conservation of our dwindling water resources?
Is the high risk associated with this venture worth taking for the city and for the La Quinta residents affected
by this proposed commercial project in a residential neighborhood?
Thank you for your consideration.
Page 1 of 2
Brian & Gail Levy
81214 Santa Rosa Court
La Quinta, CA 92253
Page 2 of 2
August 6, 2021
City of La Quinta
78-945 Calle Tampico
La Quinta, CA 92253
Attn: Ms. Nicole Saviat Criste
Dear Ms. Saviat Criste:
RE: Response to Draft EIR Coral Mountain Resort
I am writing in response to the Draft EIR for the Coral Mountain Resort development. I have
owned a home in La Quinta for 20 years. When my husband and I first built a home in La
Quinta I loved that the city motto was "Gem of the Desert" and "Growth with Charm". You don't
see the "Growth with Charm" anymore and this development certainly flies in the face of that
motto! I have many concerns about the development but I think it must be said that this DEIR
was so long, convoluted and hard to understand it was almost unreadable. The fact that the
entire report was hired and paid for by the developer also presents huge concerns to its validity.
Another concern is that most of the study was completed during COVID which certainly affects
the traffic study and noise to some degree. Here are my concerns:
Lighting — Seventeen 80 foot tall lights surrounding the wave pool will certainly have an effect on
everyone living around this development. Most homes in the neighborhood with mountain views
look towards Coral mountain. What they will see in the future is light poles during the day and
light glow at night. What happened to the Dark Sky ordinance? Well, the City Council voted to
remove the Dark Skies ordinance from the Municipal Code in May, 2021. How convenient! Yet
the people living here say that the night skies are precious part of their community. Ads on the
internet extolling La Quinta's many virtues talk about the Dark Sky ordinance. So much for all
the people who live here and visitors too!
Noise — The noise study found no issues with noise whether it be construction or the operation
of the Wave pool. They studied the noise of traffic (during COVID) and did theoretical studies of
other aspects of the operation. One of their conclusions was that sound would be absorbed by
rock. Really? Since when does rock absorb sound? And if it did, why can I hear hikers near
Coral Mountain when I'm standing on the corner of 58th and Madison? Theoretical studies don't
replicate reality and this area needs real world study.
Traffic — As mentioned before the studies were done during COVID. In my development (Puerta
Azul) none of the Canadians made it to La Quinta in the winter of 2020 which is a significant
number of owners. The rate of COVID in early winter was also very high keeping some
homeowners from coming as well as visitors. I heard a presentation from the developer
admitting that the study may not reflect non COVID traffic amounts but if there are stop lights
needed they would help pay for them. For a light at 58th and Madison, which I can't see NOT
having, they would contribute 10%. If that is correct then the homeowners living around this
PRIVATE development end up paying for a light that wouldn't have been needed. How in the
world is that fair?! This development is in a land locked area with very few roads to get people
to it. Someone needs to really look at what will happen with traffic especially with planned
events of 2500 people. I can think of the traffic jams from the PGA concerts a couple of years
ago as perfect examples of what happens when thousands of people try to squeeze into an
area with few roads. If this were to happen on Madison thousands of people would be unable to
leave their developments. Any emergency vehicle would have trouble reaching any destination
on that route. This needs serious attention.
Water — We are in a serious drought. The entire west coast and beyond is suffering in ways no
one anticipated happening for many years because of Global Warming. The water numbers in
the DEIR are calculated using information from the Lemoore surf park. The climate there is
different from La Quinta, we have many more and hotter days, the proposed pool is bigger than
Lemoore (more area to evaporate) yet no one attempted to extrapolate what that would mean
for water consumption. I heard an engineer at the City Council this week say that the
development was at 99% of their total water allotment. That's not much of a cushion! What
happens if they need more water? And let's be clear: this is drinking water! Someone needs to
look at this carefully.
Bats — No one mentions the bats when they talk about this project but the bat study in the DEIR
says that night time light is the biggest concern for the multiple bat species living on and near
the proposed development site. Light disrupts feeding, roosting, maternity and raising of the
young. The study recommends that all lighting be "dark sky compliant". Does La Quinta care
about this anymore since they removed Dark Sky from Municipal Code? And how compliant can
the custom 80 foot lights be? At that height they will disrupt any creature flying anywhere near
the wave pool. What mitigation can be made for bats, a protected species? Is there really any
reason people need to surf at night? You certainly can't do that at the beach, why should this
be any different?
Zoning — I realize that zoning isn't part of the DEIR but it must be addressed. What homeowner
buys a house where they're researched all things that could impact that important, expensive
decision, only to have something like this happen? How can a homeowner trust their Mayor and
City council to look out for their best interests when a developer comes along with a proposal to
change a swath of land located in the middle of a number of neighborhoods zoned low density,
residential to Commercial, tourist? I don't see another area in La Quinta that is as quiet and
residential as this area. It defies logic why this would be the place to build something like what
is proposed and to allow a zoning change along with it.
I appreciate the time you've taken to read my concerns. I hope that all parties involved in the
decision making will take the time to study the issues, be open minded and see that this
development belongs in another area.
Sincerely,
Nancy Bruce
nbruce@me.com
80843 Calle Azul
La Quinta, CA 92253
Copies to:
Linda Evans. Mayor levans@laquintaca.gov
Robert Radi, Mayor Pro Tem rradi@laquintaca.gov
Kathleen Fitzpatrick, Council Member kfitzpatrick@laquintaca.gov
John Pena, Council Member jpena@laquintaca.gov
Steve Sanchez, Council Member ssanchez@laquintaca.gov
La Quinta Planning Commission cdd@laquintaca.gov
Ms. Cheri Flores, Planning Mgr. cflores@laquintaca.gov
We are 10 year homeowners at Andalusia at Coral Mountain. We enjoy the quiet environment the
southern La Quinta border provides. We are proponents of property rights but wonder if the wave park
is consistent with development of this area of La Quinta.
Alternative uses for the property are well defined in the EIR. We support alternatives (in descending
order of preference):
• Alternative #4 Golf/Resort Hotel
• Alternative #2 No project / Existing Entitlements
• Alternative #3 Reduced density
Additional areas of concern are:
• Traffic — We are concerned event related traffic will overload the corridor resulting in gridlock.
The 4 way stop at Madison and 58th will be overwhelmed during events. The memory of
Ironman l's paralyzing of La Quinta streets is still fresh. Additional access to the property would
provide additional ingress/egress on alternatives to Madison alone.
• Noise — The area is a quiet, serene neighborhood. We are concerned about noise from
equipment required to heat, treat the pool in addition to the wave making machinery.
• Lighting —17 80' towers will create a "ball park" type of illumination immediately adjacent to
the beautiful mountains. We understand the desire for specific light angles but ask
consideration be given to lighting standards of 30' or less to reduce the lighting glare.
• Hours of operation — reduce end time to 8 pm.
• Special events — 4 special events drawing attendees and traffic to La Quinta's southern edge has
the potential to create traffic gridlock.
Dennis & Jackie Miller
58131 Carmona
La Quinta, CA 92253
FINAL ENVIRONMENTAL IMPACT REPORT
Coral Mountain Resort, La Quinta CA
3.0 Revisions to the Draft EIR
Chapter 3.0 Revisions to the Draft EIR
3.1 Purpose
The following provides changes to the Draft EIR being made as a result of the Response to Comments
(Chapter 2.0) of this Final EIR. Typographical errors and other editorial modifications are also provided
below. Please note that deletions are indicated in strikethrough and additions are underlined text.
Location & Page
EIR Preparers, Page i-
3
Revision
The following revision adds a list of agencies and organizations consulted
during the writing of the Draft EIR document. The Draft EIR provided a
list of EIR Preparers after the EIR cover page. The list included the City (as
the Lead Agency), authors of the document, and subconsultants
commissioned to provide their expertise on environmental topics such as
biology, cultural resources, air quality, etc. The list below expands on the
EIR Preparer list in the Draft EIR by including agencies who where
informally or formally contacted, and agencies that responded to the
NOP or commented on the Draft EIR. Page i-3 is revised to state the
following:
"Additional Agencies and Organizations Consulted
Along with a list of EIR prepares, a list of public agencies, organizations
and persons consulted for the EIR is included below, compliant with CEQA
Guidelines Section 15129. The following list includes agencies that were
informally or formally contacted, as well as agencies that responded to
the Notice of Preparation (NOP) or commented on the DEIR (listed in
alphabetical order).
Agua Caliente Band of Cahuilla Indians
Air Resources Board
Augustine Band of Cahuilla Indians
Cabazon Band of Mission Indians
Cahuilla Band of Indians
CAL FIRE
California Department of Fish and Wildlife
CalTrans District #8
Coachella Valley Mountain Conservancy
Colorado River Board
Fish and Game Region #6
Imperial Irrigation District
Los Coyotes Band of Cahuilla and Cupeno Indians
Coral Mountain Resort Final EIR
3-1 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Morongo Band of Mission Indians
Native American Heritage Commission (NAHC)
Public Utilities Commission
Regional WQCB #7
Ramona Band of Cahuilla
Riverside County Airport Land Use Commission (ALUC)
Riverside County Flood Control and Water Conservation District
Samuel A. McLeod, Ph.D. (Vertebrate Paleontology)
Santa Rosa Band of Cahuilla Indians
Soboba Band of Luiseno Indians
South Coast Air Quality Management District (SCAQMD)
Torres -Martinez Desert Cahuilla Indians
Twenty -Nine Palms Band of Mission Indians"
Chapter 3.0, Project The following revision addresses Comment Number 10-c, located in
Description, Page 3-5 Chapter 2.0, Responses to Comments, where CVWD requests that the on
pages 3-5 of the Draft EIR "CVWD Levees" be changed to "USBR Levees".
"South • Avenue 60
• Developed and Undeveloped Single Family Residences
and Communities
• Golf Course, including Trilogy
• Vacant Land
• CVWD Lcvcc USBR Levees"
Chapter 3.0, Project The following revision addresses Comment Number 10-a, located in
Description, Page 3- Chapter 2.0, Response to Comments, where CVWD corrects the
29 Conceptual Water Plan exhibit in the Draft EIR.
"Water and sewer service for the Specific Plan area is provided by the
Coachella Valley Water District (CVWD). The CVWD provides domestic
water from wells. Pursuant to an existing agreement with CVWD, the
project will develop two onsite wells sites, one of which will be equipped
with a well pumping plant as required by CVWD to serve the project. The
project will also drill a private well to provide an additional source of
water for non-domestic (outdoor) purposes. The exact location of the
wells and well sites will be subject to CVWD approval. The project
proposes to connect to the existing water lines located on Avenue 58
(north) and Madison Street (east). The proposed water lines will consist
of 18 -inch, 12 -inch, and 8 -inch public water lines. In accordance with an
existing agreement with CVWD, CVWD also requires an offsite pipeline in
Avenue 60. This is indicated in the Conceptual Water Plan. Sewer lines in
the are currently exist along Avenue 58 and along a portion of Avenue 60
(southeast of the project). The project proposes 15 -inch, 12 -inch, and 8 -
Coral Mountain Resort Final EIR
3-2 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Chapter 3.0, Project
Description, Page 3-
30 (Exhibit 3-11)
Section 4.1,
Aesthetics, Page 4.1-
8
inch sewer lines that will connect to the existing sewer lines and provide
sewer service to the project. The project will be required to conform to
the requirements of the CVWD's programs and standards pertaining to
water management and conservation."
Please see the updated Conceptual Water Plan exhibit below to replace
Exhibit 3-11 in the Draft EIR, per CVWD's comment (Comment Letter No.
10 in Chapter 2.0 of this Final EIR.
Revisions to page 4.1-8 of Section 4.1, Aesthetics, is indicated in the table
below. This revision corrects Table 4.1-1, Development Standards
Planning Area 1, in the Draft EIR, which states that the maximum pole
height in Planning Area I would be 25 feet. The pole height has been
lowered to the maximum allowed under LQMC Section 9.100.150 of 18
feet. The table below indicates this change.
Table 4.1-1 Development Standards Planning Area 1
Neighborhood Commercial
Project Max/Min
Max. Structure Height
35 ft1,2
Max. No. of Stories
2
Min. Front Setback
10 ft
Min. Rear Setback
10 ft
Min. Parking
1/250 ft GFA.
Max. Building Floor Area in PA I
60,000 SF
Min. Building Setback to Avenue 58
25 ft
Min. Building Setback to Madison Street
25 ft
Min. Setback from Interior Property Line3
0 ft
Min. Building/Landscape Setback from Residential PA4
40 ft/20 ft
Max. Wall Height
6 ft
Max. Light Pole Height
2-5 18 ft
Min. Parking Provided
Per Code
Min. Parking Dimension
9' X 19'
Min. Bicycle Parking
Per Code
Min. Golf Cart / NEV Parking
Per Code
Min. Electric Vehicle Charging Spaces
Per Code
Notes:
1. Height is limited to 22' within 150' of the Madison & Avenue 58 R.O.W.
2. Architectural and roof projections, such as chimneys, spires, finials and similar features not
providing habitable or otherwise unusable space shall be permitted to extend up to fifteen feet
above the maximum structure height.
3. Mechanical equipment to have a minimum 3 -foot setback from interior property lines.
4. Landscape setback occurs within the building setback.
6. 25 % of Planning Area I is 1.9 acres (7.7 acres x 25%). The property proposes a building floor area
of 60,000 square feet, which is approximately 1.4 acres of the site.
Coral Mountain Resort Final EIR
3-3 February 2022
3.0 REVISIONS TO THE DRAFT EIR
7. Five bicycle parking spaces for each tenant having over twenty thousand square feet of gross
floor area.
Section 4.1, Revisions to page 4.1-52 of Section 4.1, Aesthetics, is indicated in the
Aesthetics, Page 4.1- table below. This revision corrects Table 4.1-7, PA 1 Development
52 Standards Comparison, in the Draft EIR, which, like Table 4.1-1
addressed above, states that the maximum pole height in Planning Area
I would be 25 feet. The pole height has been lowered to the maximum
allowed under LQMC Section 9.100.150 of 18 feet. The table below
indicates this change. Additionally, Section 9.100.150 of the Municipal
Code allows 18 -foot light poles in parking lots. This is indicated in
footnote 5.
Table 4.1-7 PA 1 Development Standards Comparison
Neighborhood Commercial
Project Max/Min
Municpal Codes
Max. Structure Height
35 ft1,2
35
Max. No. of Stories
2
2
Min. Front Setback
10 ft
10 ft
Min. Rear Setback
10 ft
10 ft
Min. Parking
1/250 ft GFA.
1/250 ft GFA
Max. Building Floor Area in PA I
60,000 SF
25 %6
Min. Building Setback to Avenue 58
25 ft
30 ft
Min. Building Setback to Madison Street
25 ft
30 ft
Min. Setback from Interior Property Line3
0 ft
0 ft
Min. Building/Landscape Setback from Residential PA4
40 ft/20 ft
40 ft/20 ft
Max. Wall Height
6 ft
6 ft
Max. Light Pole Height
2 18 ft
8 18 ft
Min. Parking Provided
Per Code
1 space per 300 sq
Min. Parking Dimension
9' X 19'
Min. Bicycle Parking
Per Code
Five Bike Parking'
Min. Golf Cart / NEV Parking
Per Code
2
Min. Electric Vehicle Charging Spaces
Per Code
2
Notes:
1. Height is limited to 22' within 150' of the Madison & Avenue 58 R.O.W.
2. Architectural and roof projections, such as chimneys, spires, finials and similar features not providing habitable or
otherwise unusable space shall be permitted to extend up to fifteen feet above the maximum structure height.
3. Mechanical equipment to have a minimum 3- foot setback from interior property lines.
4. Landscape setback occurs within the building setback.
5. This column compares the project's proposed development standards in PA I, compared to the development
standards in CN Zones as established in Section 9.90.040 (Table 9-6) of the La Quinta Municipal Code. Section
9.100.150 of the La Quinta Municipal Code allows 18 -foot light poles in parking lots in Neighborhood Commercial
zones.
6. 25 % of Planning Area I is 1.9 acres (7.7 acres x 25%). The property proposes a building floor area of 60,000 square
feet, which is approximately 1.4 acres of the site.
7. Five bicycle parking spaces for each tenant having over twenty thousand square feet of gross floor area.
Coral Mountain Resort Final EIR
3-4 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Section 4.2, Air The page numbers provided in Section 4.2, Air Quality, of the Draft EIR
Quality were incorrectly indicated as "4.1-X" instead of "4.2-X" in the document
when published for public review. The pages with Section 4.2, should
have been indicated as "4.2-X". The revision addresses Comment
Number 34-f, located in Chapter 2.0, Response to Comments, in the Final
EIR.
Section 4.3
Biological Resources,
Page 4.3-8
Section 4.3
Biological Resources,
Page 4.3-15
Revisions to page 4.3-8 of Section 4.3, Biological Resources, is indicated
by the text below. This revision is in response to Comment Letter No. 13
from the CDFW (Comment 13-f).
"No take of the Peninsular bighorn sheep is allowed because the species
is a federally endangered species and a California Fully Protected
Species."
Revisions to page 4.3-15 of Section 4.3, Biological Resources, is indicated
by the text below. This revision is in response to Comment Letter No. 13
from the CDFW (Comment 13-g).
"Peninsular bighorn sheep (Ovis canadensis nelsonii) (peninsula Distinct
Population Segment): This species occurs on open desert slopes below
1,220 meters (4,000 feet) elevation from San Gorgonio Pass south into
Mexico. Optimal habitats include steep -walled canyons and ridges
bisected by rocky or sandy washes, with available water. Thi spcc ^�
This species
is not present on the development portion of the site due to the absence
of suitable habitat. While a small portion of the project site includes the
northeastern most edge of Coral Mountain and PBS have been tracked
by monitoring devices on Coral Mountain itself, no development
activities of any kind are proposed or allowed on that portion of the
property, which will be separated from all development by an 8 -foot -high
sheep barrier. While the proposed project development does not occur
in or adjacent to the CVMSHCP designated conservation area for PBS,
Coral Mountain and other adjacent BLM land were identified as Essential
Habitat for the PBS in the USFW Recovery Plan (2000) that preceded the
CVMSHCP. To avoid any impacts to this essential habitat, and because
the sheep are known to travel outside the designated Conservation Area
for sources of forage and water, the project will comply with the
Adjacency Guidelines relating to PBS."
Coral Mountain Resort Final EIR
3-5 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Section 4.3
Biological Resources,
Page 4.3-16
Section 4.3
Biological Resources,
Page 4.3-18
Revisions to page 4.3-16 of Section 4.3, Biological Resources, is indicated
by the text below. This revision is in response to Comment 13-m in
Comment Letter No. 13 from the CDFW. The revision explains the
reasoning for the inclusion of Mitigation Measures BIO -9 and BIO -10,
included at the request of the CDFW.
"Seven federally/state listed species were identified as having the
potential to occur in the project vicinity. These include the Coachella
Valley milkvetch, triple -ribbed milkvetch, Casey's June beetle, desert
pupfish, desert slender salamander, Coachella Valley fringe -toed lizard
and the Peninsular bighorn sheep (PBS). As previously stated, the project
does not provide suitable habitat for PBS, however, monitoring devices
tracked PBS on Coral Mountain (not within the project boundaries). To
ensure that PBS do not enter the project site, an 8 -foot high sheep barrier
is proposed. In addition to the sheep barrier, the onsite lakes will be
designed and maintained to reduce the breeding of vector species. This
is required by Mitigation Measures BIO -9 below. The project also
proposes the implementation of Mitigation Measure BIO -10 which
requires the project educate the public of bighorn sheep habitat and
ecology, threats to PBS and how recovery actions will reduce these
threats. The development of the sheep barrier and the implementation
of Mitigation Measures BIO -9 and BIO -10 will reduce threats to PBS to
less than significant levels."
Revisions to page 4.3-18 of Section 4.3, Biological Resources, is indicated
by the text below. This revision includes additional mitigation prepared
in coordination with the project's biologist.
"The project site contains suitable roosting and foraging habitat for
multiple bat species. Native and non-native ornamental palms on and
surrounding the project site could provide suitable roosting habitat for
bats, including the western yellow bat. Roosting habitat suitable for use
as maternity roosts, which are native wildlife nursery sites, is also present
in rock outcrops associated with the portions of Coral Mountain that is
situated within and adjacent to the project site. Locations of suitable
roosting habitats are illustrated in Exhibit 4.3-1. In April 2021, a nighttime
acoustic and emergence survey was conducted by LSA as part of a larger
focused bat survey effort. The nighttime survey included a combination
of acoustic and exit count methods and took place during the early phase
of the bat maternity season (March 15—August 31 in the Coachella Valley)
to enable detection of maternity -roosting bats. However, not all bat
species are fully aggregated in their maternity roost sites in April, when
the initial survey was conducted. Therefore, to avoid impacts to all
potential bat species which may occur on the site, additional maternity -
Coral Mountain Resort Final EIR
3-6 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Section 4.3
Biological Resources,
Page 4.3-21
season surveys will be performed in June 2021 to maximize the
probability of detection of maternity roosts for all bat species, as
provided in Mitigation Measure BIO -2. If maternity roosts are identified
within the project area, a significant impact would occur. To reduce these
impacts to less than significant levels, Mitigation Measure BIO -3, BIO -4,
BIO -5, and BIO -8 are provided below. They require that the biologist
coordinate with the California Department of Fish and Wildlife (CDFW)
to implement avoidance measures during the bat maternity season in
accordance with CDFW's established standards. No construction will
occur within a 300 -foot buffer of maternity roost sites during the bat
maternity season unless concurrence is received from CDFW to reduce
that buffer distance based upon the bat species present and the activities
occurring. In addition to roosting habitat, foraging habitat supporting
multiple bat species was identified onsite. Therefore, Mitigation
Measure BIO -8 requires that existing native vegetation, particularly palo
verde trees, will be retained where feasible. Landscaping shall include
native desert species. With implementation of Mitigation Measure BIO -
2 through BIO -5 and BIO -8 impacts to roosting bats will be reduced to
less than significant levels."
Revisions to page 4.3-21 of Section 4.3, Biological Resources, is indicated
by the text below. This revision, located in discussion e/f, explains further
the project's consistency with the CVMSHCP Land Use Adjacency
Guidelines. Threshold discussion e/f analyzes whether the project
conflicts with any local policies or ordinances protecting biological
resources, such as a tree preservation policy or ordinance, or conflict
with the provisions of an adopted Habitat Conservation Plan, Natural
Community Conservation Plan, or other approved local, regional, or state
habitat conservation plan.
"The project site's native vegetation consists of desert saltbush scrub,
tamarisk scrub, and mesquite hummock. There is a stand of blue palo
verde in the eastern portion of the project site. The removal of this
vegetation and trees as the result of the proposed project will not conflict
with any local policy relating to these species, because the City does not
have a tree preservation policy or ordinance that protects any of these
species. The project lies within the boundary of the CVMSHCP which
outlines policies for conservation habitats and natural communities and
is implemented by the City of La Quinta, and establishes no policies
applicable to the removal of these species of trees and habitat, except
that the project will be required to pay the CVMSHCP mitigation fee to
mitigate the loss of habitat for covered species in the Coachella Valley.
Compliance with the CVMSHCP also requires compliance with the Land
Use Adjacency Guidelines specified in Section 4.5 of the Plan. The
Coral Mountain Resort Final EIR
3-7 February 2022
3.0 REVISIONS TO THE DRAFT EIR
CVMSHCP defines "adjacent" as "sharing a common boundary with any
parcel in a Conservation Area" (see page 4.176 of Plan). No part of the
project satisfies this definition because the project is located
approximately 0.62 miles to the east of the nearest designated
Conservation Area. Although the project is not located adjacent to a
conservation area, and consistent with the identified presence of PBS on
Coral Mountain, the project will comply with all provisions of those
Guidelines for all areas adjacent to Coral Mountain or other BLM open
space, and this requirement is being made enforceable through the
project Development Agreement.
As stated on page ES -12 of the CVMSHCP, 'jt)he purpose of the Land Use
Adjacency Guidelines is to avoid or minimize indirect effects from
Development adjacent to or within the Conservation Areas. Such indirect
effects are commonly referred to as edge effects, and may include noise,
lighting, drainage, intrusion of people into the adjacent Conservation
Area, and the introduction of non-native plants and non-native predators
such as dogs and cats.'
Here, all project lighting will be required to be shielded and directed to
avoid light spillage onto Coral Mountain (see Mitigation Measure BIO -4).
In addition, the lighting system analysis conducted for the project
demonstrates that there will be no light spillage outside the Wave Basin
planning area, including toward Coral Mountain or other BLM open
space. The lighting system analysis determined that light levels would
drop to 0.01 foot candles or below at least 375 feet from the nearest
portion of Coral Mountain.
The Draft EIR analyzed potential construction and operational noise
impacts. As explained on pages 4.11-32 - 4.11-35 in Section 4.11, Noise,
construction noise can range from approximately 68 dBA to in excess of
80 dBA when measured at 50 feet from the source, with a reduction of 6
dBA for every doubling of distance. The closest project construction to
Coral Mountain will be the Wave Basin, and the highest projected noise
level is 76.5 dBA (see Table 4.11-15, Phase 1 Construction Equipment
Noise Level Summary). Therefore, when considering the noise
attenuation resulting from distance, construction noise will not exceed
75 dBA at 100 feet from the location of construction activities. The
closest any construction activity will be to Coral Mountain is
approximately 100 feet at the northwest corner of the project site. Based
on the configuration of the project site, most construction activity will be
located at least 300-400 feet from Coral Mountain. Although the DEIR
demonstrates that noise levels during construction will also be below this
threshold, in order to assure that no impact to wildlife utilizing Coral
Mountain occurs during the construction period, Mitigation Measure
BIO -7 is included. BIO -7 requires noise monitoring to occur for all
Coral Mountain Resort Final EIR
3-8 February 2022
3.0 REVISIONS TO THE DRAFT EIR
construction activities using heavy equipment within 150 feet of the base
of Coral Mountain. The highest projected operational noise levels is 64.5
dBA at location P-10 in the tourist commercial portion of the site next to
the hotel and Wave Basin (see Table 4.11-25, Daytime Project
Operational Noise Levels and Exhibit 4.11-2, Noise Source and Receiver
Locations). Accordingly, the project will not exceed the CVMSHCP Land
Use Adjacency Guidelines for noise levels at Coral Mountain.
The Land Use Adjacency Guidelines also prohibit planting invasive, non-
native plant species in and adjacent to Conservation Areas, and include
tables of recommended and prohibited species (see CVMSHCP p. 4-177
and Tables 4-112 and 4-113). Section 2.5.2 has been added to the Specific
Plan to prohibit all species listed on Table 4-113 in all portions of the
project adjacent to Coral Mountain and the other BLM open space (see
Specific Plan pp. 35-36 and Figure 13). This requirement will be made
enforceable through the project Development Agreement and will be
enforceable for the life of the project through the Covenants, Conditions
& Restrictions (CC&Rs) that will be recorded against all portions of the
project site that are subject to the plant palette restrictions.
Finally, Section 4.5.6 of the Land Use Adjacency Guidelines requires the
incorporation of barriers to minimize unauthorized public access,
domestic animal predation, illegal trespass, and dumping in a
Conservation Area. The Specific Plan has been revised to expressly
include a protective sheep barrier which complies to the requirements
for PBS barriers in the CVMSHCP along the western boundary (covering
all areas adjacent to Coral Mountain and other BLM open space
property). The protective sheep barrier will be 8 -feet high, with the final
design and location subject to City approval in consultation with CDFW.
With the foregoing, the project will be consistent with the guidelines in
the CVMSHCP and avoid any impacts to PBS or any designated PBS
conservation areas or essential habitat. The project will also pay the
CVMSHCP fee, and implement avoidance and minimization measures,
design features, as well as mitigation measures to ensure compliance
with the CVMSHCP. Impacts will be less than significant.
There are no other local, regional, or state habitat conservation plans
currently in place other than the CVMSHCP that are applicable to the
proposed project. Therefore, the project will have no impacts on local
policies or ordinances protecting biological resources, or with the
provisions of an adopted Habitat Conservation Plan, Natural Community
Conservation Plan, or other approved local, regional, or state habitat
conservation plan."
Coral Mountain Resort Final EIR
3-9 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Section 4.3
Biological Resources,
Pages 4.3-22 to 24
Revisions to the Mitigation Measures provided in Section 4.3, Biological
Resources, were amended to address comments received by public
agencies in coordination with the project's biologist. Revisions to the
Mitigation Measures are provided below:
"BIO -1: A bBurrowing owl cl arance surveys shall be performed by a
qualified biologist approved by the City not more than 30 days prior to
any site disturbance activities _ _ _ :, .. _ :, _ _ _ . A
minimum of two surveys, occurring at least three weeks apart, shall be
completed in advance of any site disturbance activities. If disturbance
activities are expected to start during the burrowing owl breeding
season, three surveys shall be completed. The final burrowing owl survey
shall be completed within three days prior to initiation of any site
disturbance activities. The pre -construction survey shall be conducted
following accepted protocol and the requirements specified in the
CVMSHCP (see pp. 4-168 & 4-169). is required to use accepted protocol
(as determined CDFW). Prior to construction, a qualified biologist will
survey the construction area and an area up to 500 feet outside the
project limits for burrows that could be used by burrowing owls. If the
burrow is determined to be occupied, the burrow will be flagged, and a
160 -foot diameter buffer will be established during non -breeding season
or a 250 -foot diameter buffer during the breeding season. The buffer
area will be staked and flagged. No development activities will be
permitted within the buffer until the young are no longer dependent on
the burrow and have left the burrow.
If the burrow is found to be unoccupied, the burrow will be made
inaccessible to owls, and construction may proceed. If either a nesting or
escape burrow is occupied, owls shall be relocated pursuant to accepted
Wildlife Agency protocols. Determination of the appropriate method of
relocation, such as eviction/passive relocation or active relocation, shall
be based on the specific site conditions (e.g., distance to nearest suitable
habitat and presence of burrows within that habitat) in coordination with
the Wildlife Agencies.that, based on surveys conducted following protocol, at least one
burrowing owl has been observed occupying a burrow on site during the
past three y ars. If there arc no records for the site, surveys must bo
conducted to determine, prior to construction, if burrowing owls aro
present. Determination of the appropriate method of relocation, such as
eviction/passive relocation or active relocation, shall be based on the
specific site conditions (e.g., distance to n crest suitable habitat and
presence of burrows within that habitat) in coordination with the Wildlife
Agencies. Active relocation and eviction/passive relocation require the
preservation and maintenance of suitable burrowing owl habitat
Coral Mountain Resort Final EIR
3-10 February 2022
3.0 REVISIONS TO THE DRAFT EIR
determined through coordination with the Wildlife Agencies. If
burrowing owls are observed within the Project site during construction
activities, CDFW shall be notified immediately and provided with
proposed avoidance and minimization measures, consistent with the
requirements of the CVMSHCP.
BIO -4:
occupied bat roosts were identified during the April 2021 surveys, bats
project related light overspill. To avoid permanent impacts to roosting
bats from the installation of new light fixtures associated with the
proposed development, all lighting fixtures shall have light shields or
similar devices (e.g., dark sky compliant lighting) installed to ensure that
there is no minimize light trespass overspill on -to Coral Mountain and
surrounding open space. A supplemental light study will be performed to
collect nighttime lighting measurements and confirm that no light
trespass onto Coral Mountain is occurring; this will be submitted for City
approval prior to issuance of any permit for occupancy or use of the
Wave Basin.
BIO -6: To ensure compliance with California Fish and Game Code and the
Migratory Bird Treaty Act (MBTA) and to avoid potential impacts to
nesting birds, vegetation removal and ground -disturbing activities shall
be conducted outside the general bird nesting season (January 15
through August 311. Any vegetation removal, ground disturbance,
and/or construction activities that occur during the nesting season will
require that all suitable habitats be thoroughly surveyed for the presence
of nesting birds by a qualified biologist that is pre -approved by the CDFW.
Prior to commencement of clearing, a qualified biologist shall conduct
preconstruction surveys within 14 days and repeated 3 days prior to
ground -disturbing activities. If any active nests are detected a buffer of
300 feet (500 feet for raptors) around the nest adjacent to construction
will be delineated, flagged, and avoided until the nesting cycle is
complete. During construction activities, the qualified biologist shall
continue biological monitoring activities at a frequency recommended by
the qualified biologist using his or her best professional judgment, or as
otherwise directed by the Wildlife Agencies. If nesting birds are detected,
avoidance and minimization measures may be adjusted and construction
activities stopped or redirected by the qualified biologist using their best
professional judgment as otherwise directed by the Wildlife Agencies to
avoid Take of nesting birds. The buffer may be modified and/or other
recommendations proposed as determined appropriate by the biologist
to minimize impacts.
Coral Mountain Resort Final EIR
3-11 February 2022
3.0 REVISIONS TO THE DRAFT EIR
BIO -7: To ensure that the project will avoid any significant construction
noise impacts on wildlife using Coral Mountain, noise monitoring will
occur for all construction activities using heavy equipment within 150
feet of the base of Coral Mountain. If noise levels exceed 75 dBA,
construction operational changes or other project modifications shall be
made, as directed by the project biologist to reduce the noise levels at
Coral Mountain to below 75 dBA.
BIO -8: Existing native vegetation, particularly palo verde trees, will be
retained where feasible. Landscaping shall include native desert species.
BIO -9: Onsite lakes will be designed and constructed by industry
professionals and will incorporate proper aeration, circulation and
filtration to maintain a balanced lake ecosystem. Lakes will be stocked
with beneficial fish and plant species. Limited chemical applications will
be utilized as necessary. Ongoing maintenance will ensure that onsite
lakes function properly to control any invasive species or other nuisance
conditions.
BIO -10: An educational program about the Peninsular bighorn sheep and
their associated habitat shall be implemented and maintained
throughout the resort, open space, and low-density community
programs through the use of signage, pamphlets, and staff education.
The Education Program should inform the reason of why specific
measures are being taken to support recovery of Peninsular bighorn
sheep. The Education Program should include the ecology of Peninsular
bighorn sheep, what threats this species is currently facing, and how
recovery actions will reduce these threats. This includes information that
explains: (1) why restrictions on toxic plants, fences, and pesticides are
needed; (2) how artificial feeding of coyotes could adversely affect
bighorn sheep; and (3) how recreational activities may affect sheep. The
use of interpretive signs is encouraged."
Section 4.10, Land Revisions to Section 4.10, Land Use and Planning, were amended to
Use and Planning, address comments received by the California Department of Fish and
Page 4.10-30 Wildlife (CDFW) to address Comment 13-e indicated in Chapter 2.0,
Comment Letters and Responses. The following discussion will be located
under threshold topic discussion b, which asks whether the project will
cause a significant environmental impact due to a conflict with any land
use plan, policy, or regulation adopted for the purpose of avoiding or
mitigating an environmental effect.
"CVMSHCP Consistency
Coral Mountain Resort Final EIR
3-12 February 2022
3.0 REVISIONS TO THE DRAFT EIR
A Biological Resources Assessment and Coachella Valley Multiple Species
Habitat Conservation Plan (CVMSHCP) Consistency Analysis ("Biology
Report") was completed for the project site by LSA Associates, Inc. in May
2021 (updated November 2021). The Biology Report (Appendix D.1 and
D.4) included a review of the Final Recirculated CVMSHCP (CVAG 2016)
to determine CVMSHCP consistency and conservation measures that
apply to the proposed project (see page 4.3-21 of this Draft EIR). The
consistency analysis conducted by LSA Associates concluded that the
project is consistent with the CVMSHCP because the project is not
located in any conservation area, will pay the CVMSHCP development
fee, and will not remove trees or habitat that are subject to any
CVMSHCP conservation policies.
The project area is located in the portion of the CVMSHCP plan area
designated for future development, rather than conservation, and this
site was approved for development by the County of Riverside nearly 20
years ago, prior to the property being annexed into the City of La Quinta.
As a result, the project is required to pay the CVMSHCP impact fee, which
has been adopted by the City of La Quinta to help fund CVCC's acquisition
of additional high-quality habitat within the conservation areas
designated in the CVMSHCP.
The project is also required to implement all applicable avoidance and
minimization measures set forth in Section 4.4 of the CVMSHCP. As
described in the Draft EIR (see Mitigation Measure BIO -1), the project is
required to conduct burrowing owl surveys in accordance with the
protocols set forth in Section 4.4 of the CVMSHCP (see pp. 4-166 — 4-167).
Section 4.4 also prohibits construction activities within the Peninsular
bighorn sheep (PBS) conservation area during the lambing season, but as
the project site is located outside of the designated conservation areas,
this provision is inapplicable.
Compliance with the CVMSHCP also requires compliance with the Land
Use Adjacency Guidelines specified in Section 4.5 of the Plan. The
CVMSHCP defines "adjacent" as "sharing a common boundary with any
parcel in a Conservation Area" (see p. 4-176). No part of the Project
satisfies this definition because the Project is located approximately 0.62
miles to the east of the nearest designated Conservation Area (see Figure
4-26(b) in the CVMSHCP). Although the project site is not located
adjacent to a conservation area, and consistent with the identified
presence of PBS on Coral Mountain, as described in Section 4.3,
Biological Resources, the project will comply with all provisions of the
CVMSHCP Guidelines for all areas adjacent to Coral Mountain or other
BLM open space. This requirement is being made enforceable through
the project Development Agreement.
Coral Mountain Resort Final EIR
3-13 February 2022
3.0 REVISIONS TO THE DRAFT EIR
As stated on page ES -12 of the CVMSHCP, "[t]he purpose of the Land Use
Adjacency Guidelines is to avoid or minimize indirect effects from
Development adjacent to or within the Conservation Areas. Such indirect
effects are commonly referred to as edge effects, and may include noise,
lighting, drainage, intrusion of people into the adjacent Conservation
Area, and the introduction of non-native plants and non-native predators
such as dogs and cats."
Here, all project lighting will be required to be shielded and directed to
avoid light spillage onto Coral Mountain (see Mitigation Measure BIO -4).
In addition, the lighting system analysis conducted for the project
demonstrates that there will be no light spillage outside the Wave Basin
planning area, including toward Coral Mountain or other BLM open
space. The lighting system analysis determined that light levels will drop
to 0.01 foot candles or below at least 375 feet from the nearest portion
of Coral Mountain.
The Draft EIR analyzed potential construction and operational noise
impacts. As explained on pages 4.11-32 - 4.11-35 in Section 4.11, Noise,
construction noise can range from approximately 68 dBA to in excess of
80 dBA when measured at 50 feet from the source, with a reduction of 6
dBA for every doubling of distance. The closest project construction to
Coral Mountain will be the Wave Basin, and the highest projected noise
level is 76.5 dBA (see Table 4.11-15, Phase 1 Construction Equipment
Noise Level Summary). Therefore, when considering the noise
attenuation resulting from distance, construction noise will not exceed
75 dBA at 100 feet from the location of construction activities. The
closest any construction activity will be to Coral Mountain is
approximately 100 feet at the northwest corner of the project site. Based
on the configuration of the project site, most construction activity will be
located at least 300-400 feet from Coral Mountain. The highest
projected operational noise levels is 64.5 dBA at location P-10 in the
tourist commercial portion of the site next to the hotel and Wave Basin
(see Table 4.11-25, Daytime Project Operational Noise Levels and
Exhibit 4.11-2, Noise Source and Receiver Locations). Accordingly, the
Project will not exceed the CVMSHCP Land Use Adjacency Guidelines for
noise levels at Coral Mountain.
The Land Use Adjacency Guidelines also prohibit planting invasive, non-
native plant species in and adjacent to Conservation Areas, and includes
tables of recommended and prohibited species (see CVMSHCP p. 4-177
and Tables 4-112 and 4-113). Section 2.5.2 has been added to the
Specific Plan to prohibit all species listed on Table 4-113 in all portions of
the project adjacent to Coral Mountain and the other BLM open space
(see Specific Plan pp. 35-36 and Figure 13). This requirement will be
Coral Mountain Resort Final EIR
3-14 February 2022
3.0 REVISIONS TO THE DRAFT EIR
made enforceable through the project Development Agreement and will
be enforceable for the life of the project through the Covenants,
Conditions & Restrictions (CC&Rs) that will be recorded against the
project site.
Finally, Section 4.5.6 of the Land Use Adjacency Guidelines requires the
incorporation of barriers to minimize unauthorized public access,
domestic animal predation, illegal trespass, and dumping in a
Conservation Area. The Specific Plan has been revised to expressly
include a protective sheep barrier which complies to the requirements
for PBS barriers in the CVMSHCP along the western boundary (covering
all areas adjacent to Coral Mountain and other BLM open space
property). The protective sheep barrier will be 8 -feet high, with the final
design and location subject to City approval in consultation with CDFW.
Based on the consistency analysis provided above, the project will be
consistent with the guidelines in the CVMSHCP. The Specific Plan will
establish design components that address project -related edge effects,
such as prohibiting the planting of invasive, non-native plant species, and
the implementation of a protective sheep barrier. The project will also
pay the CVMSHCP fee, as well as implement avoidance and minimization
measures and mitigation measures to ensure compliance with the
CVMSHCP. Impacts will be less than significant."
Section 4.10, Land In response to the Southern California Association of Government's
Use and Planning, (SCAG) comment letter (Comment Letter No. 4) and correspondence
Page 4.10-30 between SCAG and the City, Table 4.10-8, SCAG Connect SOCAL Goals
Consistency Analysis, is to be included in Section 4.10, Land Use and
Planning, on page 4.10-30 of the Draft EIR. The addition shall be included
as follows:
"SCAG Connect SOCAL Goals Consistency Analysis
The Southern California Association of Governments (SCAG) developed
the Connect SoCal planning document through a four-year process to
provide land use and transportation strategies to increase mobility
options and achieve a more sustainable growth pattern. Connect SoCal,
also known as the 2020-2045 Regional Transportation Plan/Sustainable
Communities Strategy (RTC/SCS), was adopted in September 2020 by the
SCAG Regional Council. Connect SoCal established goals intended to
provide guidance for governing bodies considering proposed projects
within the Southern California Region. Analysis discussion regarding the
proposed project's consistency, non -consistency, or non -applicability to
SCAG's Connect SoCal goals, is detailed in Table 4.10-8, SCAG Connect
SoCal Goals Consistency Analysis, below. Per Table 4.10-8, the project
Coral Mountain Resort Final EIR
3-15 February 2022
3.0 REVISIONS TO THE DRAFT EIR
will be consistent with the applicable Connect SoCal goals. Less than
significant impact.
Table 4.10-8 SCAG Connect SoCal Goals Consistency Analysis
SCAG Goals
Consistency Analysis
Goal #1: Encourage regional
Consistent: Page 3-8 of the DEIR lists the objectives of the
economic prosperity and global
proposed project, where one objective states that the project
competitiveness.
strives to "create a private resort community with a variety
of interrelated and mutually supportive commercial and
recreational land uses that will also generate transient
occupancy and sales tax revenues in order to enhance the
City's economic base and long-term financial stability."
Another objective states that the project will "develop a high-
quality private Wave Basin that provides unique recreational
opportunities for future residents of the project, and that
attracts resort guests and creates a landmark facility that will
enhance the City's reputation as the 'Gem of the Desert'."
The City of La Quinta, as well as other Coachella Valley cities,
caters not only to full time residents, but also to seasonal
residents and resort guests. La Quinta is characterized as a
desirable resort destination, as it includes resort/hotel
facilities and recreational amenities within the City's
boundary. The proposed project will encourage regional
economic prosperity by offering a world-class recreational
facility (Wave Basin) that will attract visitors who want to
experience the artificial surf basin. The project will also host
up to four special events per year at the Wave Basin, bringing
up to 2,500 people to the project site each event.
As stated on page 4.10-16 of the DEIR, the project proposes
tourist commercial land uses consisting of a recreational
facility and hotel to promote the continued growth of the
tourism and resort industries in La Quinta by providing resort,
recreational, commercial, and residential land uses on the
project site. Additionally, the residential uses will
incrementally increase demand for commercial goods and
services in the region, thus enhancing the economy. The
resort facility and Wave Basin will encourage regional
economic prosperity by attracting people to the high-quality
facility and resort, and global competitiveness by providing a
facility that features technology designed to re-create ocean
waves for recreational surfing.
Coral Mountain Resort Final EIR
3-16
February 2022
3.0 REVISIONS TO THE DRAFT EIR
Goal #2: Improve mobility,
Consistent: The project includes both neighborhood
accessibility, reliability and travel
commercial and tourist commercial land uses in an area that
safety for people and goods.
is surrounded by residential communities. Additionally, the
project proposes residential dwelling units, and open space
recreational areas. As stated on page 4.13-54 of the Draft EIR,
the placement of 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. Moreover, the project includes
improved design elements to enhance walkability and
connectivity. Recognized 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
provides 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 minimizes barriers to pedestrian access and
interconnectivity. The project includes sidewalk connections,
particularly to / from the retail areas resulting in interaction
with residential and resort uses on-site.
As stated in Section 4.10 of the Draft EIR (page 4.10-17), the
implementation of the Tourist Commercial land use
designation and the associated development of a
recreational facility and hotel will promote the continued
growth of the tourism and resort industries in La Quinta by
providing resort, recreational, commercial, and residential
land uses on the 386 -acre property. Additionally, the
residential uses will incrementally increase demand for
commercial goods and services in the region, thus enhancing
the economy.
Goal #3: Enhance the
Consistent: This Goal is not necessarily applicable to the
preservation, security, and
proposed project since it focuses on the regional
resilience of the regional
transportation system. However, the project site supports
transportation system.
the regional transportation system because it will generate
substantial TUMF fees to fund regional transportation
improvements. As stated on page 4.13-6 of the DEIR, the
Coachella Valley Association of Governments (CVAG)
administers the Coachella Valley Regional Program, which
allocates Measure A and Transportation Uniform Mitigation
Fee (TUMF) funds for necessary improvements to the
Coral Mountain Resort Final EIR
3-17
February 2022
3.0 REVISIONS TO THE DRAFT EIR
Coral Mountain Resort Final EIR
3-18
February 2022
regional transportation system. Page 4.13-47 states that the
project will be required to pay TUMF fees in place at the time
that building permits are sought. The payment of the TUMF
fees is provided as Mitigation Measure TRA -2 in the DEIR.
The project will also build out Madison Street, Avenue 58,
and Avenue 60 to ultimate standards per the General Plan.
See page 4.13-29 in the Draft EIR for project roadway
improvements. The internal roadways and surrounding
roadways will provide infrastructure needed to access the
site. The proposed resort, recreational, and commercial land
uses, along with the full buildout of the surrounding
roadways enhances the security and resilience of the regional
transportation system by attracting visitors to the project
and requiring goods to be delivered to the project site.
Goal #4: Increase person and
Consistent: The project property is currently vacant and
goods movement and travel
undeveloped. The project proposes a complimentary mix of
choices within the transportation
low density residential, neighborhood commercial, tourist
system.
commercial, and open space uses on the 386 -acre project
site. The tourist commercial component of the project (which
includes the hotel, amenities, resort residential, and the
Wave Basin) will increase services associated with tourism
and neighborhood commercial uses, as well as increase the
movement of people and goods to the site. Additionally, the
project's neighborhood commercial and tourist commercial
land uses will generate revenue and create employment
opportunities.
The proposed project will introduce a recreational facility
(Wave Basin) that will attract visitors who want to surf at the
Wave facility. The project will also host up to four special
events per year at the Wave Basin, bringing up to 2,500
people to the project site. The resort facility and Wave Basin
will increase person and goods movement and travel choices
within the area by attracting people to the high-quality
facility and resort. As stated on page 4.10-16 of the DEIR, the
project proposes tourist commercial land uses consisting of a
recreational facility and hotel to promote the continued
growth of the tourism and resort industries in La Quinta by
providing resort, recreational, commercial, and residential
land uses on the project site. Additionally, the residential
uses will incrementally increase demand for commercial
goods and services in the region.
Coral Mountain Resort Final EIR
3-18
February 2022
3.0 REVISIONS TO THE DRAFT EIR
Coral Mountain Resort Final EIR
3-19
February 2022
The project proposes both vehicular and alternate
transportation access through a roadway network that
interconnects all land uses within the project. The project
proposes a multi -modal circulation system by providing
transportation systems for a variety of user groups including
motorists, cyclists, pedestrians, and drivers of electric
vehicles. The roadways proposed in the project will include
multiple access points to serve as vehicle and multi -use
transportation routes for residents and visitors. As stated in
the consistency analysis for Goal #2, the project proposes
different land use types near one another, which can
decrease the trip lengths between the land use types; where
commercial uses, such as grocery stores, can be accessed by
residential communities.
Goal #5: Reduce greenhouse gas
Consistent: The project will be designed with sustainability
emissions and improve air
features to reduce GHGs and promote energy efficiency
quality.
project -wide. As described on pages 4.7-11 of the Draft EIR,
such features include but are not limited to, pedestrian
connections and interconnectivity, implementation of ride
share programs, drought -tolerant landscaping, and use of
photovoltaic systems. These project design features (PDFs)
are listed in the project's Specific Plan and includes:
- Use of pedestrian connections to promote access,
interconnectivity, and vehicle trip reduction.
- Variety of proposed land uses and amenities within
the project to promote vehicle trip and emission
reductions.
- Implementation of ride sharing programs (including
designated ride -share vehicle parking) and employer-
sponsored shuttle services to reduce commute trips.
- Compliance with Title 24 standards for residential and
non-residential buildings.
- Use of drought -tolerant plants in landscape design.
- Use of energy efficient lighting.
- Use of photovoltaic (PV) systems.
If the Specific Plan is approved by the City of La Quinta, these
PDFs will be implemented at the project site.
Additional PDFs proposed to reduce project -generated GHG
emissions are listed on page 4.7-11 through 4.7-13, in Section
4.7, Greenhouse Gas Emissions, of the Draft EIR.
Coral Mountain Resort Final EIR
3-19
February 2022
3.0 REVISIONS TO THE DRAFT EIR
Coral Mountain Resort Final EIR
3-20
February 2022
PDFs to improve air quality are listed on page 4.2-13 through
4.2-15 in Section 4.2, Air Quality, in the Draft EIR.
Goal #6: Support healthy and
Consistent: As stated on page 4.10-18 of the DEIR, the project
equitable communities.
promotes a high-quality mix of uses that will contribute to
the built environment, promote walkability in the resort
center of the project, and provide opportunities for active
recreation. As stated on page 3-8 of the Draft EIR, one project
objective is to promote walkability and non -motorized
connectivity as an integral part of the project design,
including (1) establishing residential neighborhoods that are
linked through multi -use trails that connect neighborhoods
throughout the project; and (2) providing "walk streets" in
the Resort area to provide internal connection between
facilities within the Resort and the Wave Basin.
Additionally, the project will introduce 60,000 square feet of
neighborhood commercial building to the surrounding area,
which is not currently served by commercial uses in close
proximity. The closest grocery store to the project site is
located approximately four miles north, at the Jefferson
Street and Avenue 50 intersection. The project site is
surrounded by residential communities. The proposed
neighborhood commercial buildings will be open to the
public.
Goal #7: Adapt to a changing
Consistent: As stated under Goal #5, the project will be
climate and support an
designed with sustainability features to reduce GHGs and
integrated regional development
promote energy efficiency project -wide. Please refer to Goal
pattern and transportation
#5 for a list of PDFs, as well as Section 4.7 and 4.2 of the DEIR
network.
for a list of features.
As stated on page 4.10-17 of the DEIR, the project proposes
a private circulation system include both vehicular and
alternate transportation access through a roadway network
that interconnects all land uses within the project. The
project proposes a multi -modal circulation system by
providing transportation systems for a variety of user groups
including motorists, cyclists, pedestrians, and drivers of
electric vehicles. The roadways proposed in the project will
include multiple access points to serve as vehicle and multi-
use transportation routes for residents and visitors.
Goal #8: Leverage new
Not Appliable: The project proposes resort, residential, and
transportation technologies and
commercial land uses to the City. The project will include
data -driven solutions that result
both vehicular and alternate transportation access through a
in more efficient travel.
roadway network that interconnects all land uses within the
Coral Mountain Resort Final EIR
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February 2022
3.0 REVISIONS TO THE DRAFT EIR
Coral Mountain Resort Final EIR
3-21
February 2022
project. The project proposes a multi -modal circulation
system by providing transportation systems for a variety of
user groups including motorists, cyclists, pedestrians, and
drivers of electric vehicles. The roadways proposed in the
project will include multiple access points to serve as vehicle
and multi -use transportation routes for residents and
visitors. The project will introduce commercial facilities that
will reduce vehicle miles traveled by area residents (see Goal
#2 consistency analysis).
Goal #9: Encourage development
Consistent: The project proposes high-quality housing of
of diverse housing types in areas
varying types and sizes with access to resort and recreational
that are supported by multiple
amenities. The project proposes up to 600 residential
transportation options.
dwelling units on the project site. The project will include up
to 496 single family attached and detached dwellings and
affiliated amenities permitted within Low Density Residential
land use designations. Low Density Residential product types
may include estate compounds, single-family
detached/attached units, alley loaded homes, and clustered
products. Up to 104 dwelling units will be resort residential
units. Resort residential product types may include single
family detached units, townhomes, and stacked flats. See
page 4.10-11 in the Draft EIR for a description of the
proposed residential types.
The project's circulation plan proposes a multi -modal system.
The design seeks to decrease automobile dependency by
providing transportation facilities for a variety of user groups
including motorists, cyclists, pedestrians, and drives of
electric vehicles. The proposed circulation systems will
provide a roadway network that will interconnect all land
uses within the project. See page 3-11 in the Draft EIR for a
full discussion of project vehicular and non -vehicular
circulation.
Goal #10: Promote conservation
Consistent: The project site proposes approximately 23.6
of natural and agricultural lands
acres of open space areas at the western property boundary.
and restoration of habitats.
The project's southwest boundary abuts Coral Mountain. As
stated on page 4.13-47 of the Draft EIR, the Desert
Recreation District Master Plan includes a proposed trail
along the toe of Coral Mountain associated with the future
Coral Mountain Interpretive Center. The proposed trail
alignment falls within the project boundaries. As shown in
Mitigation Measure TRA -15 project plans will include
accommodations for this trail within the designated
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February 2022
3.0 REVISIONS TO THE DRAFT EIR
Coral Mountain Resort Final EIR
3-22 February 2022
conservation area at the southwestern edge of the property.
Mitigation Measure TRA -15 specifically states:
"The project proponent shall ensure that the proposed Coral
Mountain Interpretive Center trail designated by the Desert
Recreation District Master Plan and associated with the
future Coral Mountain Interpretive Center is incorporated
into project plans. Accommodations for this trail shall be
located along the approximate toe of Coral Mountain, within
the designated conservation area at the southwestern edge
of the property."
In addition to the trail, the project proposes to develop a
sheep barrier to deter Peninsular bighorn sheep from
entering the site. A barrier/fence would prevent PBS from
exiting Coral Mountain onto the site, where there is no
escape cover and where they would be very vulnerable to
predation and exposure to toxic plants, herbicides and
insecticides. PBS would still be able to transverse the open
space associated with the BLM lands between the Santa
Rosas and Coral Mountain but will not be able to migrate off
Coral Mountain onto the valley floor area of the project site.
The project also proposes mitigation measures to reduce
project impacts regarding biological resources. Please refer
to Section 4.3, Biological Resources, of the DEIR for a full
analysis and discussion of the plant and animal species onsite
in the region, and mitigation measures required.
Finally, the project will pay the applicable MSHCP fee to fund
the continued acquisition and preservation of important
habitat areas within the Coachella Valley."
Coral Mountain Resort Final EIR
3-22 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Location & Page Revision
Section 4.13, Urban Crossroad's Traffic Report provided a table indicating the Trip
Transportation, Generation at project buildout. This is indicated as Table 4-3 in the
Page 4.13-21 Report. This table was included on page 4.13-21 in the Draft EIR,
however, certain quantities appear to have been incorrectly inserted into
Table 4.13-13 in the Draft EIR. An updated table consistent with the
Traffic Report is included below. The discrepancies did not affect the
project totals, and thus did not affect the assessment of traffic
impacts. A corrected Table 4.13-13 has been included below.
Table 4.13-13 Project Buildout (2026)
Trip Generation Rates
Land Use
ITE LU
Code
Quantity
(note 2)
AM Peak Hour
PM Peak Hour
Daily
In
Out
Total
In
Out
Total
Single Family Detached
210
220
496 DU
104 RM
94
273
367
308
184
492
4,682
Multifamily Housing (Low -Rise)
11
36
47
36
22
58
761
Internal to Retail/Resort
(4014)
(2826)
(3040)
(4050)
(2938)
(6988)(595771)
Residential External Trips
9891
289283
384374
304294
177168
484462 _
4,84Y4 672
Shopping Center
820
60 TSF
35
22
57
110
119
229
2,265
Pass -By (25%)
(7)
(7)
(14)
(28)
(28)
(56)
(566)
Internal to Residential/Resort
(9)
(7)
(16)
(21)
(35)
(56)
(448560)
Shopping Center External Trips
19
8
27
61
56
117
1,2511
139
Resort Hotel
330
150 RM
41
15
56
30
41
71
1,181
Internal to Residential/Retail
(4417)
(4014)
(2431)
(4823)
(2428)
(3651)
(446612)
Resort Hotel External Trips
2724
51
3425
457
2813
3620
765569
Wave Basin Facility
(note 4)
12 AC
14
10
24
29
19
48
600
Internal to
Residential/Retail/Resort
(12)
(8)
(20)
(26)
(17)
(43)
(470)
Wave Basin Facility External Trips
2
2
4
3
2
5
130
Wave Village 861
15 TSF
3
2
5
16
15
31
431
(1)
(1)
(2)
(7)
(7)
(14)
(168)
Wave Village External Trips
2
1
3
9
8
17
263
The Farm
495
16 TSF
18
11
29
18
19
37
461
(9)
(6)
(15)
(9)
(11)
(20)
(240)
The Farm External Trips
9
5
14
9
8
17
221
Project Subtotal
216
369
585
547
419
966
10,381
Internal Capture Subtotal
(62)
(62)
(124)
(136)
(136)
(272)
(2,821)
Pass -By (Shopping Center)
(7)
(7)
(14)
(28)
(28)
(56)
(566)
Total
443147
304300
447
383
255
638
6,994
1. Trip Generation Source: Institute of Transportation Engineers (ITE), Trip Generation Manual 10th Edition (2017).
2. DU = Dwelling Unit; TSF = Thousand Square Feet; RM = Occupied Room
3. Pass -by Source: Shops at Coral Mountain TIA, prepared by Urban Crossroads, Inc. (November 2009)
4. 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.
5. Hotel trip rates account for 23.5 tsf of ancillary facilities which include bar, restaurant, kitchen, rooftop bar, pool bar & grill,
spa, and back of house resort operations.
6. The Wave Basin Facility trip rates account for pool area and 1.5 tsf of back of house wave operations.
7. Wave Village trip rates account for 15 tsf of ancillary facilities which include shape studio, surf shop, board room, surf
lounge/living room, surf classroom, fitness pavilion, high performance center, & beach club.
8. The Farm trip rates account for 16 tsf of ancillary facilities which include Barn, Greenhouse, Equipment Barn, Tool Shed,
Family Camp, Gym, Outfitters, & Locker Rooms.
9. The 1 tsf back of house guardhouse use is accounted for in the Project rates.
Coral Mountain Resort Final EIR
3-23 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Location & Page
Section 4.15, Utilities
and Service Systems,
Page 4.15-16
Section 4.15, Utilities
and Service Systems,
Page 4.15-24 (Exhibit
4.15-1)
Revision
The following revision addresses Comment Number 10-a, located in
Chapter 2.0, Response to Comments, where CVWD corrects the
Conceptual Water Plan exhibit in the Draft EIR.
"Water Infrastructure
The project proposes to connect to the existing water lines located north
of the project site on Avenue 58, to the east on Madison Street, and to
the southeast on Avenue 60. Specifically, an 18 -inch water main is
located along Avenue 58; 30 -inch and 24 -inch water mains occur along
Madison Street; and a 24 -inch water main occurs along Avenue 60. The
proposed project water lines will consist of 18 -inch, 12 -inch, and 8 -inch
public water lines. Two points of connection will occur at Avenue 58. The
project will connect 12 -inch lines at the northern boundary to the existing
18 -inch water main. Four points of connection will occur on Madison
Street. The project will connect an 18 -inch water main to the existing 30 -
inch water main at Madison Street's northern -most point of connection.
This water line will decrease in diameter from 18 inches to 12 inches to
serve the residential and resort portions of the site. Two additional points
of connection will occur at the eastern -most property boundary. At this
location, the project will connect two 12 -inch water mains to the existing
30 -inch water main. The southern -most Madison Street point of
connection will connect a proposed 18 -inch water main to the existing
24 -inch water main. CVWD also requires an offsite pipeline in Avenue 60
in accordance with an existing agreement. The infrastructure and design
components for the project will be consistent with CVWD requirements
and the UWMP. The project will be further reviewed by City and CVWD
staff to ensure compliance with all current and applicable water
requirements."
Please see the updated Conceptual Water Plan exhibit below to replace
Exhibit 4.15-1 and Exhibit 3-11 in the Draft EIR, per CVWD's comment
(Comment Letter No. 10) in Chapter 2.0 of this Final EIR.
Coral Mountain Resort Final EIR
3-24 February 2022
3.0 REVISIONS TO THE DRAFT EIR
Exhibit 3-11 and 4.15-1, Conceptual Water Plan
Legend:
..
Project Bcundavy
■w. — —
Existing Water h9a'r
Proposes C.V.44.C.
Well Site
Proposes Public 8"
Wafer Man
Propasea Puolic 12
Water Ma -r•
�12w
Proposed Public 18
Water Mar
18W m.1
Notes- t. Information showr> is conoeptrraf orgy.
FnaJ engineering design plans may deviafe.
2. Number and tocafion of weUs is preliirninary.t
subjecf fo furtherdiscwsion with C.V.W.p_
MSA CONSULTING, INC. CONCEPTUAL WATER PLAN
o- PLANNING s CNIL ENGINEERING : LANG SURVEYING40
yaw Bob RNA Driok Rancho- Min U.22E+5
760.12014911 mLaconilrtFgin[aorn
CORAL MOUNTAIN RESORT
ENVIRONMENTAL IMPACT REPORT
Coral Mountain Resort Final EIR 3-25
February 2022
3.0 REVISIONS TO THE DRAFT EIR
3.2 No Significant New Information Requiring Recirculation
CEQA and the CEQA Guidelines provide that when "significant new information" is added to an EIR
after the expiration of the public comment period but before certification, the lead agency must
recirculate the EIR for additional public comment. However, recirculation is required only when the
information added to the EIR changes the EIR in a way that deprives the public of a meaningful
opportunity to comment on either a substantial adverse environmental impact of the project or a
feasible project alternative or mitigation measure that would clearly reduce the impact and that is
not going to be implemented. Section 15088.5 (e) of the CEQA Guidelines provides that a decision not
to recirculate is appropriate if it is supported by substantial evidence in the administrative record.
Under CEQA and the CEQA Guidelines, the following constitutes substantial evidence: (a) facts; (b)
reasonable assumptions predicated on facts; and (c) expert opinions supported by facts. Basically, a
lead agency's determination whether information in the record constitutes "substantial evidence"
boils down to a determination not only that the information is relevant and material but also that it
is sufficiently reliable to have solid evidentiary value. Under CEQA, to determine the reliability of the
evidence, a lead agency may consider several factors, such as, but not limited to:
• Whether the evidence has an adequate foundation in the witness's personal knowledge of
facts;
• Whether the evidence is provided by a qualified source, such as when an opinion is provided
by a witness who is qualified to render an opinion on the subject; and
• Whether the evidence is just simply credible.
Upon reviewing all of the written comments submitted during the 45 -day public review period,
responses were provided based on the multitude of studies and analyses prepared and/or conducted
by various experts (consultants) in preparation of the Draft EIR, the Final EIR, and the project's
Mitigation Monitoring and Reporting Program.
The consultants who prepared the studies utilized in the Draft EIR, performed the necessary analyses
and/or otherwise participated in reviewing the proposed project's potential effects under CEQA and
the CEQA Guidelines included, the Director of Environmental Services, a Senior Environmental
Planner/GIS Analyst, a Planner, an Environmental Planner, a Planning CAD Technician, and a Principle
Engineer of MSA Consulting, Inc.; Biologists with LSA Associates, Inc.; a Principal
Investigator/Historian, a Professional Archaeologist, and a Paleontological Surveyor with CRM Tech;
a Project Geologist and a Principal Engineer with Sladden Engineering; an Associate Principal, Principal
Engineer, and AICP Principal with Urban Crossroads, Inc.; and light experts of Musco Lighting. The
City staff who also coordinated efforts with the various consultants included the City's Director of
Development Services, Planning Manager, and Director of Public Works.
Coral Mountain Resort Final EIR
3-26 February 2022
3.0 REVISIONS TO THE DRAFT EIR
During the public review period of the Draft EIR, concerns regarding specific environmental topics
were raised. The concerns included those related to light, traffic, biological resources, noise, and City
land use and zoning. Additional reports were conducted by technical experts to address, verify, or
validate the findings of the Draft EIR and associated studies. The additional technical reports were
completed by light experts of Musco Lighting; Dr. McGill, PhD, with ELMT Consulting; and Kelly Slater
Wave Company. Urban Crossroads, Inc. and LSA Associates, Inc. also provided updates and revisions
to their existing reports to address concerns raised by the public.
Through the coordinated efforts of all who participated in studying, researching and analyzing the
proposed project and its potential effects in the environment, the Draft EIR, and Final EIR was
organized to address the following environmental topics:
4.1 Aesthetics
4.2 Air Quality
4.3 Biological Resources
4.4 Cultural Resources
4.5 Energy
4.6 Geology and Soils
4.7 Greenhouse Gas Emissions
4.8 Hazards and Hazardous Materials
4.9 Hydrology and Water Quality
4.10 Land Use and Planning
4.11 Noise
4.12 Public Services
4.13 Transportation
4.14 Tribal Cultural Resources
4.15 Utilities
The City relied on the collective expertise of each of the above consultants and staff as reflected in
the analyses of each of the aforementioned environmental topics to prepare its responses to each of
the comments received at the close of the public review period. It was determined that none of the
comments and none of the responses to the comments generated any "significant new information"
that needed to be added to the EIR, such as but not limited to identifying or disclosing an
unbeknownst substantial adverse environmental impact of the project, an unbeknownst feasible
project alternative or unbeknownst mitigation measure that would clearly reduce a significant impact
and/or one that was not going to be implemented.
In light of the foregoing, it was determined that there is substantial evidence in the administrative
record to support the City's decision to not recirculate the EIR for further public comment.
Coral Mountain Resort Final EIR
3-27 February 2022
FINAL ENVIRONMENTAL IMPACT REPORT
Coral Mountain Resort, La Quinta CA
4.0 Mitigation Monitoring and Reporting Program
Chapter 4.0 Mitigation Monitoring and Reporting Program
4.1 Introduction
If mitigation measures are required or incorporated into a project as part of the CEQA process, the
lead agency must adopt a Mitigation Monitoring and Reporting Program (MMRP) to ensure
compliance with the project's mitigation measures. Section 15126(a)(2) of the CEQA Guidelines
provides that a project's mitigation measures must be enforceable through permit conditions,
agreements, or other mechanisms. CEQA and the CEQA Guidelines further provide that the MMRP
must be adopted at the time of project approval. However, while the MMRP does not have to be
included in the EIR, for the sake of maximizing public transparency, a copy of the proposed project's
MMRP has been included in this Final EIR below.
In light of the foregoing, this Chapter contains the proposed project's MMRP. The MMRP was
prepared to provide a program for not only monitoring and reporting on the project's mitigation
measures, but also enforcing compliance with respect to the implementation of each mitigation
measure adopted for the project. The purpose of the mitigation measures is to mitigate or avoid
significant environmental effects of the project.
4.2 Monitoring Authority
The City may delegate duties and responsibilities for monitoring any given mitigation measure to
designated environmental monitors or consultants as deemed necessary. The City may also delegate
such duties and responsibilities to certain responsible agencies, affected jurisdictions, enforcement
and regulatory agencies of the state or county, special districts and other agencies. The same duties
and responsibilities may also be delegated to qualified private entities which accept the delegation.
The City's Development Services (or equivalent positions of other designated agencies or entities)
must ensure that the officials delegated the duties or responsibilities to monitor any given set of
mitigation measures are qualified to assume such duties and responsibilities.
Any deviation from the procedures identified under the MMRP shall require prior approval or
authorization by the City. Moreover, any deviations from any of the established monitoring
procedures set forth in the MMRP and any remedial actions taken to correct such deviations shall be
reported immediately to the City by the assigned environmental monitor or consultant.
Notwithstanding any such delegation, the City shall remain responsible for monitoring the
implementation of all of the project's mitigation measures in accordance with the project's MMRP.
Coral Mountain Resort Final EIR
4-1 February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
4.3 Enforcement Responsibility
The mitigation measures for the proposed project will primarily apply prior to or during construction
of the project in all phases of development the project. The City shall be responsible for enforcing
each mitigation measure, albeit the City may assign such enforcement responsibilities to a qualified
environmental monitor. The assigned environmental monitor for each construction activity shall
report any problems with enforcement to the City and appropriate agencies.
The MMRP prepared for the proposed project will be fully enforceable through permit conditions,
agreements, or other measures.
4.4 Mitigation Monitoring Table
Table 4-1, Coral Mountain Resort Mitigation Monitoring and Reporting Program, below identifies
for each mitigation measure: (1) the potential impact on the environment that the mitigation measure
is focused on; (2) a description of the mitigation measure; (3) who or which entity is responsible for
monitoring the mitigation measure; (4) the timing for implementing the measure; and (5) the
anticipated level of significant after mitigation.
Coral Mountain Resort Final EIR
4-2 February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
Table 4-1
Coral Mountain Resort Mitigation Monitoring and Reporting Program
Potential Impacts on
the Environment
Mitigation Measure
Responsible for
Monitoring
Timing
Level of
Significance
After Mitigation
Section 4.1,
Aesthetics
a. Adverse effect on
scenic vistas
c. Visual character
or scenic quality
AES -1 The perimeter walls around the low density residential
planning areas shall be setback from the Madison Street
and Avenue 58 public rights-of-way by a minimum
average of 30 feet (10 feet more than required under the
LQMC), which shall be confirmed through the City's
review and approval of final perimeter wall and
landscape plans to reduce impacts to existing views of
Coral Mountain and the Santa Rosa Mountains.
City Council/
Planning
Commission
Public Works
Department
Project Applicant
During review
of Tentative
Tract Maps
Significant and
Unavoidable
AES -2 All residential structures shall be setback by a minimum
of 75 feet from the Madison Street and Avenue 58 public
rights-of-way to reduce impacts to existing views of
Coral Mountain and the Santa Rosa Mountains.
City Council/
Planning
Commission
Public Works
Department
Project Applicant
During review
of Tentative
Tract Maps
Significant and
Unavoidable
d. Light and glare
AES -3 The operation of the Wave Basin will be limited to the
hours of 7:00 a.m. to 10:00 p.m., and the lighting will
only be permitted between dusk and 10:00 p.m. to
ensure compliance with the City's outdoor lighting
requirements (LQMC 9.100.150).
Public Works
Department
Project Applicant
During
operation of
the Wave
Basin
Less than
Significant
Section 4.2, Air
Quality
a. Conflict with
implementation
of applicable air
quality plan
b. Result in a
Construction -Source Mitigation Measures
AQ -1: During Phase 1 of construction, the paving installation
activity shall not overlap with the architectural coating
(building painting) activity. That prohibition shall be
included on all building plans.
AQ -2: For equipment greater than 150 horsepower (>150 HP),
the Construction Contractor shall ensure that off-road
City Planning &
Public Works
Department
Project
Contractor
During ground
disturbing
activities &
construction
Less than
Significant
Coral Mountain Resort Final EIR
4-3
February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
cumulatively
considerable net
increase if any
criteria pollutant
for which the
project region is
non -attainment
under an
applicable
federal or state
ambient air
diesel construction equipment that complies with
Environmental Protection Agency (EPA)/California Air
Resources Board (CARB) Tier 3 emissions standards and
shall ensure that all construction equipment is tuned
and maintained in accordance with the manufacturer's
specifications.
Operational -Source Mitigation Measures
AQ -3: The project will require the use of low VOC paints for re -
painting and maintenance of exterior structures
consistent with SCAQMD Rule 1113(not to exceed 50
quality standard
grams per liter VOCs for interior and exterior building
City Planning &
c. Expose sensitive
receptors to
envelope re -painting). Under federal and state law,
SCAQMD is under a legal obligation to enforce air
Public Works
Department
During
Less than
substantial
pollution regulations. These regulations are primarily
Construction
Significant
pollutant
meant to ensure that the surrounding (or ambient) air
Project
concentrations
meets federal and state air quality standards. The South
Contractor
Coast AQMD also has broad authority to regulate toxic
and hazardous air emissions, and these regulations are
enforced in the same manner as those which pertain to
the ambient air quality standards.
Standard Regulatory Requirements/Best Available Control
Measures
Measures listed below (or equivalent language) shall
appear on all project grading plans, construction
specifications and bid documents, and the City shall
ensure such language is incorporated prior to issuance
City Planning &
of any development permits. South Coast Air Quality
Public Works
Prior to the
Management District (SCAQMD) Rules that are currently
Department
approval of
Less than
applicable during construction activity for this project
include but are not limited to Rule 403 (Fugitive Dust) (2)
and Rule 1113 (Architectural Coatings). It should be
noted that these Best Available Control Measures
Project
Contractor
grading plans
Significant
(BACMs) are standard regulatory requirements.
BACM AQ -1: The contractor shall adhere to applicable
Coral Mountain Resort Final EIR
4-4
February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
Coral Mountain Resort Final EIR
4-5
February 2022
measures contained in Table 1 of Rule 403 including, but
not limited to:
• All clearing, grading, earth -moving, or excavation
activities shall cease when winds exceed 25 mph per
SCAQMD guidelines in order to limit fugitive dust
emissions.
• The contractor shall ensure that all disturbed
unpaved roads and disturbed areas within the
project are watered at least three (3) times daily
during dry weather. Watering, with complete
coverage of disturbed areas, shall occur at least
three times a day, preferably in the mid-morning,
afternoon, and after work is done for the day.
• The contractor shall ensure that traffic speeds on
unpaved roads and project site areas are limited to
15 miles per hour or less.
BACM AQ -2: The following measures shall be incorporated into
project plans and specifications as implementation of
SCAQMD Rule 1113 (3):
• Only "Low -Volatile Organic Compounds (VOC)"
paints (no more than 50 gram/liter (g/L) of VOC)
consistent with SCAQMD Rule 1113 shall be used.
BACM AQ -3: The project is required to comply with SCAQMD
Rule 445, which prohibits the use of wood burning
stoves and fireplaces in new development.
Section 4.3,
Biological Resources
a. Candidate,
sensitive or special
BIO -1: Burrowing owl surveys shall be performed by a qualified
biologist, approved by the City prior to any site
disturbance activities. A minimum of two surveys,
occurring at least three weeks apart, shall be completed
in advance of any site disturbance activities. If
Qualified
Biologist
City Planning
Prior to
Less than
status species
disturbance activities are expected to start during the
Department
ground
Significant
d. Interfere with
burrowing owl breeding season, three surveys shall be
Project
disturbance
movement of
completed. The final burrowing owl survey shall be
Applicant/
native resident or
completed within three days prior to initiation of any site
disturbance activities. The pre -construction survey shall
Developer
Coral Mountain Resort Final EIR
4-5
February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
migratory fish or
wildlife species or
with established
native resident or
migratory wildlife
corridors
be conducted following accepted protocol and the
requirements specified in the CVMSHCP (see pp. 4-168
& 4-169). Prior to construction, a qualified biologist will
survey the construction area and an area up to 500 feet
outside the project limits for burrows that could be used
by burrowing owls. If the burrow is determined to be
occupied, the burrow will be flagged, and a 160 -foot
diameter buffer will be established during non -breeding
season or a 250 -foot diameter buffer during the
breeding season. The buffer area will be staked and
flagged. No development activities will be permitted
within the buffer until the young are no longer
dependent on the burrow and have left the burrow.
If the burrow is found to be unoccupied, the burrow will
be made inaccessible to owls, and construction may
proceed. If either a nesting or escape burrow is
occupied, owls shall be relocated pursuant to accepted
Wildlife Agency protocols. Determination of the
appropriate method of relocation, such as
eviction/passive relocation or active relocation, shall be
based on the specific site conditions (e.g., distance to
nearest suitable habitat and presence of burrows within
that habitat) in coordination with the Wildlife Agencies.
If burrowing owls are observed within the Project site
during construction activities, CDFW shall be notified
immediately and provided with proposed avoidance and
minimization measures, consistent with the
requirements of the CVMSHCP.
BIO -2: In June 2021, a qualified bat biologist will conduct a
second round of focused nighttime surveys for roosting
bats at locations where suitable roosting habitat is
Qualified Bat
Biologist
Less than
identified. The nighttime survey will include a
City Planning
June 2021
combination of acoustic and exit count methods, and
will take place during the bat maternity season (March
Department
Significant
15—August 31 in the Coachella Valley) to enable
Project
Coral Mountain Resort Final EIR
4-6
February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
Coral Mountain Resort Final EIR
4-7
February 2022
detection of maternity -roosting bats. If maternity roosts
are identified within the project area, the biologist will
coordinate with CDFW to implement avoidance
measures during the bat maternity season in accordance
with CDFW's established standards. No construction
activities will occur within a 300 -foot buffer of maternity
roost sites during the bat maternity season unless
concurrence is received from CDFW to reduce that
buffer distance based upon the bat species present and
the activities occurring.
Applicant/
Developer
BIO -3: Removal of trees (including palm trees) shall occur
outside the bat maternity season (March 15—August 31
in the Coachella Valley), which coincides with the bird
nesting season, to avoid the potential for "take" of
flightless young. Trees and snags that have been
identified as confirmed or potential roost sites require a
two-step removal process and the involvement of a bat
Qualified Bat
Biologist
Outside bat
biologist to ensure that no roosting bats are killed during
this activity. Consistent with CDFW protocols this two-
City Planning
Department
maternity
season
Less than
step removal shall occur over two consecutive days as
(March 15 —
Significant
follows: on Day 1, branches and limbs not containing
cavities, as identified by a qualified bat biologist, will be
removed. On Day 2, the remainder of the tree may be
removed without supervision by a bat biologist. The
disturbance caused by limb removal, followed by an
interval of one evening, will allow bats to safely abandon
the roost.
Project
Applicant/
Developer
August 31)
BIO -4: To avoid impacts to roosting bats from the installation of
new light fixtures associated with the proposed
development, all lighting fixtures shall have light shields
or similar devices (i.e., dark sky compliant lighting)
installed to ensure that there is no light trespass onto
Qualified Bat
Biologist
City Planning
Department
Prior to the
installation of
Less than
Coral Mountain and surrounding open space. A
supplemental light study will be performed to collect
nighttime lighting measurements and confirm that no
light trespass onto Coral Mountain is occurring; this will
Project
Applicant/
Developer
light poles
Significant
Coral Mountain Resort Final EIR
4-7
February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
Coral Mountain Resort Final EIR
4-8
February 2022
be submitted for City approval prior to issuance of any
permit for occupancy or use of the Wave Basin.
BIO -5: A qualified bat biologist shall confirm the absence of
roosting bats prior to any restoration work or other
disturbance of the adobe site. If bats are found or if the
absence of bats cannot be confirmed, the bat biologist
will install or directly supervise installation of humane
eviction devices and exclusionary material to prevent
bats from roosting in the building. Implementation of
the humane eviction/exclusions is typically performed in
the fall (September or October) preceding construction
activity at each structure to avoid impacts to hibernating
bats during the winter months or during the maternity
season (March 15—August 31 in the Coachella Valley),
when nonvolant (flightless) young are present. Any
humane eviction/exclusion devices must be installed at
least 10 days prior to the demolition of a structure
housing bats to allow sufficient time for the bats to
vacate the roost(s).
Qualified Bat
Biologist
City Planning
Department
Project
Applicant/
Developer
10 days prior
to the
demolition of
a structure
housing bats
Less than
Significant
BIO -6: To ensure compliance with California Fish and Game
Code and the MBTA and to avoid potential impacts to
nesting birds, vegetation removal and ground -disturbing
activities shall be conducted outside the general bird
nesting season. Any vegetation removal, ground
disturbance, and/or construction activities that occur
during the nesting season will require that all suitable
habitats be surveyed for the presence of nesting birds by
a qualified biologist that is pre -approved by the CDFW.
Prior to commencement of clearing, a qualified biologist
shall conduct preconstruction surveys within 14 days
and repeated 3 days prior to ground -disturbing
activities. If any active nests are detected a buffer of 300
feet (500 feet for raptors) around the nest adjacent to
construction will be delineated, flagged, and avoided
until the nesting cycle is complete. During construction
activities, the qualified biologist shall continue biological
Qualified Bat
Biologist
City Planning
Department
Project
Applicant/
Developer
14 days prior
to clearing
activities
Outside the
general bird
nesting
season
Less than
Significant
Coral Mountain Resort Final EIR
4-8
February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
Coral Mountain Resort Final EIR
4-9
February 2022
monitoring activities at a frequency recommended by
the qualified biologist using his or her best professional
judgment, or as otherwise directed by the Wildlife
Agencies. If nesting birds are detected, avoidance and
minimization measures may be adjusted and
construction activities stopped or redirected by the
qualified biologist using their best professional
judgment as otherwise directed by the Wildlife Agencies
to avoid Take of nesting birds.
BIO -7: To ensure that the project will avoid any significant
construction noise impacts on wildlife using Coral
Mountain, noise monitoring will occur for all
construction activities using heavy equipment within
150 feet of the base of Coral Mountain. If noise levels
exceed 75 dBA, construction operational changes or
other project modifications shall be made, as directed by
the project biologist to reduce the noise levels at Coral
Mountain to below 75 dBA.
City Manager
Project
Developer
During
construction
activities
within 150
feet of Coral
Mountain
During Special
Events
Once annually
Less than
Significant
_
BIO -8: Existing native vegetation, particularly palo verde trees,
will be retained where feasible. Landscaping shall
include native desert species.
City Planning
Department
Project Applicant
During
Landscaping
Less than
Significant
BIO -9: Onsite lakes will be designed and constructed by
industry professionals and will incorporate proper
aeration, circulation and filtration to maintain a
balanced lake ecosystem. Lakes will be stocked with
beneficial fish and plant species. Limited chemical
applications will be utilized as necessary. Ongoing
maintenance will ensure that onsite lakes function
properly to control any invasive species or other
nuisance conditions.
Project Applicant
During
operation
Less than
Significant
BIO -10: An educational program about the Peninsular bighorn
sheep and their associated habitat shall be implemented
and maintained throughout the resort, open space, and
City Planning
Department
During
operation
Less than
Significant
Coral Mountain Resort Final EIR
4-9
February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
Coral Mountain Resort Final EIR
4-10
February 2022
low-density community programs through the use of
signage, pamphlets, and staff education. The Education
Project Applicant
Program should inform the reason of why specific
measures are being taken to support recovery of
Peninsular bighorn sheep. The Education Program
should include the ecology of Peninsular bighorn sheep,
what threats this species is currently facing, and how
recovery actions will reduce these threats. This includes
information that explains: (1) why restrictions on toxic
plants, fences, and pesticides are needed; (2) how
artificial feeding of coyotes could adversely affect
bighorn sheep; and (3) how recreational activities may
affect sheep. The use of interpretive signs is encouraged.
4.4 Cultural
Resources
CUL -1: A comprehensive recordation program shall be
prepared by a qualified archaeologist for Site 33-008388.
a. Adverse change
to Historical
Resources
b. Adverse change
The program shall contain detailed drawings and
measurements to preserve the information on the
adobe building. Such information would include the
floor plan, elevations, building materials and their
configurations, and any other notable structural and
to Archaeological
architectural details. The adobe remains and an
Qualified
Resources
c. Disturb human
appropriate buffer determined by the project
archaeologist shall be flagged and cornered off during all
Archaeologist
prior to the
remains
ground disturbance and preserved in place. Prior to the
City Planning &
occupancy of
Less than
occupancy of any structure in Planning Area II, the adobe
Engineering
any structure
Significant
will be fenced off and an informational plaque describing
the history of the ranch complex shall be provided, and
the project proponent shall provide the City with the
Department
Project Applicant
in Planning
Area II
CC&Rs for the project area, demonstrating that the
feature would be maintained in perpetuity by the
project's Homeowners Association. Special attention
should be given to the residence foundation, which, may
be the remains of one of the earlier structures at the site,
dating from 1920s or before. The footings and slabs at
this location should be cleared and measured, and
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attempts should be made to locate the original trash pits
or privies which could contain valuable artifacts
revealing much about life in the harsh environment at
such an early date. The scatter of artifacts has the
greatest number of pre -1925 artifacts, mostly in the
form of sun -colored glass, but also in brown and olive
glass, porcelain, ceramics and more. There may be
remains of an early structure near this point, hidden
amidst the broad stand of tamarisk trees, an original
windbreak. Search of these remains is required to
ensure the most complete recovery possible of the early
20th century artifacts and features. Photos,
measurements, and artifacts shall be catalogued,
analyzed, reported, and curated at the Coachella Valley
Museum (Love et aI.1998:54).
CUL -2: The presence of a qualified archaeologist shall be
required during all project related ground disturbing
activities, including clearing and grubbing. A monitoring
plan shall be prepared and approved by the ACBCI and
the City prior to the initiation of any ground disturbing
activity for all construction phases and activities. If
potentially significant archaeological materials are
discovered, all work must be halted in the vicinity of the
archaeological discovery until the archaeologist can
assess the significance of the find.
Qualified
Archaeologist
City Planning
Department
ACBCI
Prior to
ground
disturbing
activities
Less than
Significant
CUL-3:An approved Agua Caliente Band of Cahuilla Indians
(ACBCI) Native American Cultural Resource Monitor
shall be present during any ground disturbing activities
(including archaeological testing and surveys) for the
project. If potentially significant archaeological materials
are discovered, all work must be halted in the vicinity of
the archaeological discovery until the Tribal monitor can
assess the significance of the find.
City Planning
Department
Agua Caliente
Band of Cahuilla
Indians — Native
American
Resource
Monitor
Project Applicant
During ground
disturbing
activities
Less than
Significant
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CUL -4: Prior to ground disturbance during any phase of the
project, cultural sensitivity training shall take place for
all workers, conducted by the Agua Caliente Tribal
Historic Preservation Office (THPO).
Agua Caliente
Tribal Historic
Preservation
Office
Project Applicant
Prior to
ground
disturbing
activity
Less than
Significant
CUL -5: Sites 33-00193, 33-001715, and 33-009545, along the
base of Coral Mountain and at the toe of the slope,
which contains the rock art panels and bedrock milling
features, shall be avoided and protected in situ during
project construction through the establishment of
Environmentally Sensitive Areas. Deed restrictions shall
be recorded for the Environmentally Sensitive Areas and
provided to the City prior to any ground disturbance of
any portion of Planning Area III. For the balance of Site
33-001715, where scattered artifacts but no features
were found, mitigative surface collection and subsurface
excavation shall be completed prior to ground
disturbance to recover a representative sample of the
cultural materials prior to the commencement of the
project and as a condition of grading permit issuance.
The excavation shall include a combination of standard
archaeological units, shovel test pits, and backhoe
trenches to optimize both efficient coverage of the site
area and safe recovery of cultural remains. The survey
protocols shall be approved by ACBCI and their approval
provided to the City in writing prior to the initiation of
any ground disturbing activity on the site.
City Planning
Department
ABCBI
Project Applicant
Section 4.6, Geology
and Soils
a. Expose people or
structures to
potential
substantial
GEO-1 All designs for any water body on the site shall be
prepared by a qualified engineer and comply with all
seismic codes in effect at the time they are constructed.
All designs shall be based on and incorporate the
recommendation of a qualified soils engineer in a site
and water body specific report attached to the plans
submitted to the City.
Qualified Soils
Engineer
City Planning,
Engineering &
Prior to site
plan approval
Less than
Significant
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4.0 MITIGATION MONITORING AND REPORTING PROGRAM
adverse effects
involving:
iii. Seismic -related
ground failure,
including
liquefaction
c. Located on an
Unstable
Geologic Unit
d. Located on
Expansive Soil
f. Destroy a unique
paleontological
resource or site
or unique
geologic feature
Public Works
Department
Project
Applicant/
Developer
GEO-2 All earthwork including excavation, backfill and
preparation of the subgrade soil, shall be performed in
accordance with the geotechnical recommendations,
presented below, and portions of the local regulatory
requirements, as applicable. All earthwork should be
performed under the observation and testing of a
qualified soil engineer. The following geotechnical
engineering recommendations for the proposed project
are based on observations from the field investigation
program, laboratory testing and geotechnical
engineering analyses.
• Stripping: areas to be graded shall be cleared of the
vegetation, associated root systems and debris. All
areas scheduled to receive fill should be cleared of
old fills and any irreducible matter. The stripping
shall be removed off -sit or stockpiled for later use in
landscape areas. Undocumented fill soil or loose soil
shall be removed in its entirety and replaced as
engineered fill. Voids left by obstruction shall be
properly backfilled in accordance with the
compaction recommendations of this report.
• Preparation of the Residential Building Areas: in
order to provide firm and uniform foundation
bearing conditions, the primary foundation bearing
soil shall be over -excavated and recompacted. Over -
excavation shall extend to a minimum depth of 3
feet below existing grade or 3 feet blow the bottom
of the footings, whichever is deeper. Once adequate
removals have been verified, the exposed native soil
Qualified Soils
Engineer
City Planning,
Engineering &
g g
Public Works
Department
p
Project
Applicant/
Developer
During ground
disturbing
activities
Less than
Significant
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•
•
shall be scarified, the moisture -conditioned
compacted to a minimum of 90 percent relative
compaction.
Preparation of the Hotel Building: In order
provide firm and uniform foundation bearing
conditions, over -excavation and re -compaction
through the building and foundation area
recommended. All artificial fill soil and low density
near surface native soil shall be removed to a depth
of at least 4 feet below existing grade or 4 feet below
the bottom of the footings, whichever is greater.
Remedial grading shall extend laterally, a minimum
of five feet beyond the building perimeter.
exposed surface shall then be scarified, the moisture
conditioned to within two percent of optimum
moisture content and compacted to at least
percent relative compaction.
Compaction: Soil to be used as engineered fill should
be free of organic material, debris and other
deleterious substances, and shall not contain
irreducible matter greater than six (6) inches
maximum dimension. All fill materials shall
placed in thin lifts not exceeding six inches in a loose
condition. If import fill is required, the material shall
be of a non -expansive nature and shall meet
following criteria:
and
to
is
The
90
in
be
the
the
Plastic Index
Less than 12
Liquid Limit
Less than 35
Percent Soil Passing
#200 Sieve
Between 15% and
35%
Maximum Aggregate
Size
3 Inches
The subgrade and all fill material shall be compacted
with acceptable compaction equipment, to at least
90 percent relative compaction. The bottom of
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exposed subgrade shall be observed by a
representative of Sladden Engineering prior to fill
placement. Compaction testing shall be performed
on all lifts in order to verify proper placement of the
fill materials.
• Shrinkage and Subsidence: Volumetric shrinkage of
the material that is excavated and replaced as
controlled compacted fill shall be anticipated. It is
estimated that shrinkage could vary from 10 percent
to 25 percent. Subsidence of the surfaces that are
scarified and compacted shall be between 1 and 3
tenths of a foot. This will vary depending upon the
type of equipment used, the moisture content of the
soil at the time of grading and the actual degree of
compaction attained.
GEO-3 All earth -moving operations reaching beyond the depth
of two feet shall be monitored by a qualified
paleontological monitor and continuous monitoring will
become necessary if undisturbed, potentially
fossiliferous lakebed sediments are encountered. The
monitor shall be empowered to stop earth moving
activities if fossils are identified. The monitor shall be
prepared to quickly salvage fossils, but must have the
power to temporarily halt or divert construction
equipment to allow for removal of abundant or large
specimens. A monitoring plan shall be provided to the
City prior to the issuance of any earth moving permit, or
the disturbance of any soils on the site, which will
include:
• Samples of sediments shall be collected and
processed to recover small fossil remains.
• Recovered specimens shall be identified and curated
at a repository with permanent retrievable storage
that would allow for further research in the future.
A report of findings, including an itemized inventory of
recovered specimens and a discussion of their
City Planning,
Department
Qualified
Paleontological
Monitor
Project
Applicant/
Developer
During earth -
moving
operations
reaching
beyond the
depth of two
feet
Less than
Significant
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February 2022
significance when appropriate, shall be prepared upon
completion of the research procedures outlined above.
The report shall be provided to the City within 30 days
of the conclusion of monitoring activities.
Section 4.7,
Greenhouse Gas
Emissions
a. GHG Emissions
that may
Significantly
Impact the
Environment
GHG-1: Prior to the issuance of occupancy permits, the project
applicant shall purchase a minimum of 72,000 MTCO2e
credits (2,400 MTCO2e per year for 30 years). The
purchase of carbon credits must be made from a CARB-
approved carbon registry with independent third -party
verification. Examples of approved registries include the
American Carbon Registry, Climate Action Reserve, and
Verra. The applicant shall submit documentation of the
offset purchase to the City demonstrating that it
mitigates a minimum of 2,400 MTCO2e per year (72,000
MTCO2e over a 30 -year period), prior to any occupancy
of the site. Alternatively, the project applicant may
submit a GHG reduction plan to the City for approval
that achieves an equal level of GHG reduction outlined
herein. The GHG plan must include enforceable actions
that reduce GHG emissions to at or below the total
mitigated values presented herein.
City Planning
Department
Project Applicant
Prior to the
issuance of
occupancy
permits
Significant and
Unavoidable
Section 4.11, Noise
a. Generation of
noise levels in
excess of
established
standards
b. Generation of
excessive
groundborne
vibration
NOI-1 Prior to approval of grading plans and/or issuance of
building permits, plans shall include a note indicating
that project construction activities shall comply with the
City of La Quinta Municipal Code requirements.
NOI-2 During all project site construction, the construction
contractors shall equip all construction equipment, fixed
or mobile, with property operating and maintained
mufflers, consistent with manufacturers' standards. The
construction contractor shall place all stationary
construction equipment so that emitted noise is
directed away from the noise sensitive receptors nearest
the project site.
City Planning &
Public Works
Department
Project
Applicant/
Developer
Prior to the
approval of
grading plans
and/or
issuance of
building
permits
Less than
Significant
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NOI-3 The construction contractor shall locate equipment
staging in areas that will create the greatest distance
between construction -related noise sources and noise -
sensitive receivers nearest the project site during all
project construction (i.e., to the center).
NOI-4 The contractor shall design delivery routes to minimize
the exposure of sensitive land uses or residential
dwellings to delivery truck -related noise.
NOI-5 A six-foot perimeter wall will be developed along the
northern and eastern property boundaries, adjacent to
the proposed Low Density Residential Planning Area (PA
II), in order to protect the proposed onsite residential
uses from off-site traffic noise. The barriers shall provide
a weight of at least four pounds per square foot of face
area with no decorative cutouts or line -of -sight openings
between shielded areas and the roadways. The barrier
must present a solid face from top to bottom.
Unnecessary openings or decorative cutouts shall not be
made. All gaps (except for weep holes) should be filled
with grout or caulking.
City Planning &
Public Works
Department
Project
Applicant/
Developer
During
construction
Less than
Significant
NOI-6 The operation of the Wave Basin and associated Wave
machines shall be limited to the daytime and evening
hours of 7:00 a.m. and 10:00 p.m., compliant with the
recreational operational hours allowed by the City of La
Quinta.
City Planning
Department
Project
Applicant/
Developer
During
Operation
Less than
Significant
Section 4.13,
Transportation
a. Conflict with an
applicable plan or
TRA -1 The project proponent shall contribute DIF as required
by the City of La Quinta.
TRA -2 The project proponent shall contribute TUMF traffic
impact mitigation feesprior to the issuance of Building
p g
Permits.
City Public Works
Department
Project Applicant
Prior to the
issuance of
Building
Permits.
Less than
Significant
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February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
policy addressing
the circulation
system
c. Increase hazards
due to a
geometric design
feature
d. Result in
inadequate
emergency access
TRA -3 The project proponent shall ensure that streetscape
improvement plans for the project frontage on Avenue
58, Madison Street and Avenue 60, are submitted to
the City for review and approval prior to the initiation
of landscape or roadway improvements.
City Planning &
Public Works
Department
Project Applicant
Prior to the
initiation of
landscape or
roadway
improvements
Less than
Significant
TRA -4 The project proponent shall ensure that clear
unobstructed sight distances are provided at all site
access points and internal intersections. Sight distances
shall be reviewed and approved by the City prior to
approval of landscape and street improvement plans.
City Planning &
Public Works
Department
Project Applicant
Prior to the
approval of
landscape or
roadway
improvements
Less than
Significant
TRA -5 The project proponent shall ensure that final layout and
site access design are subject to the review and
approval of the City Traffic Engineer prior to final
project approval.
City Traffic
Engineer
Project Applicant
Prior to final
project
approval
Less than
Significant
TRA -6 The project proponent shall ensure that emergency
police, fire and paramedic vehicle access are provided
for the project prior to final project approval.
Fire Department
City Planning &
Public Works
Department
Project Applicant
Prior to final
project
approval
Less than
Significant
TRA -7 The project proponent shall ensure that traffic signing
and striping plans shall be developed in conjunction
with street improvement plans and submitted to the
City of La Quinta for review and approval during the
project approval process.
City Planning &
Public Works
Department
Project Applicant
During the
project
approval
process
Less than
Significant
TRA -8 The project proponent shall ensure that Construction
Traffic Control Plans are reviewed and approved by the
City prior to project construction. These plans are to be
implemented during construction activities.
Construction includes onsite and offsite improvements.
City Planning &
Public Works
Department
Project Applicant
Prior to
project
construction
Less than
Significant
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February 2022
TRA -9 If Special Events are to take place prior to the
completion of Phase 3 construction, Phase 3 typical
operations traffic improvements will be completed or
the applicant shall provide a focused traffic analysis
with the Temporary Use Permit that identifies any
improvements that are not necessary to maintain
acceptable levels of service at study intersections. If the
City Planning &
Public Works
analysis does not demonstrate acceptable operations,
the TUP will be denied.
Department
Qualified Traffic
During Special
Events, prior
to Phase 3
Less than
Significant
TRA -10 If Special Events are to take place prior to the
construction of Phase 3, a special event traffic and
parking plan will be submitted with each Temporary Use
Engineer
Project Applicant
construction
Permit to ensure that special events will not cause any
significant traffic or parking impacts. If the analysis does
not demonstrate acceptable operations, the TUP will be
denied.
TRA -11 Traffic Management Plans will be submitted to the City
and the Police Department for review and approval prior
to special events. Timing for installation of traffic
management measures will be scaled to the size and
duration of the event. In general, signage for large
City Planning &
Public Works
events should be in place five days prior and two days
Department
30 days prior
following special events. The City and Police Department
to Special
Less than
may impose additional measures if determined to be
necessary. Individual management plans for specific
special events shall be submitted at least 30 days prior
to the start of the event. The special event Traffic
Police
Department
Project Applicant
Events
Significant
Management Plans shall include the measures identified
in Mitigation Measures TRA -12 through TRA -14 below.
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TRA -12 In developing the Special Event Traffic Management
Plan, the project proponent shall include the use of
Portable changeable message signs (CMS) or moveable
mechanical electronic message boards. CMS will be
located at critical locations identified by the La Quinta
Police Department (LAPD) and in place 5 days ahead of
the event and 2 days after.
TRA -13 In developing the Special Event Traffic Management
Plan the project proponent shall include the use of law
enforcement personnel and/or special event flaggers to
direct traffic in locations reviewed and approved by the
City and Police Department.
TRA 14 In developing the Special Event Traffic Management
Plan the project proponent shall include the use of
public service announcements (PSA) to provide
information to event guests and surrounding
neighborhoods prior to the event. Examples include
online event information, brochures and changeable
message signs that include details such as suggested
routes, drop-off and parking facility locations.
City Planning &
Public Works
Department
Police
Department
Project Applicant
During
development
of Special
Event Traffic
Management
Plan
Less than
Significant
TRA -15 The project proponent shall ensure that the proposed
Coral Mountain Interpretive Center trail designated by
the Desert Recreation District Master Plan and
associated with the future Coral Mountain Interpretive
Center is incorporated into project plans.
Accommodations for this trail shall be located along the
approximate toe of Coral Mountain, within the
designated conservation area at the southwestern edge
of the property.
City Planning
Department
Desert
Recreation
District
Project Applicant
Prior to
project
approval
Less than
Significant
Section 4.14, Tribal
Cultural Resources
TCR -1: Before ground disturbing activities begin, the applicant
shall contact the ACBCI Tribal Historic Preservation
Office to arrange cultural monitoring. The project
requires the presence of an approved Agua Caliente
Qualified
Archaeologist
Agua Caliente
Native American
Prior to
ground
disturbing
activities
Less than
Significant
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February 2022
4.0 MITIGATION MONITORING AND REPORTING PROGRAM
a. Cause substantial
adverse change in
significance of
tribal cultural
Native American Cultural Resource Monitor(s) during
any ground disturbing activities (including
archaeological testing and surveys). Should buried
cultural deposits be encountered, the Monitor may
Cultural
Resource
Monitor
resource that is
request that destructive construction halt in the vicinity
ACBCI Tribal
i. A site listed in
of the deposits, and the Monitor shall notify a Qualified
Historic
the CRHR or
Archaeologist (Secretary of the Interior's Standards and
Preservation
Local Register,
Tribal Cultural
Guidelines), within 24 hours, to investigate and, if
necessary, prepare a mitigation plan for submission to
Office
Resources
the State Historic Preservation Officer and the Agua
City Planning
ii. A resource
determined to
be significant to
a California
Native
American tribe.
Caliente Tribal Historic Preservation Office.
Department
Project Applicant
TCR -2: The presence of a qualified archaeologist shall be
required during all project related ground disturbing
activities, including clearing and grubbing. A monitoring
plan shall be prepared and approved by the ACBCI and
Qualified
Archaeologist
During all
provided to the City prior to the initiation of any ground
ACBCI
ground
Less than
disturbing activity for all construction phases and
City Planning
disturbing
Significant
activities. If potentially significant archaeological
materials are discovered, all work must be halted in the
vicinity of the archaeological discovery until the
archaeologist can assess the significance of the find.
Department
Project Applicant
activities
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February 2022
TCR -3: Before ground disturbing activities, the project's
archaeologist shall prepare an Archaeological
Treatment, Disposition, and Monitoring Plan to be
submitted to the ACBCI Tribal Historic Preservation
Office for approval. The Treatment, Disposition and
Monitoring Plan shall be deemed rejected by ACBCI's
Tribal Historic Preservation Office if no action to approve
the plan is taken within 30 days from submission for
approval. If the ACBCI Tribal Historic Preservation Office
rejects two Treatment, Disposition and Monitoring Plans
submitted for approval, the applicant may appeal the
second denial to the La Quinta City Council for a final
determination. The approved Treatment, Disposition
and Monitoring Plan shall be provided to the City prior
to any ground disturbance on the site.
TCR -4: Before ground disturbing activities, the project's
archaeologist shall prepare a Rock Art Management
Plan, based on recommendations made in the report by
McCarthy and Mouriquand, and shall submit the plan to
the ACBCI Tribal Historic Preservation Office for
approval. The Rock Art Management Plan shall be
deemed rejected by ACBCI's Tribal Historic Preservation
Office if no action is taken to approve the plan within 30
days of submission for approval. If the ACBCI Historic
Preservation Office rejects two Rock Art Management
Plans submitted for approval, the applicant may appeal
the second denial to the La Quinta City Council for a final
determination. The approved Rock Art Management
Plan shall be provided to the City prior to any ground
disturbance on the site.
Qualified
Archaeologist
ACBCI Tribal
Historic
Preservation
Office
City Planning
Department
City Council
Project Applicant
Prior to
ground
disturbing
activities
Less than
Significant
g
TCR -5: Sites 33-00193, 33-001715, and 33-009545, along the
base of Coral Mountain and at the toe of the slope,
which contains the rock art panels and bedrock milling
features, shall be avoided and protected in situ during
project construction through the establishment of
Qualified
Archaeologist
City Planning
Department
During project
construction
& Prior to
ground
disturbance in
Less than
Significant
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Environmentally Sensitive Areas; the Environmentally
Sensitive Areas shall be recorded on the property, and
proof of recordation shall be provided to the City prior
to any ground disturbance in Planning Area III.
Nominations of these sites to the National Register of
Historic Places shall be filed with the appropriate federal
agency prior to the issuance of the first grading permit;
and the sites shall be subject to the provisions of the
Rock Art Management Plan.
Project Applicant
Planning Area
III
TCR -6: For the portion of Site 33-001715 outside the
preservation area established in TCR -5, mitigative
surface collection and subsurface excavation shall be
completed prior to any ground disturbance in Planning
Area III to recover a representative sample of the
cultural materials prior to the commencement of the
project and as a condition of grading permit issuance.
The excavation shall include a combination of standard
archaeological units, shovel test pits, and backhoe
trenches to optimize both efficient coverage of the site
Qualified
Archaeologist
Prior to
area and safe recovery of cultural remains. The survey
protocols shall be approved by ACBCI. A report of
ACBCI
ground
disturbance in
Less than
findings, including written confirmation of completion to
City Planning
Planning Area
Significant
ACBCI's satisfaction, shall be provided to the City prior
to ground disturbance.
Department
III
TCR -7: Prior to ground disturbance in Planning Area III, a
qualified archaeologist shall complete surface collection,
testing and excavation if necessary, for sites 33-1716,
Project Applicant
33-1717, 33-8386, 33-9001, 33-9003, 33-28907, 33-
28908, 33-28909, 33-28910, 33-28911, 33-28912. A
report of findings, including written confirmation of
completion to ACBCI's satisfaction, shall be provided to
the City prior to ground disturbance.
TCR -8: A comprehensive recordation program shall be
Qualified
Prior to the
Less than
prepared by a qualified archaeologist for Site 33-008388.
Archaeologist
occupancy of
Significant
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The program shall contain detailed drawings and
measurements to preserve the information on the
adobe building. Such information would include the
floor plan, elevations, building materials and their
configurations, and any other notable structural and
architectural details. The adobe remains and an
appropriate buffer determined by the project
archaeologist shall be flagged and cornered off during all
ground disturbance and preserved in place. Prior to the
occupancy of any structure in Planning Area II, the adobe
will be fenced off and an informational plaque describing
the history of the ranch complex shall be provided, and
the project proponent shall provide the City with the
City Planning
Department
Project Applicant
any structure
in Planning
Area II
CC&Rs for the project area, demonstrating that the
feature would be maintained in perpetuity by the
project's Homeowners Association. Special attention
should be given to the residence foundation, which, may
be the remains of one of the earlier structures at the site,
dating from 1920s or before. The footings and slabs at
this location should be cleared and measured, and
attempts should be made to locate the original trash pits
or privies which could contain valuable artifacts
revealing much about life in the harsh environment at
such an early date. The scatter of artifacts has the
greatest number of pre -1925 artifacts, mostly in the
form of sun -colored glass, but also in brown and olive
glass, porcelain, ceramics and more. There may be
remains of an early structure near this point, hidden
amidst the broad stand of tamarisk trees, an original
windbreak. Search of these remains is required to
ensure the most complete recovery possible of the early
20th century artifacts and features. Photos,
measurements, and artifacts shall be catalogued,
analyzed, reported, and curated at the Coachella Valley
Museum (Love et aI.1998:54).
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February 2022
TCR -9: The applicant shall coordinate with ACBCI Tribal Historic
Preservation Office to ensure there are a sufficient
number of Native American monitors for the number of
earth -moving machinery for each phase of
development. The applicant shall provide the City with
fully executed monitoring agreements prior to each
phase of ground disturbing activity.
ACBCI THPO
City Planning
Department
Project Applicant
Prior to each
phase of
ground
dturbing
activity
Less than
Significant
TCR -10: Should human remains be inadvertently discovered
during ground disturbance, the provisions of California
Health and Safety Code Section 7050.5, and the CEQA
Guidelines Section 15064.5 shall be followed. In the
event of discovery or recognition of any human remains
in any location other than a dedicated cemetery, there
shall be no further excavation or disturbance of the site
the remains, or any nearby area reasonably suspected
to overlay adjacent remains, until the County Coroner
has examined the remains. If the coroner determines
the remains to be Native American or has reason to
believe that they are those of Native American, the
coroner shall contact the Native American Heritage
Commission within 24 -hours.
County Coroner
City Planning
Department
Project Applicant
During ground
disturbingof
activities
Less than
Significant
TCR -11: Prior to any ground disturbance, the applicant shall
sign a curation agreement with the ACBCI THPO. A fully
executed copy of the agreement shall be provided to the
City.
ACBCI THPO
City Planning
Department
Project Applicant
Prior to
ground
disturbing
activities
Less than
Significant
TCR -12: Prior to any ground disturbance, cultural sensitivity
training shall take place for all contractors with the staff
at the Agua Caliente Tribal Historic Preservation Office
(THPO).
ACBCI THPO
City Planning
Department
Project Applicant
Prior to
ground
disturbing
activities
Less than
Significant
Coral Mountain Resort Final EIR
4-25
February 2022