AIR QUALITY & GREENHOUSE GAS COMMENT LTR 2020-01-10
January 10, 2020
Mr. Garrett Simon
CM Wave Development LLC
2440 Junction Place, Suite 200
Boulder, CO 80301
SUBJECT: AIR QUALITY AND GHG REPORT REVIEW COMMENTS
GENERAL PLAN AMENDMENT 2019-0002
ZONE CHANGE 2019-0004
SPECIFIC PLAN 2019-0003 (AMENDMENT 5 TO SP 03-067)
TENTATIVE TRACT MAP 2019-0005 (TTM 37815)
MASTER PROJECT 2019-0004
Dear Mr. Simon,
The City has completed its review of the air quality and greenhouse gas emissions reports, and
has the following comments. When the studies are revised and resubmitted, please provide the
Project’s CalEEMod excel file for review in addition to the responses to this memo.
In general, the Air Quality and Greenhouse Gas Reports analyzed Project emissions against the
appropriate SCAQMD thresholds. However, there are questions regarding CalEEMod inputs and
emission projections for the Project.
1. Construction Hauling
Currently, the Air Quality and Greenhouse Gas Reports do not account for “hauling” emissions
because “earthwork activities are expected to balance on site and no import or export of soils
would be required” (AQ Report, pg 27). Two comments:
A. The preliminary grading plan shows a subtotal cut/fill of 896,838 CY/918,759 CY
with an import of 21,920 CY (see screenshot below). If the cut and fill calcs
balanced on-site, that would still require an import of 21,920 CY, which was not
accounted for in the construction hauling emissions and will require a re-run of
CalEEMod. Haul trips should consider actual haul locations to determine miles per
haul. CalEEMod assumes a 20-mile haul trip, one-way. This may need to be
adjusted for accuracy. Also, the CalEEMod re-run will need to be specific about
which Phase(s) will require material import.
B.It is unclear how the balanced earthwork material is divided amongst the three
separately phased site plans and whether or not this division would have an impact
on material being hauled from one phase area to another. This could potentially
result in a 0.3-0.75-mile haul trip depending on the location of earthwork and
stockpile area. For example, Phase 1 will generate substantial cut in order to dig
the wave pool. If all cut is to remain on Phase 1 property, the analysis is adequate,
but an explanation must be added. If, on the other hand, Phase 1 cut is being
moved to Phase 3 property, hauling must be incorporated into the analysis. Please
provide further explanation and re-run CalEEMod, if necessary.
2.Sensitive Receptors
The sensitive receptor analysis in the Air Quality Report does not consider the addition of Phase
1 sensitive receptors (new residences, hotel guests) when Phases 2 and 3 are being constructed.
The Air Quality Report, specifically section 3.6 Localized Significant – Construction Activity,
should be updated accordingly to include the sensitive receptors present on the property when
each subsequent phase is constructed.
3.Vehicle Miles Traveled (VMT)
It does not appear that a VMT analysis was prepared, or a general VMT assumption made, for
the hotel and wave pool land uses. Default VMTs (CalEEMod) were used in both reports that are
similar to those of residential and commercial land uses (5.4 – 12.5 miles per trip), which is
equivalent to traveling from Palm Springs. It is anticipated that the wave pool and hotel will
attract regional attention, meaning passenger vehicles would likely be traveling from greater
distances such as the Los Angeles or San Diego areas, which are approximately 130 miles west
of the Project area. The default trip miles do not adequately account for emission impacts
associated with the typically long-distance travel associated with hotel uses or the proposed
wave pool. Therefore, the air quality and greenhouse gas emission projections and impacts
should be reevaluated to include VMTs more appropriate for the hotel and wave pool land uses.
4.Project Buildout Year
The following paragraph is located on page 43 of the Greenhouse Report:
“As previously noted, the 2017 Scoping Plan identifies a reduction target of 40% below 2020
levels by 2030. As such, the appropriate reduction target for 2030 would be 2.88 MTCO2e/yr.
For analysis purposes herein, the SP threshold for the Project’s buildout year of 2026 was
calculated by linear interpolation between the 2020 target of 4.8 MTCO2e/yr and the 2030 target
of 2.88 MTCO2e/yr. As such, the target for the Project’s buildout year of 2021 is 3.65
MTCO2e/yr.”
Please confirm if the buildout year cited in the last sentence is in fact 2021, or if it is supposed
to be 2026. Please recalculate SP threshold and reassess Project impacts for 2026 if necessary.
5. Wave Pool Energy Demand and Emissions
It is unclear if the energy demand and emissions of the wave pool equipment was accounted for
in CalEEMod. The wave pool will have an unusually high energy demand which should be
calculated based on existing operations at other facilities. Please provide further analysis and
explanation of this energy demand. Re-run CalEEMod with Project-specific energy demand
numbers, if necessary.
6. Wave Pool Water Demand and Emissions
It is stated that water demand projections are based on default CalEEMod values for a
“recreational swimming pool” (CalEEMod output notes for Phase 3 Operations). Intuitively, this
assumption is incorrect because it does not account for wave pool daily water loss,
evapotranspiration for a pool of the proposed size, annual cleanings or repairs that may require
full drainage and re-fills, etc. Further analysis should be conducted for water demand (which
should be consistent with the Water Supply Assessment for the project) and specific water
demand calculations should be applied to CalEEMod.
7. New “Vehicle Trips” Values in CalEEMod
It is unclear why the following defaults were adjusted in CalEEMod. Please provide further
explanation. Below is a screenshot of an example (from left, default values in 3rd column and
new values in 4th column).
8. Special Events
The Air Quality and Greenhouse Gas Reports did not analyze impacts from special events, which
would generate significantly higher mobile-related emissions. The Air Quality and Greenhouse
Gas Reports shall be updated to include a new CalEEMod run and analysis of special events using
daily trips and trip rates consistent with the Traffic Impact Analysis.
If you have any questions please contact me at ncriste@terranovaplanning.com, and/or at (760)
777-7132 or (760) 341-4800.
Sincerely,
Nicole Sauviat Criste
Consulting Planner