NOISE STUDY COMMENT LTR 2020-01-30
January 30, 2020
Mr. Garrett Simon
CM Wave Development LLC
2440 Junction Place, Suite 200
Boulder, CO 80301
SUBJECT: NOISE IMPACT ANALYSIS COMMENTS FOR THE WAVE PROJECT
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 the initial review of the Noise Impact Analysis submitted for the above-
referenced project and has the following comments (please note that we have used “first
instance” when referencing comments to note that the discussion occurs elsewhere in the report,
and that the same changes need to be made at multiple locations):
1. The noise study will need to be amended based on changes expected to the traffic impact
analysis. This will include analysis of special event noise levels. Please review for
consistency once the traffic study is complete.
2. The noise study refers to “The Wave-Coral Mountain” as the project. Please modify the
project description to reflect the newly added “new” Specific Plan, the Specific Plan
Amendment to Specific Plan 03-097, Andalusia at Coral Mountain, the General Plan
Amendment, Change of Zone and Tentative Tract Map. Please also note that references to
Planning Areas will need to be modified now that the project will be governed by an
independent Specific Plan. Presumably, for example, references to Planning Ar ea VIII will
change.
3. References to a “pop-up village park” need to be defined. Please also see comments on this
subject made in the Specific Plan text.
4. Please delete the second paragraph of the Executive Summary. The reference to Ballona is
inappropriate. The impacts of the project components on future residents of the project are
appropriate and will be analyzed in this study and CEQA documents.
5. Page 2 (first instance): The description of the prescribed barrier includes a statement that if
the roadway occurs above the grade of the home, the barrier must be 6 feet from the
highest point on the road. The City’s standard does not allow for walls beyond 6 feet, and
the Specific Plan proposes 8 feet in PA VIII. The noise study needs to clearly state that the
barrier proposed will fit within those standards, and if it does not, will need to be reflected
in the CEQA document as a potentially significant impact.
6. Page 3 (first instance): Operational noise mitigation cannot use “may.” Mitigation is
required, and therefore mitigation measures need to be required, not suggested. Please
rephrase to make clear what the mitigation requirements are, not what they may be. Also
see related comments below.
7. Page 4 (first instance): Both construction noise and vibration need to address not only
impacts to surrounding properties, but also impacts to sensitive receptors within the
project, because the project will be constructed in phases. Therefore, the analysis needs to
include the impacts on phase 1 sensitive receptors of phase 2 construction activities, and
so on through build out of the project. Also see specific comments below.
8. Page 20: Please remove the reference to nursing home uses. There is no nursing home
proposed. Instead, add a reference to the appropriate noise levels for hotels.
9. Page 23: Open Section 3.6 with a sentence that states that the City does not have a
vibration standard, and that the County standard was therefore used.
10. Page 25: First paragraph after lettered list, remove Guidelines after General Plan. Change
Guideline A and Guideline C to Significance Criteria A and C later in the paragraph.
11. Page 25: First paragraph in Section 4.2, please delete the last sentence.
12. Page 26: The use of a court case out of context is inappropriate. Please delete the first
sentence, and rework the paragraph to explain the exceedance. In addition, if the project
results in a noise level in excess of 65 dBA at any sensitive receptor, that is an impact that
requires mitigation, regardless of the level of increase. That needs to be made clear. Also
correct the discussion on page 27 and in Table 4-2 in this regard.
13. Page 30: Madison Avenue should be Madison Street; Cll Conchita should be Calle Conchita.
14. Page 37, Table 6-1: Please add to footnotes where roadway classifications are not City of
La Quinta.
15. Page 54: Last paragraph. The paragraph appears to indicate that the only impact that
matters is the long term (build out) or year 2040 impact. That is not correct. If the
implementation of Phase 1 results in a noise level increase that either is greater th an 3 dB
or which exceeds 65 dBA at a sensitive receptor, that impact must be mitigated. Please
delete the paragraph and replace with a discussion of the impacts of each phase of
development, and that analysis was conducted to determine whether each phase w ould
impact surrounding sensitive receptors.
16. Page 56: Last paragraph. The paragraph is incorrect. The conclusion should be the same as
existing conditions plus project – that the condition could not occur.
17. Section 10: This section deals only with off-site receptors. There is no discussion on noise
levels within the project. Since sensitive receptors will occur adjacent to the surf wave,
hotel and recreational areas, noise levels at interior receptors must be demonstrated, and
mitigation measures provided if necessary.
18. Page 75: Section 10.1.1 should be based on noise measurements at the existing facility in
Lemoore, CA. If that is the case, please modify the text to explicitly state this. If it is not,
we will need to discuss, and a more substantial description of how noise levels were
determined will need to be provided. In addition, the statement “the applicant has
established exterior noise limits…” is unsubstantiated, and without inclusion as mitigation in
the noise analysis and environmental document, cannot be relied on as any more than an
assumption. Either include these limits as mitigation measures in the noise study, or
remove the discussion from the document.
19. Page 76: Section 10.1.4 must define the outdoor game field activities based on land uses
provided in the Specific Plan. As currently described in the Specific Plan, no such activities
are allowed.
20. Page 80: The need for night-time mitigation cannot be stated in terms of “may include.”
Please re-write this section to provide required mitigation measures, and also demonstrate
that these mitigation measures will result in less than significant impacts by quantifying the
reduction.
21. Section 11: This section only considers construction noise and vibration impacts to off-site
receptors. Since this project is to be built in phases, residents of Phase 1 will be impacted
by Phase 2, and so on. Please add a quantified analysis of the impacts to early phase
sensitive receptors from later phase construction, and mitigate as needed.
If you have any questions please contact me at ncriste@terranovaplanning.com, and/or at
(760) 777-7132 or (760) 341-4800. When these comments have been addressed, please
resubmit the noise study for a second review.
Sincerely,
Nicole Sauviat Criste
Consulting Planner