TRAFFIC IMPACT ANALYSIS COMMENT LTR 2019-12-12
December 12, 2019
Mr. Garrett Simon
CM Wave Development LLC
2440 Junction Place, Suite 200
Boulder, CO 80301
SUBJECT: TRAFFIC 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’s Traffic Engineer and Planning staff have completed the initial review of the Traffic
Impact Analysis submitted for the above-referenced project and have the following comments:
1. The Specific Plan Amendment is for the entire Specific Plan area, on both the west and east
sides of Madison Street. Please modify the TIA to look at the entire Specific Plan area,
including the existing development’s trips and movements, the potential additional trips
and movements from build out of the east side, and the new trips and movements on the
west side.
2. The TIA project description is not adequate. Please modify to describe the following:
a. The entirety of the Specific Plan area, as described in #1, above.
b. The project description inconsistencies with the Specific Plan Amendment (SPA) and
Phase descriptions:
i. The project description adds up to 600 housing units, the phasing description 592
units, and the SPA 750 units. The TIA must analyze maximum potential
development based on the SPA, and provide for existing and future units on the east
side of the SPA. If the east side of the SPA is currently calculated in the cumulative
project analysis, it must be removed from that analysis and added to the project
analysis. Adjustments to the overall trip generation for the project will result. Please
see related comments below. Please note that this will change not only total project
numbers, but phase quantities as well.
c. Please include a description of the General Plan Amendment and Zone Change proposed
(including descriptions and exhibits of existing and proposed land use and zoning
designations) to support the General Plan buildout analysis.
d. The Specific Plan allows short term vacation rentals and calls them out specifically.
Please include the number of short term rentals, and their associated trip generation
characteristics (as opposed to standard residential units) in the analysis.
e. Please add specificity regarding the wave pool use:
i. It is unclear if the wave pool is to be open to the public. Based on trip generation
and the accompanying description on page 35, it appears that this is not the case,
since the only external trips anticipated are for “off-site lunch, wave pool
employees, etc.” If the surf pool is private, it must be so stated. If the surf pool is
open to the public, the trip generation rate will need to be adjusted (see #3 below).
ii. The average number of attendees per day on a typical day, a weekend day and a
special event day.
iii. There is no description of special events at the wave pool. Please describe the
special events at the wave pool and analyze them in terms of attendees, distance of
travel, typical duration, anticipated number of events per year, etc. A separate
analysis of special events under EAP, EAPC and General Plan buildout conditions
must be provided. Please note that if special events affect freeway interchange(s)
(based on City and Caltrans standards), these interchange(s) will need to be
analyzed.
3. The trip generation should be modified. As we discussed in our first meeting, Urban
Crossroads completed a Traffic Impact Analysis (TIA) for a resort surf wave pool project in
2019. The trip generation for that project was developed based on analysis of TIAs for
similar projects in other locations, attendance at the surf pool, and other factors. That trip
generation rate would appear to be more appropriate and should be used here, rather than
using rates for a generic recreational facility. It may need to be modified based on the
characteristics of the project, as described in #2, above. Additionally, the internal capture
reduction must be explained (with supporting logic) based on the revised project
description, since the TIA assumes a 50% internal capture reduction for the surf pool. Since
it appears that the trip generation is currently too low, it is likely that an increased trip
generation will generate a lower internal capture rate. Please note that if the trip
generation rises, and additional outlying intersections are affected (per City standard), they
will need to be added to the analysis.
4. The TIA must demonstrate that there is sufficient separation, per City standards, between
intersections (both signalized and unsignalized) on Madison Street and along Avenue 58. If
minimum intersection spacing is not provided, its adequacy must be analyzed.
5. The TIA must clearly state that analysis was completed in conformance with Engineering
Bulletin 06-13 and reference the requirements of the Bulletin throughout.
6. At multiple locations in the TIA, the discussion regarding impacts to the intersection of
Avenue 52 and Jefferson seems inadequate. The intersection is fully within the City of La
Quinta, so any preference by the City of Indio would not be relevant here. Although La
Quinta has in the past considered a single lane roundabout to be preferred, if the project
requires a second lane to preserve acceptable LOS, this needs to be considered and
analyzed, and mitigation measures proposed. (the nearby intersection of Jefferson / Ave 53
is proposed to be designed and built with 2 lanes NB and SB as example.) If feasible
mitigation exists (which may include redesign of the roundabout), it cannot be assumed
that failure will continue. Alternatively, if the TIA, when revised, still shows failure at this
intersection, the project will be required to prepare an Environmental Impact Report, and
the City will need to consider adoption of Findings and a Statement of Overriding
Considerations.
7. Assumptions regarding fair share allocations also seem inadequate. If the project triggers
the need for a traffic signal, the required signal will be installed by the project, and
reimbursement to the project’s developer may be provided for all but the project’s share by
future developments, or CIP, or DIF, etc. Where this condition occurs, the fair share would
be the project’s percentage of traffic on that intersection at the time the impact occurs, not
at 2040 traffic conditions. If the intersection fails with or without project, the project’s fair
share would be the difference between without and with project volumes at the Phase when
the intersection fails, not at 2040 conditions. The TIA also needs to include an analysis of
when in project phasing each signal is required, when it is funded and scheduled for
installation in the CIP, and whether the CIP schedule will meet project needs. If these do
not mesh, appropriate mitigation measures must be included in the TIA.
8. The TIA references “recommendations” which are actually mitigation measures. Please
provide a Mitigation Measure section, use “shall” instead of “should,” and tie the
construction of improvements to specific project events (initiation of grading, initiation of
construction, issuance of 1st, 10th, 100th building permit/certificate of occupancy, etc.).
Please also remove references to “when warranted”, as they represent deferred mitigation,
which cannot occur under CEQA.
9. The Main Project Access and Madison Street requires a traffic signal at General Plan build
out. Please add a mitigation measure to that effect.
10. Please provide a complete list of all improvements required by Phase, including road
widening, raised medians, sidewalks, landscaping, additional lanes, traffic signals,
interconnect, etc. in a tabular format, with trigger points (as enumerated in #8 above). The
TIA must clearly show in one central location, all improvements required by the project and
when they will be undertaken.
11. Throughout the document, please assure that references to the appropriate scenarios are
made. For example, at the end of Section 1.5.3, which is a discussion of EAP conditions,
EAPC is referenced.
When these comments have been addressed, please resubmit the traffic study for a second
review.
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