Loading...
Meridian Consultant (Locacciato, Tony) 2025-10-07 Turnbridge SRR Objecting to SAFER EA allegationsCITY COUNCIL MEETING - OCTOBER 7, 2025 - WRITTEN PUBLIC COMMENTS FROM TONY LOCACCIATO OF MERIDIAN CONSULTANTS CONSENT CALENDAR ITEM NO. 3 - ADOPTING ORDINANCE NO. 626 AT SECOND READING APPROVING DA 2025-0001 - REINSTATED AND AMENDED DEVELOPMENT AGREEMENT 2014-1001 FOR THE SILVERROCK RESORT PROJECTS RESPONSE TO COMMENTS REGARDING ADDENDUM NO. 3 TO MITIGATED NEGATIVE DECLARATION ADOPTED UNDER ENVIRONMENT ASSESSMENT 2002-453 FOR THE SILVERROCK RESORT PROJECT IVj1eridian 860 Hampshire Road, Suite P Westlake Village, California 91631 COnSU/tants Tel. 805.367.5720 October 7, 2025 City of La Quinta Design & Development Department 78495 Calle Tampico La Quinta, California 92253 Attn: Cheri Flores Planning Manager Re: 2025 SilverRock Resort Project Addendum Environmental Assessment 2025-0002 Development Agreement 2025-0001 Responses to Comments from SAFER Dear Cheri Flores, On October 6, 2025, Lozeau Drury, LLP submitted comments in support of an appeal filed by Supporters Alliance for Environmental Responsibility (SAFER) on the approval Environmental Assessment 2025-0002 (Addendum No. 3 to Environmental Assessment 2002-453) and conditionally approving Development Agreement 2025-0001, which were approved on September 22, 2025, for the 2025 SilverRock Resort Project Addendum (2025 Project). Meridian Consultants (Meridian) prepared the September 2025 Addendum to the 2002 MND adopted by the Cityforthe SilverRock Resort Project. Meridian also prepared the City's 2014Addendum to the Adopted 2002 MND. I also managed the preparation of the City's 2002 MND as well as the City's 2006 Addendum to the Adopted 2002 MND. Each Addendum the City prepared compared the revised Project to the project as defined and analyzed in prior documents and includes updated information on existing conditions as well as analysis of the changes to the Project. Meridian reviewed the comments in the October 6, 2025 letter from Lozeau Drury and responses to these comments are provided below. 1. Growth Inducement Lozeau Drury comments that the 2025 Project, as disclosed in the 2025 Addendum, would add 1,690 additional residents to the City of La Quinta and that this would represent a 9.9 percent increase in population, which would impact water supply, traffic, schools and other public services, air pollution and other impacts. Responses to Comments from SAFER 2025 SilverRock Resort Project Addendum October 7, 2025 Page 2 This comment, however, ignores the planning context for the Project as discussed in the Addendum. First, the City updated the La Quinta General Plan in 2013 (2035 La Quinta General Plan). The SilverRock Resort Project was originally approved in 2002, and in 2006, the City approved the SilverRock Resort Specific Plan to guide the development of the Project. The Specific Plan was reviewed in the 2006 Addendum to the Adopted MND. The 2025 General Plan incorporated the 2006 SilverRock Specific Plan. The City's Program ElRforthe 2025 General Plan provides a comprehensive assessment of the potential cumulative impacts from implementing the General Plan, including the SilverRock Specific Plan, as discussed in the 2014 Addendum to the original MND. The 2025 Project would reduce overall intensity of the uses allowed by the SilverRock Specific Plan, as detailed in Table 2-2, Comparative land Use Summary, Prior Environmental Review, and the 2025 SilverRock Master Plan, in the 20205 Addendum. As explained in the 2025 Addendum, the population estimate presented in the Addendum reflects a conservative approach that assumes all hotel and branded residential units operate as full-time residences. In contrast, the Previous Assessments treated these uses as seasonal and therefore did not attribute any growth in the City's permanent population. As described on page 3.0-8 of the Addendum, the 2025 Project would generate an estimated 1,690 residents. Given the City's 2025 population of approximately 38,796 and its projected 2050 population of 55,836—an increase of 17,040 residents over 25 years; the Project's contribution would represent only about 9.9 percent of the projected growth for the City, which reflects the City's 2025 General Plan as evaluated in the General Plan Program EIR and the 2014 and 20245 Addendums to the Adopted MND. As the 2025 Project reduces the intensity of the uses allowed by the SilverRock Specific Plan, which was incorporated into the City's General Plan, the potential increase in the City's population from the Project would not result in growth not anticipated for bythe City's 2035 General Plan and, for this reason, preparation of a Supplemental EIR to examine the potential impacts of this potential growth in the City's population is not warranted. 2. Traffic The comments state that the 2025 Project would generate more daily vehicle trips than identified in the 2002 Mitigated Negative Declaration (MND) and the Addendum does not evaluate potential transportation impacts in terms of Vehicle Miles Traveled (VMT), as currently required by CEQA. The comment compares the 2025 SilverRock Resort Project to the project as defined and analyzed 2002 MND and ignores the updated traffic analysis provided in the 2006, 2014 and 2025 Addendums to the 2002 MND. Each of these Addendums evaluates changes to the Project as defined and analyzed in the 2002 MND. As documented in the 2025 Addendum (Table 3.6-1), the Project would generate fewer total daily vehicle trips than the 2018 Project and does not increase roadway capacity demands or result in new significant impacts related to LOS or traffic safety. The overall development intensity, including hotel keys, residential units, and commercial space, has been substantially Responses to Comments from SAFER 2025 SilverRock Resort Project Addendum October 7, 2025 Page 3 reduced from prior approvals. For this reason, the Project would not result in new or more severe traffic impacts beyond those previously analyzed. All prior mitigation measures and conditions of approval remain applicable. Therefore, pursuant to CEQA Guidelines §15162 and §15164, preparation of an Addendum is appropriate. Because the M ND for the Project was adopted prior to July 1, 2020, it analyzed transportation impacts using LOS, which was the required CEQA metric at the time. The change in CEQA Guidelines Section 15064.3 designating VMT as the primary significance threshold does not apply retroactively to previously adopted CEQA documents based on the Court of Appeal decision in Olen Properties Corp. v. City of Newport Beach (2023) 93 Cal.App.5th 270. In addition, as discussed above, the 2025 Project reduces the intensity of land uses and vehicle trips from the project at previously approved. Accordingly, VMT would also be reduced in comparison to the Project as previously approved. For these reasons, preparation of a VMT analysis is not required. 3. Biological Impacts The comments provided include photographs of wildlife within four miles of the Project Site is support of comments that development of the 2025 Project would impact the wildlife in the area. The photographs and brief reconnaissance -level site visit described in the comments do not constitute substantial evidence under CEQA to refute the Addendum's conclusions. Under CEQA Guidelines §15384, substantial evidence must consist of facts or expert opinion supported by facts, not unverified observations, or speculation. While the photographs include certain wildlife species identified as special -status species, the mere observation of individual animals within or adjacent to a previously developed and landscaped site does not indicate a new or more severe biological impact. The Project Site consists of areas previously graded for golf and resort uses, partially developed with the City's existing golf course and partially constructed buildings, and is designated as "Developed/Disturbed" and "Golf Course" land by the Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP). The Project remains fully consistent with the CVMSHCP and continues to implement all applicable avoidance, minimization, and mitigation measures, including payment of conservation fees that provide regional habitat compensation for covered species. No new natural habitat would be disturbed, and no evidence indicates that the Project would result in take, habitat loss, or population -level effects on any special -status species. Courts have consistently held that short-term observations or photographs, without supporting survey data, do not constitute substantial evidence of a significant impact (Anderson First Coalition v. City of Anderson (2005) 130 Cal.App.4th 1173; Bowman v. City of Berkeley (2004) 122 Cal.App.4th 572). Responses to Comments from SAFER 2025 SilverRock Resort Project Addendum October 7, 2025 Page 4 Based on the analysis and conclusions presented in the 2025 Addendum to the MND, the potential impacts of the 2025 Project on special -status species have been accurately and adequately addressed, and the 2025 Project will not result in any new or substantially more severe significant environmental effects than those previously analyzed. Accordingly, preparation of a Supplemental EIR is not required. 4. Air Quality The comments state that due to the increase in population and traffic, the 2025 Project would exceed the Project's volatile organic compound (VOC) threshold of 55 pounds per day (ppd). As discussed in the Growth Inducement and Traffic sections above, the 2025 Project would reduce overall land use intensity compared to the Previous Assessments, would induce only planned population growth consistent with the City's General Plan, and would generate fewer vehicle trips than the 2018 Master Plan. The comments further assert that the 2025 Addendum substantially underestimates Project VOC emissions based on land use intensity, concluding that total VOC emissions would be 65.4 ppd, which is above the CEQA significance threshold of 55 ppd. One comment claims the landscaped golf course area (361 acres or approximately 15.7 million square feet) was set to zero in the Ca1EEMod air emissions modeling completed for the Addendum, resulting in no estimated VOC emissions from fertilizer and pesticide application. The 361 acres include the existing 161-acre Arnold Palmer Golf Course and a second proposed approximately 200-acre 18-hole golf course. The existing 161-acre portion was intentionally set to zero in CaLEEMod because it is a fully developed and operational facility that has been analyzed in previous CEQA documents. The 2025 Addendum appropriately evaluates only new development and improvements; not routine maintenance activities associated with the existing golf course. Regular landscaping and turf management practices are part of the environmental baseline and do not constitute new sources of emissions attributable to the current Project. Including those emissions again would have resulted in double -counting impacts already evaluated and occurring under existing conditions. It should also be noted that none of the Previous Assessments identified exceedances of South Coast Air Quality Management District (SCAQMD) daily thresholds for construction or operation. In the Tables 3.5-1 and 3.5-2 of the 2014 Addendum, the applicable SCAQMD VOC thresholds were 75 ppd, with maximum daily emissions of 72.4 ppd during construction and 65.6 ppd during operation — both below the threshold. Even when applying Mr. Sutton's overestimated figure of 65.4 ppd, the 2025 Project would not substantially emit levels significantly above the Previous Assessment. Therefore, no further analysis is warranted. Responses to Comments from SAFER 2025 SilverRock Resort Project Addendum October 7, 2025 Page 5 5. Valley Fever The comments state that the Addendum does not analyze potential Valley Fever impacts. These comments contain only generalized statements regarding Valley Fever risks and reported increases in cases across Riverside County in 2024 but provide no site -specific data demonstrating the presence of Coccidioides fungus on the Project site or any aspect of the 2025 Project that would exacerbate such risks in the City of La Quinta. The Project Site has already been mass graded and that completion of construction under the 2025 Project would reduce dust, blow sand, and soil erosion relative to current conditions. Additionally, Valley Fever is not a required environmental topic under the CEQA Guidelines Appendix G Environmental Checklist. CEQA requires analysis of environmental effects caused by a project, not naturally occurring diseases that may exist in a region. Potential exposure to Coccidioides spores is a regional public health issue, not an environmental impact attributable to project -specific emissions or land use. As such, Meridian finds that the 2025 Addendum appropriately addresses dust -related emissions through compliance with SCAQMD Rule 403 (Fugitive Dust) and existing air quality mitigation measures (MM AQ-1 through AQ-4), and that no new or more severe impacts related to Valley Fever would occur under CEQA. 6. Formaldehyde Comments state that development of the proposed new residential and commercial buildings would result in significant formaldehyde exposure. With respect to the claim of indoor air quality risks associated with formaldehyde, the comments do not provide substantial evidence of any new or substantially more severe environmental effects than those analyzed in the previously adopted MND. The comments contain only generalized statements about potential cancer risks from building materials but provide no site -specific information regarding the 2025 Project or the materials that would be used for project development. Moreover, the submission fails to acknowledge that the 2025 Project would substantially reduce the total amount of building square footage developed and occupied on the Project Site compared to the prior analysis, thereby further reducing any potential for indoor air quality emissions. The concern regarding formaldehyde exposure is also unfounded. The 2025 Addendum's air quality analysis and health risk assessment appropriately address emissions of volatile organic compounds (VOCs), including formaldehyde, within the modeling and mitigation framework established by the South Coast Air Quality Management District (SCAQMD). Construction and operational emissions were modeled using CaLEEMod v2022.1, which accounts for VOC emissions from architectural Responses to Comments from SAFER 2025 SilverRock Resort Project Addendum October 7, 2025 Page 6 coatings, consumer products, and combustion sources consistent with SCAQMD Rules 1113 and 1144. These rules impose strict VOC limits on building materials and coatings, effectively minimizing potential formaldehyde emissions. As shown in Tables 3.5-2 and 3.5-3 of the Addendum, the Project's total VOC emissions are well below the SCAQMD significance threshold of 55 pounds per day, confirming that formaldehyde exposure would remain less than significant. Additionally, Title 24 Building Energy Efficiency Standards and the CalGreen Code regulate indoor air quality and limit off - gassing from composite wood and finish materials. Based on this substantial evidence, the City finds that the Proposed Project Modifications would not result in any new or more severe impacts related to formaldehyde exposure under CEQA Guidelines §15162. Conclusion As the responses above demonstrate, the Addendum adequately assesses the potential for significant impacts from 2025 SilverRock Resort Project, which is consistent with the prior assessments and no further environmental review is required for this project under the standards in CEQA and the CEQA Guidelines. Sincerely, Meridian Consultants Tony Locacciato, AICP Partner