1983: RDA area 1 - EIR Final Comments - Nov. 14, 19834
LA QUINTA REDEVELOPMENT PROJECT
FINAL ENVIRONMENTAL IMPACT REPORT
STATE CLEARINGHOUSE #83072017
RESPONSES TO COMMENTS
ON DRAFT EIR
PREPARED FOR
LA QUINTA REDEVELOPMENT AGENCY
78-105 CALLE ESTADO
LA QUINTA, CA 92253
PREPARED BY
LSA, INC.
500 NEWPORT CENTER DRIVE, SUITE 600
NEWPORT BEACH, CA 92660
(714) 640-6363
NOVEMBER 14, 1983
RESPONSES TO COMMENTS FROM
THE EPA E,
THE RES UR ES AGENCY, STATE OF CALIFORNIA
COMMENT
0
We have received the Draft EIR for La Quinta Redevelopment Project No. 1,
prepared for the La Quinta Redevelopment Agency. The project involves flood
control improvements in the city of La Quinta located in the Coachella Valley
of Riverside County.
Of primary concern to the Department of Fish and Game are potential
impacts to riparian zones and to the habitat of the rare Peninsular bighorn
sheep (State rare) associated with the Upper Bear Creek drainage of the Santa
Rosa Mountains. We believe that flood control Alternative 1 would offer the
least detrimental impacts to existing wildife values located within this por-
tion of the redevelopment zone. Additionally, it is important to recognize
that the growth -inducing impacts of flood control features may adversely
impact the remaining sand dune habitat of the Coachella Valley fringe -toed
lizard located within the redevelopment zone. We believe this potential
impact can be greatly reduced, however, by careful land use planning directed
at minimizing impacts to this State endangered species.
The measures included in the Draft EIR to reduce potential wildlife
impacts should be specifically included as conditions of approval in the Final
EIR. We also encourage early consultation and coordination with the Depart-
ment in planning and implementing flood control Alternative 1. We believe
such an approach would facilitate necessary flood control measures as well as
provide for the necessary conservation of existing important wildlife
resources.
M RESPONSE
We agree with your concern of protecting, to the extent possible, the
riparian zones and habitats for'the Peninsular bighorn sheep and Coachella
Valley fringe -toed lizard. Impacts to these resources will be reduced by
implementing the mitigation measures in the DEIR (Pages 74-77), to a lesser or
greater extent, depending on the flood control alternative selected and the
rate of growth that will occur in the project area. As identified 'in Mitiga-
tion Measures 25 and 26, future mitigation plans and zoning will be developed
to provide protection for these resources. Mitigation Measure 47 (Page 91,
DEIR) suggests a growth monitoring program to measure the cumulative impacts
from new development.
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RESPONSES TO COMMENTS FROM
T ON
THE RESOURCES AGENCY, STATE OF CALIFORNIA
COMMENT
The La Quinta Redevelopment Plan encompasses an area of 17.5 square
miles, and includes the existing urbanized area of La Quinta (DEIR, Page 2,
however, indicates that the project area is 18.5 square miles, conflicting
with the vicinity map on Page 4, which shows an area of 17.5 square miles).
Of this area, 2,786 acres are currently in agricultural production. According
to the draft U.S. Department of Agriculture -Soil Conservation Service/Cali-
fornia Department of Conservation Important Farmland Map for this area,
effectively all 2,786 acres are "Prime" farmland. Approximately 79% or 2,206
acres of this farmland will be converted to non-agricultural uses by the proj-
ect (DEIR, Pages 13 and 46).
The DEIR recognizes that the irreversible conversion of over 2,206 acres
of prime agricultural soils represents "a significant adverse impact" (DEIR,
Page 46). The discussion of mitigation, however, fails to adequately address
this impact. The Department does not consider using the displaced farmland's
irrigation water to create replacement farmland elsewhere realistic mitigation
(DEIR, Page 89). Such a water transfer would probably involve the construc-
tion of new water delivery systems, would require very large amounts of capi-
tal investment, and could create adverse environmental impacts of its own.
While it is a suggestion with merit, it appears to be outside the lead agen-
cy's scope to require this as a mitigative measure.
To approve the project in the absence of any feasible mitigation of the
farmland conversion impact, the lead agency would have to show in the record
the overriding positive impacts of the project. The DEIR does not appear to
provide such documentation. If overriding considerations are pertinent to
this project, such as an existing or projected regional need for housing or
jobs, they should be documented and balanced against the permanent loss of
productive agricultural land.
RESPONSE
Comment so noted. In approving the redevelopment project, the City must
recognize the significant adverse impact that will occur from the loss of
® prime agricultural soils. Any infeasible mitigation measures stated in the
DEIR must be disregarded in favor of the overriding positive considerations
that would result from implementation of the project. This action occurs when
a statement of findings is adopted in approving the project.
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COMMENT
Further analysis should be included in the Final EIR regarding the impact
of this project on the local and county agricultural economy. The Coachella
Valley's agricultural history is well known, yet the DEIR states that agricul-
ture may no longer be economically vital (Page 2). Such a claim should be
documented.
RESPONSE
The statement on Page 2 implies that tourism is rapidly becoming a popu-
lar attraction in the Coachella Valley due to its mild winters. Consequently,
local business is focusing on the economic potential of seasonal tourism.
This is not to say that agriculture is not economically viable, rather that
the area is becoming well known for vacationing and weekend resort tourism.
COMMENT
Based on the County's Agricultural Crop Report for 1981 (compiled by the
County Agricultural Commissioner's Office) and multipliers developed by the
University of California's Cooperative Extension ("Economic Impacts of Agri-
cultural Production and Processing in Stanislaus County," March 1981), we
roughly estimate the annual fiscal losses to the area, due to the conversion
of 2,206 acres of agricultural land, to be the following:*
Project
Average
Farmland Acreage
Annual Fiscal Losses
Valuation/
to be Converted
Due to Project Farm -
Crop
Acre**
(by Assumed Crop) Multiplier
land Conversion
Alfalfa hay
$ 560
1,103 acres 2.4
$ 1,482,432
Grapefruit
3,000
1,103 acres 3.8
12,574,200
Total
2,206 acres
$14,056,632
* Based on 1981 dollars.
**Per -acre value for grapefruit is a weighted average for desert and summer
grapefruit, and includes the value of grapefruit by-products.
The average production value per acre for the 2,206 acres of active agri-
cultural land slated for conversion is $6,372 per year. This assumes that
a
half of the acreage is in alfalfa pasture and the other half is in grapefruit
production. Though these figures may not accurately reflect existing crop
patterns, they do reflect a realistic model, based on the California Depart-
ment of Water Resources 1978 land use maps for the La Quinta area.
The Final EIR would be more complete if it were to include an analysis
similar to that presented above, utilizing more accurate and up-to-date
information on crop patterns, acreages, and production values. We recommend
that such an analysis include both possible values for potential agricultural
lands and actual values for active "Prime" agricultural lands. Impacts on
lands adjacent to the project area should also be included.
RESPONSE
According to CEQA Guidelines, as amended August 1, 1983, Section 15131,
"Economic or social information may be included in an EIR or may be presented
in whatever form the agency desires." The DEIR has excluded reference to the
assessment of economic data as it is beyond the scope of the environmental
analysis for this project. As future development projects are proposed on
agricultural lands, the City may, at its discretion, desire detailed economic
assessments documenting the loss of land to agricultural production versus the
gain in other revenues or benefits.
COMMENT
We believe that the recommendations offered in the DEIR for mitigating
the impacts of farmland conversion are not reasonable. Neither the creation
' of replacement farmland elsewhere, nor the boosting of yields on remaining
farmlands to compensate for lost production, will mitigate the actual loss of
producing and non -producing "Prime" farmland from the state agriculture
resource base.
' RESPONSE
Comment noted. See response above regarding the adoption of overriding
considerations to the project and making findings where mitigation measures
are infeasible.
COMMENT
The DEIR discusses three alternatives to the proposed project:
1. No project.
2. .Retain in agricultural production.
3. Project developed with more intense uses.
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Given the apparent worsening urban blight conditions, and the existing
flooding hazards, the "no -project" alternative does not seem realistic. On
the other hand, the substantial conversion of productive agricultural lands
that would accompany this project would be extremely damaging. As such, we
recommend adoption of Alternative 2, an option that allows redevelopment while
preserving existing "Prime" farmland.
We recommend, therefore, that the Final EIR include a detailed analysis
of Alternative 2, including analysis of impacts and the necessary mitigation
measures. Particularly, the impacts resulting from the interface of conflict-
ing land uses that would result if Alternative 2 were adopted need to be
addressed. Such impacts include, but are not limited to, dust, field access,
noise, and pesticide drift onto residential neighborhoods. Measures necessary
to mitigate these kinds of impacts may include such approaches as setbacks,
walls, windbreaks, and buffer zones.
RESPONSE
The redevelopment project would become infeasible if the lands that are
currently in agricultural production were withdrawn from the project area or
were not developed according to the summary description on Page 13 of the
DEIR. The revenues received from the future tax increments generated by these
proposed developments are essential to implementation of the Redevelopment
Plan and blight elimination. Funding of flood control improvements, as iden-
tified in the Redevelopment Plan, is contingent on orderly development of the
project area, including those lands currently in agricultural production.
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RESPONSES TO COMMENTS FROM
THE CITY OF LA QUINTA
COMMENT
LM
The City has the following comments on the above -mentioned document.
Page numbers are included in parentheses.
Redevelopment Plan Map (12). The following changes should be made:
Designate that area included within Specific Plan No. 121-E Revised; change
that area designated as Agricultural Estate, Non -Urban to Open Space and
Planned Development and Low -Density Residential as per the Coachella/Thermal/
Indio General Plan; and relocate the Medium -Density Residential area shown at
the southeast corner of existing Avenue 52 and Avenida Bermudas to the north-
east corner.
RESPONSE
The Redevelopment Plan map, Figure 6, has been revised as attached.
COMMENT
Anticipated Private Development, Development of Agricultural Land (13):
Add t e notation that the projects cite are currently proposed, ut not yet
approved for development by the City.
RESPONSE
Comment noted. The approval of discretionary actions identified on Page
16 of the DEIR will be required, where appropriate, prior to entitlement to
use these properties.
COMMENT
Development of Vacant Lands Outside Urban Area (13-14): The acreages cit-
ed are not proposed for development, but rather are estimates of the increase
in developable area; none of the vacant land within this category is currently
developable due to severe flooding and drainage hazards. Mountainous areas
have not been included in these calculations. Development of this land will
depend largely on the location of the future flood control improvements, in
that the closer the flood channels and levees are placed toward the mountains,
the larger the amount of developable residential land which will result from
redevelopment.
6
Redevelopment Plan Map lsa
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RESPONSE
IM
The acreages used to determine buildout of the project area were based on
the ultimate developable area under optimum conditions. Circumstances could
change which would affect total buildout such as described in the comment.
Given that the buildout estimates provided on Page 14 of the DEIR [13,257-
13,527 residential and hotel units and 67 commercial acres) are based on opti-
mum development, any change is likely to result in a decrease in development
intensity.
COMMENT
Development of Vacant Lands Within the Existing Urban Area (14): Add the
notation that Specific Plan No. 83-00 located south o Avenue 50 and west and
east of Washington Street is proposed, but not approved for development; Spe-
cific Plan No. 83-001 proposes 11, not 7, acres of commercial.
Alk RESPONSE
IF
Comment noted.
COMMENT
Figure 8 (21) does not show the most current flood designations for that
area north of Calle Tampico.
RESPONSE
Flood Insurance Rate Maps (FIRM) were provided by the Federal Emergency
Management Agency. Information on these maps is the most current available to
the DEIR at the time of its preparation.
COMMENT
On Page 14, Paragraph 1: Regarding anticipated development, these totals
are the maximum anticipated development based upon proposed and expected
development applications.
RESPONSE
Comment noted. It should also be noted that development will occur over ._.
an extended period of time and that, as a potential consequence of other con-
straints, the maximum anticipated development in the project area may be
unachievable.
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COMMENT
Intended Use of EIR (16). Under the last paragraph listing other
actions, delete remise an of Development and add Plot Plan. Building per-
mits and minor grading permits (not subject to CEQA review) are not discre-
tionary actions as implied by this paragraph.
RESPONSE
Comment noted.
COMMENT
Hydrology/Flood Control (20). The following comments are on Paragraph 2
of Page .
Regarding the raising of building pads for flood protection, the height
of the pads is not a minimum two feet above grade, but a minimum of two feet
above flood level. This has resulted in some pads being raised five feet
above street level.
The additional cost to the developer of a single-family lot in The Cove
is $1,500 to $2,500 for engineering, purchase and transport of fill, and con-
struction of retaining walls.
Regarding the second to the last sentence, property located in the
extreme southeasterly portion of The Cove is subject to severe flooding (as
per Exhibit 8). Also, while the property in the southern portion of The Cove
is not subject to the ponding of drainage because of the slope, there is a
significant problem with unchanneled drainage runoff causing erosion and leav-
ing debris.
RESPONSE
Comments noted.
COMMENT
Traffic/Circulation (49-56). Regarding Washington Street, while it does
have a wo- ane r- ge across the La Quinta Stormwater Channel providing an
all-weather crossing, it is subject to severe flooding hazards south of Ave-
nida Ultimo (as per Figure 8).
Avenue 50 is also the major link between La Quinta and Indio. It crosses
the flood evacuation channel at grade and therefore is subject to flooding and
closure.
Avenue 52 is designated on the Master Plan as an arterial highway east of
Washington Street and as a major highway west of Washington Street to Avenida
Bermudas. An approved roadway specific plan provides for Avenue 52's exten-
sion westward to Eisenhower Drive. As described in the Hydrology section of
this report, Avenue 52 is subject to severe flooding which has resulted in its
closure. In addition, the flood waters have seriously damaged the roadway in
the past and in a number of incidences have completely severed the street.
Eisenhower Drive is both the major north -south street for traffic: travel-
ing to and from The Cove and downtown areas and also a major route used by
motorists traveling within the Cove area. While it does have a two-lane
bridge over the La Quinta Stormwater Channel, it is subject to flooding south
of Calle Tampico to near Calle Hidalgo.
Add Calle Tampico, a designated major highway (100-foot-wide right-of-
way) which serves as the major link between Washington Street and Eisenhower
Drive through the downtown area. As commercial development in the downtown
area and residential development south of the La Quinta Stormwater Channel
occur, this will serve as a major inner-city traffic route. This roadway is
currently a two-lane facility, with a portion classified as one lane with two-
way traffic due to its substandard improved width. Current daily traffic
volume is approximately 3,000 vehicles. The roadway is subject to severe
flooding.
RESPONSE
Comment noted. Access can be severely restricted in and out of the Cove
area with portions of Washington Street, Avenue 50, Avenue 52, Eiisenhower
Drive, and Calle Tampico subject to flooding. When these roadways are out of
service, few other options to evacuate the Cove remain. Implementation of the
Redevelopment Plan will resolve these roadway closures, thus increasing Cove
area accessibility.
COMMENT
Regarding impacts, an important beneficial impact which must be added is
that reduced street flooding will significantly improve both access into and
circulation within the city during and immediately following storms. This is
extremely important with respect to the movement of emergency vehicles. Under
current conditions, flooding restricts or hinders direct access by emergency
vehicles, significantly increasing their response time.
RESPONSE
This benefit of the proposed flood control improvments is identified on
�_. Page 52 of the DEIR: "Provision of flood control improvements will result in
11
protection of roadway facilities from washouts during flash flooding. Con-
sequently, the accessibility into and out of La Quinta to the surrounding
environment will be enhanced." This point is also stated for fire Emergency
access on Page 95 of the DEIR.
' COMMENT
Regarding Exhibit 14, the alignment of Avenue 52 west of Washington
Street parallels that of Avenue 50, meeting with Calle Sinaloa one block north
of Calle Durango and extending to Washington Street.
Regarding Table E (55), there is a typographical error with Jefferson
Street being listed as a cross street of Washington Street. Also, the
anticipated lane improvements of all streets, with the exception of Madison,
are four lanes.
RESPONSE
Comment noted. With regard to Table E, the cross street reference with
Washington Street is Highway 111.
COMMENT
Regarding mitigation measures, add the upgrading of all streets in the
Cove area to City standards through the formation of an assessment district or
other forms of financing.
RESPONSE
Comment noted. Other mechanisms for providing roadway improvements are
available and are subject to additional study beyond the purview of environ-
ment assessment.
COMMENT
Noise (58). Regarding Mitigation Measure 18, Section 6.08.050 of the
Municipal Code limits the hours for construction activities as follows:
October 1 thru Monday -Friday 7:00 a.m. to 5:30 p.m.
April 30 Saturday 8:00 a.m. to 5:00 p.m.
Sunday None
Govt. Code Holidays None
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May 1 thru
September 30
. RESPONSE
Comment noted.
COMMENT
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Monday -Friday
Saturday
Sunday
Govt. Code Holidays
6:00 a.m. to 7:00 p.m.
8:00 a.m. to 5:00 p.m.
None
None
m
Cultural Resources (81). Regarding Mitigation Measure 31, we recommend
that this section specify that archaeological surveys and assessments be per-
formed during the preliminary engineering and design phase.
RESPONSE
Comment noted. This would ensure that flood control engineering and
development design planning would consider the potential impacts on cultural
resources, rather than mitigating these resources in response to proposed
design.
COMMENT
Land Use (83-91). Regarding the table on existing residential character-
istics 83 , make the following corrections or additions: 103 single-family
attached units and 18 single-family detached units are under construction; the
20 houses located in the rural agricultural areas (identified incorrectly in
the table as "farm houses") have already been included in total for single-
family detached units.
RESPONSE
Comment noted. These data will be updated in the Final EIR.
COMMENT
Regarding Paragraph 1, Page 84, no accurate information is available on
the actual number of developed residential lots in The Cove. Because of the
small lot size (generally 50 feet by 100 feet), it is common that houses are
built on two lots. This is also true for commercial lots where the lot sizes -
are 25 or 50 feet by 100 feet.
13
RESPONSE
Comment noted. The anticipated development totals are projected to allow
a reasonable estimate for assessing environmental impacts.
COMMENT
Regarding Paragraph 2, Page 84, the commercial buildings have space for
43 tenants, with the current total of tenants being 35.
Mention should be made that development of the downtown commercially zon-
ed property has been extremely slow due to the following factors:
Substandard lot sizes (25 or 50 feet by 100 feet)
Substandard water system with inadequate fire flow (and added con-
struction costs of fire sprinkling and fire walls)
No sewers (due to the small lot size, there generally is no or
little space for a commercial -size septic system)
Difficulty in assembling adjacent parcels for new structures
In addition, the substandard water system and lack of a sewer system cur-
rently limit the types of commercial uses which can locate in the downtown
area. Businesses requiring a large fire flow, such as a paint store, could
not currently locate here without substantial improvements to the water sys-
tem. Also, uses which generate a large amount of wastewater, such as a Laun-
dromat, would have difficulty assembling enough land to allow for the large
septic tank system.
Regarding Paragraph 4, approximately 600 units were constructed prior to
1972. An estimated 300-400 units were constructed prior to 1969, when seismi-
graphic safety standards were imposed under the Uniform Building Code.
RESPONSE
® EIR. Comments noted. These data will be revised and updated for the Final
COMMENT
Exhibit 15 showing the existing General Plan is not up to date.
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On Page 86, Paragraphs 1 and 2 amend the General Plan description to con-
form with current General Plan designations.
RESPONSE
The Existing General Plan, Figure 15, was assembled from the most current
mapping available from the Cove community's General Plan, the Coachella/
Thermal/Indio General Plan, and the Riverside County General Plan. These
designations, as updated on Page 86, are the official General Plan designa-
tions for La Quinta. c
COMMENT
Regarding impacts, the increase in residential units, the upgrading of
public services and utilities, and the elimination of the flooding hazard in
the downtown area would increase the rate of commercial development in the
city center.
RESPONSE
The rate of commercial development will be allowed to increase, in
response to market conditions, with the above constraints removed and infra-
structure systems enhanced.
1. COMMENT
Also, regarding impacts, the increased development will substantially
reduce the amount of open space within the city, greatly changing the charac-
ter of La Quinta from a rural to an urban area. As a mitigation measure, we
recommend that future development's compliance with the Open Space Element as
currently adopted, or later revised, to preserve the hillsides and encourage
open -space areas.
RESPONSE
Comment noted. The City decisionmakers will ultimately determine the
character of the city through implementation of the City's General Plan and
other official policy documents.
COMMENT
Concerning Mitigation Measure 41 (90), this appears to be a result of
redevelopment rather than a mitigation measure.
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RESPONSE
Comment noted. The mitigation measure was included as worded to illus-
trate how property owners can achieve the potential of their land designated
in the General Plan not otherwise possible without the Redevelopment Plan.
COMMENT
that: Community Services (92-99). Regarding fire (92), mention should be made
. The fire station is located in a severe flooding area and is subject to
restricted access and damage during times of heavy flooding.
The station is operated 24 hours a day by a single paid firefighter on
each of three shifts; he is supported by a 15-member volunteer firefighter
crew. Equipment at this station includes one 1,000-gallon-per-minute pumper
and one 750-gallon-per-minute pumper. Response time to the site will vary
between two and four minutes.
With respect to fire flow, the City has amended the 1979 Uniform Fire
Code, as adopted by the City, decreasing the fire flow requirement for new
single-family detached units from 1,500 gpm to 500 gpm. his was done because
adherence to the stricter requirement would have stopped all new development
of this type in The Cove. sib kw sd s
RESPONSE
Comment noted. Flood control improvements provided through redevelopment
will enhance protection from fire hazards through improved access and more
reliable service.
COMMENT
Regarding police protection (92), the City will contract for increased
services as the area develops.
RESPONSE
Comment noted. Police protection services, then, will remain unchanged
with Redevelopment Plan implementation except that accessibility will be
greatly enhanced.
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COMMENT
Regarding schools (94), include discussion of the Coachella Valley Uni-
fied School District.
Regarding school impacts (96 and 98), the City does not currently collect
a school mitigation fee on new development. The City is currently discussing
with the Districts other acceptable means of mitigating the impacts of this
anticipated growth in student number and also for providing schools within our
community.
RESPONSE
Negotiations with the school districts are ongoing. Separate comments
from the school districts will receive responses in the Final EIR.
COMMENT
Public Utilities (100-108). Regarding water (100), contamination of the
water supply by septic tanks has not been documented.
Regarding Paragraph 3, amend the statement from "hot water" to "warm
water."
RESPONSE
Comment noted. The Southern California Water Company has provided
detailed corrections to the information contained in the Draft EIR. This
information has been incorporated into the Final EIR.
II COMMENT
g The source of Table H should be corrected to: State Department of Health
Services, Sanitary Engineering Branch, Exhibit No. 7 in the April 1, 1982
Public Utilities Commission brief relating to a system deficiency record
report on Southern California, dated February 25, 1982.
Regarding wastewater (100, 103), note the following: Page 100, Paragraph
2, change this to state that there have been instances where septic tank sys-
tems have failed and the rate may increase over time for the older systems
with metal tanks.
A temporary sewage treatment facility is located approximately 1/4 mile
south of Avenue 50 along the Adams Street alignment. The effluent is disposed
of via a leach field; the ground over the leach field is planted in alfalfa.
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SCWC does not provide septic tank sewage disposal.
RESPONSE
Comments noted and are hereby incorporated into the Final EIR.
COMMENT
Regarding impacts on the water (104), add to the second paragraph that
the cost of improving or expanding the water systems owned by either CVWD or
Southern California Water Company is paid by the developer.
RESPONSE
This is true for new development that occurs on previously vacant lands.
The developer traditionally pays for water distribution systems as a condition
® of tract map approval.
�. COMMENT
Regarding Mitigation Measure 73 (106), add mention of Southern California
Water Company.
RESPONSE
Comment noted.
COMMENT
Alternatives to the Proposed Project (109-111). On Page 109, Paragraph
2, amend the last statement to read that impact would be less since area
development will continue at a slower rate.
RESPONSE
The statement made in the Draft EIR, "...area wildlife would not be
affected by increased local population concentrations since area development
could not occur without flood control," is not entirely correct.
Development would continue at a slower rate, particularly in the Cove
area. However, the total development potential would eventually be constrain-
ed by the absence of flood control improvements. It is correct to add, there-
fore, that impacts would be less with development occurring at a slower rate,
rather than no impact whatsoever.
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COMMENT
On Page 109, Paragraph 4, the above statement also applies.
RESPONSE
Comment noted. See previous response.
COMMENT
Additional Comments. On Page 2, Paragraph 3, make the following,correc-
tion: he area contained within the redevelopment area i 1,705 acres; with
1,196 acres located outside the current City limits. --
RESPONSE
Comment noted. The area contained within the redevelopment project area
is not 1,705 acres. We believe you are referring to the mention of the "18.5-
square-mile project site" which has been recognized as being 17.5 square miles
in size.
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RESPONSES TO COMMENTS FROM
COACHELLA ALLEY RESOURCE N ER A N DISTRICT
COMMENT
Our Board received your Redevelopment Agency information. This letter is
to advise you that the person to contact on this project is:
Sam Aslan
District Conservationist
Soil Conservation Service
83-180 Requa Avenue, Suite #3
Indio, CA 92201
RESPONSE
Comment noted.
20
RESPONSES TO COMMENTS FROM
COA A E CT
COMMENT
In response to your letter to the Board of Directors of the Coachella
Valley Water District, Lowell 0. Weeks will be the contact person for the Dis-
trict.
RESPONSE
Comment noted.
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RESPONSES TO COMMENTS FROM
COACHELLA VALLEY RESOURCE CONSERVATION DISTRICT
COMMENT
We acknowledge receipt of the Environmental Impact Report for La Quinta
Redevelopment Project No. 1 for the City of La Quinta.
We have reviewed the above Environmental Impact Report and find no con-
flict with any Coachella Valley Resource Conservation District ongoing planned
programs or projects.
The Environmental Impact Report did not adequately address alternatives
to the use of prime agricultural lands in the proposed project.
RESPONSE
The DEIR recognizes the adverse impacts associated with development of
the prime agricultural lands in the project area. The alternatives presented
on Page 89 of the DEIR, and Mitigation Measure 46, Page 91, presented to off-
set the loss of agricultural lands, may be infeasible to the City of La Quin-
ta. A finding must be made by the City stating why certain mitigation mea-
sures are infeasible prior to approving the plan. Should the City decide to
approve the redevelopment project, the overriding considerations of the proj-
ect must be adopted when balancing the project's adverse impacts.
Use of prime agricultural lands fc
the DEIR. Their use as described in th
13, is essential to implementation of
increment revenues received from these
trot improvements could not be funded
of blighted.conditions.
r other purposes is beyond the scope of
e Project Description of the DEIR, Page
the Redevelopment Plan. Without tax
proposed developments, the flood con -
which would result in the perpetuation
1
22
RESPONSES TO COMMENTS FROM
SOUTHERN CALIFORNIA WATER COMPANY
COMMENT
0
The Draft EIR states, "CVWD serves most of the remaining city, including
all new development." Our records indicate that new development in the South-
ern California Water Company service area for the last four years has been
approximately 61 services annually, or a growth rate of about 3.4%.
RESPONSE
Comment noted.
COMMENT
The Draft EIR states, "...contaminants from septic tank leakage have
infiltrated into the water lines. To overcome this health hazard, the water
is heavily chlorinated, resulting in poor taste." This statement is both
untrue and irresponsible. A modicum of chlorine is added as a preventive
measure against any bacterial growth under normal conditions.
RESPONSE
Comment noted. This information was provided by the City of La Quinta.
COMMENT
The Draft EIR states, "To provide pump pressure to the upper portions of
The Cove, the water is pumped through water pumps that have grown old with
age. In addition, sand and other debris washed into the pump area from flood
runoff has caused pump failure and system down time." The first sentence is
obvious and would hold true for any system supplying water to the upper por-
tions of The Cove. It should be noted that Southern California Water Company
has repaired or replaced 83.3% of the system operating pumps since 1979; the
one remaining unit to be worked on is part of our 1984 maintenance budget.
The second sentence is not true in that sand and debris have never caused a
pump failure since we acquired the system.
RESPONSE
Comment noted. This information was provided by the City of La Quinta.
23
M
COMMENT
The Draft EIR states, "Another problem relates to the shallow depth of
water line. In the summertime, many residents turn off their water heaters to
D save energy costs. Not water is delivered to their homes from the solar heat-
ing of the ground surface transferred to the water lines supply domestic
drinking water." This statement is not true; our records indicate that the
temperature of the water coming from the wells is normally 80" Fahrenheit or
more.
RESPONSE
Comment noted. This information was provided by the City of La Quinta.
Residents in the Cove area have apparently experienced these conditions.
COMMENT
8 The Draft EIR states, "...many of La Quinta's residences are provided
septic tank sewage disposal by SCWC." This is not true.
RESPONSE
So noted. This information was provided by the City of La Quinta.
COMMENT
The Draft EIR states, "All sources need complete chemical analyses for
General Mineral, General Physical, and Inorganic Chemicals." This has been
done.
The Draft EIR states, "The system
records and analysis indicate that the
the minimum standards established by
General Order No. 103.
has inadequate storage capacity." Our
supply and storage for La Quinta meets
the Public Utilities Commission per
The Draft EIR states, "Reservoir No. 1 - North Medera - Roof in need of
repair." This has been fixed.
The Draft EIR states, "The Well Drillers Report for all sources has not
been submitted." When Southern California Water Company purchased the La
Quinta system, the Well Drillers Reports were not in the engineering records
we received, making it impossible for us to submit same.
24
0
The Draft EIR states, "A master plan for orderly development of the sys-
tem to meet needs of the service area has not been prepared and submitted to
this office." This past week we took delivery on a microcomputer which we
intend to use for systems analysis and master planning; a master plan for the
City of La Quinta is one of our higher priorities, and should be completed
within one year.
RESPONSE
Comment noted. This information was provided to the City of La Quinta by
the State Department of Health Services, Sanitary Engineering Branch, in a
"System Deficiency Record." It appears that some of the system deficiencies
have been resolved and conditions have improved.
25
RESPONSES TO COMMENTS FROM
COACHELLA VALLEY UNIFrED—TMO-017ISTRICT
COMMENT
Any increase in area development within the CVUSD will result in increas-
ed local assessments and additional local property taxes being generated. The
district normally receives a portion of these local property taxes which will
increase as growth occurs. However, because of reallocation of the increased
taxes to the Redevelopment Agency, the district will not benefit from increas-
ed assessments until such time as the redevelopment project debt is retired.
School districts also receive funds allocated by the State of California for
children attending public schools. If new development occurs within the dis-
trict boundaries that does not generate school -aged children (such as resort -
type housing), then the district will not receive these funds from the State.
The net effect is a long-term loss in revenues that are necessary to continue
construction of capital improvements.
RESPONSE
The Redevelopment Agency and the CVUSD are currently negotiating the use
of tax increment funds collected by the Redevelopment Agency for the purpose
of constructing future capital improvements. These negotiations will effec-
tively mitigate any adverse impacts to the school district that would occur
from implementation of the Redevelopment Plan.
f 26
RESPONSES TO COMMENTS FROM
DESERT RICT
COMMENT
LM
The student population in the Coachella Valley has steadily increased
over the past number of years. This continued growth is anticipated with the
approval of each tentative tract. Population increase means increased school
enrollment. Currently our schools are housed in permanent and portable facil-
ities to capacity and any additional housing units will have a serious impact
on school facilities.
Since we are unable to absorb any additional student enrollment without
additional school facilities, we can only advise that approval of tentative
tracts within the boundaries of Desert Sands Unified School District is made
with the understanding that there are no financial resources at this point in
I time to provide additional school facilities. Our mitigation statement filed
with the County of Riverside and soon to be acted upon by the Board of Super-
visors asks for a mitigation fee of $628 per dwelling unit or mitigation under
a CEQA. We would expect the same mitigation within the city of Indio.
RESPONSE
A new elementary school is currently being planned in the Cove area and
is in the secondary planning stage by the Desert Sands Unified School Dis-
trict. The City realizes that district facilities are at capacity and that
additional student generation without an effective means to mitigate capacity
problems would present an adverse impact. However, several conditions could
occur to mitigate the impact. New development is presumed to occur over a
20-year period and the generation of new student populations will occur incre-
mentally. This lengthy time period, therefore, will tend to soften the impact
of future development on district resources. If mitigation fees are collect-
ed, or if other mitigation measures are imposed (e.g., developer/school site
donations), then the potential impact of new residential development will be
reduced to an insignificant level.
I
r
27
RESPONSES TO COMMENTS FROM
RIVERSIDE COUNTY PLANNING N ER OF 9/30/83
COMMENT
Blight
In the comments provided by the Planning Department in response to the
Notice of Preparation, it was requested that "detailed information should be
provided to document the incidence of blight within the redevelopment area.
The California Health and Safety Code Section 33032 identifies a blighted area
when one or more of a number of characteristics exist." Nowhere in the draft
EIR is this information provided. The determination regarding the incidence
of blight is crucial to any redevelopment project. In order to determine that
the intent of Community Redevelopment Law is met, the existence of blight must
be found and documented.
When redevelopment is discussed, it is the context of rehabilitation,
revitalization, or redevelopment. Inherent in this concept is the 'idea that
something is being done to bring about an original or former state of being.
However, in reviewing the Draft EIR, it is stated that "open -space and water-
shed uses are the most predominant" (Page 83) in the project area. While
development of a flood control system may be desirable, it is generally not
recognized as an eliminator of blight in open -space or watershed areas. The
primary purpose of a redevelopment project is the elimination of blight, not a
mechanism to finance desired public improvements.
RESPONSE
The environmental impact reporting process is not required to document
the incidence of blight within the project area boundaries of a redevelopment
plan. Detailed information documenting the incidence of blight is provided in
the Agency's report to City Council on the proposed Redevelopment Plan which,
in part, serves to provide reasons for the selection of project area
boundaries and a description of physical, social, and economic conditions
within the project.
The Draft EIR does provide a description of existing conditions. for the
project area under the "Setting" discussion of each environmental topic.
While these descriptions are not intended to document the incidence of blight
per the California Health and Safety Code Section 33032 requirement, the
observations and data provided begin to illustrate problems with the physical,
social, and economic environment within the project area. In summary and
without being site -specific, these problems are as follows:
ru
• Major flooding hazards
• Undevelopable land area due to flooding
• Substandard roadway conditions
• Substandard water distribution system and consequent substandard
fire flow, poor water quality, unhealthful water contamination
• Substandard sewage system aggravated during major flooding
• Inadequate local storm drain system -
• Overused local park system
The use of redevelopment authority will not be restricted to the con-
struction of flood control facilities in the project area. However„ because
the hazards associated with flooding are generally viewed as the most severe
problem in the project area, most of the attention with regard to the use of
redevelopment authority has centered on the resolution of this problem.
Other problems in the project area may also be resolved through the
authority granted to the Redevelopment Agency. These problems would be
resolved as necessary to improve the substandard conditions as stated above
and include the rehabilitation, revitalization, and redevelopment of blighted
conditions. It must also be recognized that, without adequate flood control
protection, these substandard problems could be aggravated, resulting in con-
tinued deterioration from flood inundation and erosion. The project area
boundaries, therefore, include lands designated for open space and watershed
uses that contribute runoff to the flooding hazard and indirectly to the per-
petuation of blight in the project area. The inclusion of these lands in the
project area permits the proposed flood control improvements to be effectively
designed and the blighted conditions in the project area to be resolved.
COMMENT
Project Objectives
One of the stated project objectives is for "project -area property owners
to develop their properties in accordance with the La Quinta General Plan"
(Page 5). However, the primary purpose of a redevelopment project. is the
removal of blight. Implementation of the General Plan is accomplished by a
city through its general powers such as planning and zoning.
Approval of a redevelopment project for implementation of the General
Plan would be a misuse of the redevelopment process.
w
RESPONSE
0
The objective of redevelopment plan implementation is to eliminate blight
in the project area. This must occur in conformity with the City's General
Plan as is or as amended as required by Redevelopment Law. However, because a
major flooding hazard potential exists in the project area, lands have been
precluded from development and thus implmentation of the land use program in
the General Plan has been unattainable. With Redevelopment Plan implementa-
tion and construction of an effective flood control system, the obvious flood
hazard constraint on development will be lifted and development will occur in
conformance with the General Plan through the City's general planning and zon-
ing powers.
COMMENT
Alternatives
In accordance with the California Environmental Quality Act, each EIR
must contain eight areas of description and analysis. One of these areas is
Alternatives to the Proposed Action (Section 15143[d]). In this section via-
ble alternatives should be included. One such alternative would be the forma-
tion of a benefit assessment district. The benefit assessment district
mechanism could provide flood control facilities that would eliminate the
"impact of storm and floodwaters on the proposed project area" (Page 5). The
elimination of this impact is one of the stated project objectives.
Also, in the response to the NOP, it was requested that there be a dis-
cussion of alternative financing methods such as the Roos Assembly Bill No.
3564, Community Facilities Act and the Mello -Roos Senate Bill No. 2001. This
�. discussion is noticeably absent.
RESPONSE
Mechanisms for financing the cost of eliminating blighted conditions in
the project area were not considered during the review of environmental impact
on the proposed project. According to CEQA Guidelines, as amended August 1,
1983, Section 15131, "Economic or social information may be included in an EIR
or may be presented in whatever form the agency desires."
In spite of the optional provision for including economic information,
the formation of a benefit assessment district was considered by the City to
finance the cost of flood control improvements. This concept presented numer-
ous drawbacks to the successful accomplishment of flood control objectives
when compared to that made available through redevelopment. These drawbacks
include:
M
XT
1. Flood control problems are generally regional in scope and
therefore would be difficult to resolve through administration
of a benefit assessment district.
2. It would be difficult to establish the level of benefit applied
to properties within the benefited area, particularly where
flood hazards increase or decrease in severity depending on
location.
3. Due to the high cost of flood control improvements, assessments
would be imposed on properties that would be unable to "bear the
burden," particularly in light of the benefit gained.
Although these drawbacks may be debatable as to their relative implica-
tions, it is beyond the scope of this environmental review to assess the
merits or detriments to application of assessment district formation as a
mechanism to finance cost of improvements. In addition, the Agency would not
be precluded from using this as a vehicle for assisting in the achievement of
its objectives.
"Alternatives" discussion, therefore, concentrated on alternative Rede-
velopment Plan land use conditions. These included the "No -Project" alterna-
tive, where land use development in the project area would retain the status
quo; "Retention of Agricultural Production," where agricultural lands would
not be displaced by urban uses; and "Development With More Intense Uses,"
where land use development would occur at a greater intensity than allowed in
the General Plan.
COMMENT
ffects on Taxinq Jurisdictions
One of the significant cumulative impacts the creation of this redevelop-
ment agency will have is on other taxing jurisdictions. However, nowhere in
the EIR is this impact identified. Tax increment financing does have costs to
other taxing agencies in the form of lost revenue. In order to weigh the
Redevelopment Agency's benefits against its costs, for both the short and
long term, this cumulative impact should be further expanded upon.
11*9111,I&9a
® As stated in the above response, CEQA does not require the assessment of
economic information in the evaluation of environmental impact. The Draft EIR
evaluates the impacts on services to service agencies and identifies those
11
31
Mn
areas where impact is anticipated. However, with respect to the implication
of impact on certain agencies in the form of lost revenues, these issues will
not be ignored. Through the mechanisms provided in Community Development Law,
these issues will be considered. The County of Riverside has requested the
formation of a Fiscal Review Committee, composed of a member of each taxing
agency, to determine the fiscal impact on each taxing agency. Also, the
redevelopment agency is required to individually consult with each taxing
agency to discuss direct fiscal impacts. Finally, inasmuch as a portion of
the project area remains in county unincorporated territory, the County has
negotiated an agreement with La Quinta for the return of a proportion of each
year's tax increment, thus reducing the loss in revenue to the county.
4
32
RESPONSES TO COMMENTS FROM MEETING WITH
A QUINTA CITY COUNCIL, OCTOBER 24, 983
COMMENT
\�T I
Entry into the sensitive mountain habitat areas by off -highway vehicles
in the past has disturbed habitat features and frightened wildlife away from
these areas. The opportunity to prevent future motorized access in these
areas should be investigated when planning the design of flood control facili-
ties and training dikes.
RESPONSE
So noted. These features could be included during the design of the
project, where feasible, to discourage access (see Mitigation Measure #29 of
the Draft EIR). In addition, a signage program could be implemented that pro-
hibits access.
COMMENT
A considerable amount of debris is located in the area's streambeds and
habitat areas. This is aesthetically unappealing and should be removed. With
debris removal, some of these areas may be converted into native -type park
habitat, reminiscent of its former condition.
RESPONSE
The debris could be removed as a result of project implementation, par-
ticularly if it conflicts with flood control objectives. Further study should
occur to: 1) determine the suitability of the debris for berm construction,
and 2) evaluate the most sensitive procedure for debris removal and habitat
restoration.
COMMENT
Flood control facilities, in certain instances, appear to be located in
areas of sensitive biological significance as well as having valuable develop-
ment potential. The City is concerned about providing for both; however,
obviously this would result in conflict for the use of the land. As decision -
makers, the City Council will ultimately need to make some policy decisions
regarding this issue.
I
33
RESPONSE
Lsa
So noted. The precise alignments of certain training dikes have not been
determined for this level of review. Their alignments will decide the ulti-
mate use of these lands which will: 1) wholly preserve the area's biological
significance, 2) open up these lands for urban development, or 3) employ some
combination of compromise. Other factors will also provide criteria for dike
alignment. These include: 1) location and value of cultural resources, 2)
location and order of magnitude value for habitat, 3) system hydraulics and
design, and 4) opportunity to suggest appropriate design mitigation compro-
mise.
Additional study of these areas is necessary that will allow adequate
review and comment by archaeologists, hydraulic engineers, the public, and the
City Council. With this more detailed information, the appropriate policy
decisions can be determined in good faith.
STATE OF CAUFORNIA—OFFICE OF THE GOVERNOR GEORGE DEUKMEJIAN Go" n
�4 OFFICE OF PLANNING AND RESEARCH
1400 TENTH STREET
ACRAMENTO, CA 9581A
ctober 27, 1983
1,
Frank Usher
La Quinta Redevelopment Agency
78-105 Calle Estado
La Quinta, CA 92253
Subject: SCH# 83072017 La Quinta Redevelopment Project Draft EIR
Dear Mr. Usher:
The State Clearinghouse submitted the above named draft Environmental Impact Report
(EIR) to selected state agencies for review. The review period is closed and the com-
ments of the individual agency(ies) is(are) attached. If you would like to discuss
their concerns and recommendations, please contact the staff from the appropriate
agency(ies) .
When preparing the final EIR, you must include all ccsmnents and responses (CEQA
Guidelines, Section 15146).- The certified EIR must be considered in the decision -
making process for the project. In addition, we urge you to respond directly to the
commenting agency(ies) by writing to them, including the State Clearinghouse number on
all correspondence. .
A 1981 Appellate Court decision in Cleary v. County of Stanislaus (118 Cal. App. 3d
348) clarified requirements for responding to review comments. Specifically, the
court indicated that comments must be addressed in detail, giving reasons why the
specific comments and suggestions were not accepted. The responses must show factors
of overriding significance which required the suggestion or comment to be rejected.
Responses to comments must not be conclusory statements but must be supported by em-
pirical or experimental data, scientitic authority or explanatory information of any
kind. The court further said that the responses must be a good faith, reasoned
analysis.
In the event that the project is approved without adequate mitigation of significant
effects, the lead agency must make written findings for each significant effect and it
must support its actions with a written statement of overriding considerations for
each unmitigated significant effect (CDQA Guidelines Section 15088 and 15089).
If the project requires discretionary approval from any state agency, the Notice of
Determination must be filed with the Secretary for Resources, as well as with the
County Clerk. Please contact Dan Conaty at (916) 445-0613 if you have any questions
about the environmental review process.
Sincerely,
Terry its
Manage
State Clearinghouse
cc: Resources Agency
attachment
State of California
Me'morandum
1. Projects Coordinator
Resources Agency
�. 2. La Quinta Redevelopment Agency
7B-105 Calle Estado
La Quinta, CA 92253
From Department of Fish and Game
The Resources Agent
Date • October 18, 1983
Subject:
La Quinta Redevelopment Agency, Riverside County, SCR-83072017
We have reviewed the Draft EIR for the La Quinta Redevelopment Project No. 1,
prepared for the La Quinta Redevelopment Agency. The project involves flood
control improvements in the City of La Quinta located in the Coachella Valley
of Riverside County.
Of primary concern to the Department of Fish and Game are potential impacts to
riparian zones and to the habitat of the rare Peninsular bighorn sheep (state
rare) associated with the upper Bear Creek drainage -of. the Santa Rosa
Mountains. We believe that flood control Alternative 1 would offer the least
detrimental impacts to existing wildlife values located within this portion of
the redevelopment zone. Additionally, it is important to recognize that the
growth -inducing impact of flood control features may' adversely impact the
remaining sand dune habitats of the Coachella Valley fringe -toed lizard located
within the redevelopment zone. We believe this potential impact can be greatly
reduced, however, by careful land use planning directed at minimizing impacts
to this state endangered species.
The measures included in the draft EIR to reduce potential wildlife impacts,
should be specifically included as conditions of approval in the Final M. We
also encourage early consultation and coordination with the Department in
planning and implementating flood control Alternative 1. We believe such an
approach would facilitate necessary flood control measures as well as provide
for the necessary conservation of existing important wildlife resources.
Thank you for the opportunity to review and comment on the proposed
redevelopment project. If you have any questions please contact Fred A.
Worthley Jr., Regional Manager, Region 5, 245 West Broadway, Suite 350, Long
Beach, California 90802; telephone (213) 590-5113.
- Director
:- Ji
j
1. � ='- If`•'!�
I�Z'�^..!1!.a
itote of California
THE RESOURCES AGENCY Of CALIFORNIA
Memorandum
o Dr. Gordon F. Snow
Assistant Secretary for Resources
Frank Usher, Executive Director
La Quinta Redevelopment Agency
78-105 Calle Estado
La Quinta, CA 92253
:rom : Department of Conservation —Office of the Director
Date
Subject: La Quinta Redevelop-
ment Project DEIR,
SCH'No. 83072017.
The Department of Conservation has reviewed the Draft EIR for the
La Quinta Redevelopment project. The Department is responsible for
monitoring conversions of agricultural lands on a statewide basis.
Because this project will displace large acreages of productive
agricultural lands, the Department is submitting the following
comments.
General
The La Quinta redevelopment plan encompasses an area of 17.5 square
miles, and includes the existing urbanized area of La Quinta-(DEIR,
p. 2, however, indicates that the project area is 18.5 square
® miles, conflicting with the Vicinity Map on page 4, which shows an
area of 17.5 square miles). Of this area, 2,786 acres are
currently in agricultural production. According to the draft U.S.
Department of Agriculture -Soil Conservation Service/California
Department of Conservation Important Farmland Map for this area,
effectively all 2,786 acres are "Prime" farmland. Approximately
seventy-nine percent (79%) or 2,206 acres, of this farmland will be
converted to non-agricultural uses by the project (DEIR, pp. 13 and
46).
The DEIR recognizes that the irreversible conversion of over 2,206
acres of prime agricultural soils represents "a significant adverse
impact" (DEIR, p. 46). The discussion of mitigation, however,
fails to adequately address this impact. The Department does not
consider using the displaced farmland's irrigation water to create
replacement farmland elsewhere a realistic mitigation (DEIR,
p. 89). Such a water transfer would probably involve the
construction of new water delivery systems, would require very
large amounts of capital investment, and could create adverse
environmental impacts of its own. While it is a suggestion with
merit; it appears to be outside the lead agency's scope to require
this as a mitigative measure.
U.
t I - .
Dr. Gordon F. Snow
Frank Usher
Page 2
To approve the project .in the absence of any feasible mitigation of
the farmland conversion impact, the lead agency would have to show
in the record the overriding positive impacts of the project. The
DEIR does not appear to provide such documentation. If overriding
considerations are pertinent to this project, such as an existing
or projected regional need for housing or jobs, they should be
documented and balanced against the permanent loss of productive
agricultural land.
Impacts
Further analysis should be included in the final EIR regarding the
impact of this project on the local and county agricultural
economy. The Coachella Valley's agricultural history is well
known, yet the DEIR states that agriculture may no longer be
economically vital (p. 2)_ Such a claim should be documented.
Based on the County's Agricultural Crop Report for 1981 (compiled
by the County's Agricultural Commissioner's Office) and multipliers
developed by the University of California's Cooperative Extension
("Economic Impacts of Agricultural Production and Processing in
Stanislaus County", March 1981), we roughly estimate the annual
fiscal losses to the area, due to the conversion of 2,206 acres of
agricultural land, to be the following.*
CROP
AVERAGE
VALUATION/
ACRE**
PROJECT
FARMLAND ACREAGE
TO BE CONVERTED
(BY ASSUMED CROP)
MULTIPLIER
ANNUAL FISCA
LOSSES DUE T
PROJECT FARM
LAND CONVER-
SION
Alfalfa Hay $ 560 .1,103 acres 2.4 $ 1,482,432
Grapefruit 3,000 1,103 3.8 12,574,200
TOTAL 2,206 14,056,632
* Based on 1981 dollars.
** Per acre value for grapefruit is a weighted average for desert and
summer grapefruit, and includes the value of grapefruit by-product
Dr. Gordon F. Snow
Frank Usher
0 , Page 3
p The average production value per acre for the 2206 acres of active
agricultural land slated for conversion is $6,372 per year. This
assumes that half of the acreage is in alfalfa pasture and the
other half is in grapefruit production. Though these figures may
not accurately reflect existing crop patterns, they do reflect a
realistic model, based on the California Department of Water
Resources 1978 land use maps for the La Quinta area.
The Final EIR would be more complete if it were to include a
analysis similar to that presented above, utilizing more accurate
and up-to-date information on crop patterns, acreages and
production values. We recommend that such an analysis include
both possible values for potential agricultural lands and actual
p values for active "Prime" agricultural lands. Impacts on lands
adjacent to the project area should also be included.
Mitigation/Alternatives
We believe that the recommendations offered in the DEIR for
mitigating the impacts of farmland conversion are not reasonable.
Neither the creation of replacement farmland elsewhere, nor the
boosting of yields on remaining farmlands to compensate for lost
production, will mitigate against the actual loss of producing and
�. nonproducing "Prime" farmland from the state agriculture resource
base.
The DEIR discusses three alternatives to the proposed project:
1. No -Project
2. Retain in Agricultural Production
3. Project Developed With More Intense Uses
Given the apparent worsening urban blight conditions, and the
existing flooding hazards, the "no -project" alternative does not
seem realistic. on the other hand, the substantial conversion of
productive agricultural lands that would accompany this project
would be extremely damaging. As such, we recommend adoption of
Alternative 2, an option that allows redevelopment while preserving
existing "Prime" farmland.
�? We recommend, therefore, that the Final EIR include a detailed
analysis of Alternative 2, including analysis of impacts and the
necessary mitigation measures. Particularly, the impacts resulting
i
r
Dr. Gordon F. Snow
Frank Usher
Page 4
from the interface of conflicting land uses that would result if
Alternative 2 were adopted, need to be addressed. Such impacts
include, but are not limited to, dust, field access, noise, and
pesticide drift onto residential neighborhoods. Measures necessary
to mitigate these kinds of impacts may include such approaches as
setbacks, walls, windbreaks and buffer zones.
We would appreciate being kept updated on the progress of this
Project. We would also like to receive a copy of the Final EIR, or
a direct written response to our comments. If you have questions
regarding our comments, please call at (916) 322-5873.
Dennis J. O'Bryant
Environmental Program Coordinator
cc: Ken Trott, Division of Land Resource Protection
Art Mills, Chief, Division of Land Resource Protection
4223B-2
78-105 CALLE ESTADO - LA QUINTA, CALIFORNIA 92253 - (619) 564-2246
October 28, 1983
Bill Mayer, Project Manager
LSA, Inc.
500 Newport Center Drive, Suite 600
Newport Beach, CA 92660
RE: Cam-ents on Draft Environmental Impact Report, La Quinta Redevelopment
Project
Dear Mr. Mayer:
The City has the following cannents on the above mentioned document. Page
numbers are included in parentheses.
° Redevelopment Plan Map (12) The following changes should be made: Designate
that area included within Specific Plan No. 121-E Revised; change that area
10 designated as Agricultural Estate, Non -Urban to open Space and Planned
Development and Law Density Residential as per the Coachella -Thermal -Indio
General Plan; and relocate the Medium Density Residential area shown at the
g southeast corner of the existing Avenue 52 and Avenida Bermudas to the north-
east corner.
Anticipated Private Development
° Development of Agricultural Land (13): Add the notation that the
projects cited are currently proposed, but not yet approved for
development by the City.
° Development of Vacant Lands Outside Urban Area (13-14): The acreages
cited are not proposed for development, but rather are estimates of
the increase in developable area; none of the vacant land within this
category is currently developable due to the severe flooding and
drainage hazards. Mountainous areas have not been included in these
calculations. Development of this land will depend largely on the
location of the future flood control improvements, in that the closer
the flood channels and levees are placed towards the mountains, the
larger the amount of developable residential land which will result
from redevelopment.
Development of Vacant Lands Within the Existing Urban Area (14): Add
the notation that Specific Plan No. 83-001 located south of Avenue 50 -
--
and west and east of Washington Street, is proposed, but not approved
for development; Specific Plan No. 83-001 proposes 11, not 7, acres
of oomlercial.
MAILING ADDRESS - P.O. BOX 1504 - LA QUINTA, CALIFORNIA 92253
I'
1
Bill Mayer, Project Manager
I,SA, Inc.
October 28, 1983
Page Two.
° On page 14, paragraph one: Regarding anticipated development, these
totals are the maximum anticipated development based upon proposed
and expected development applications
Intended Use of EIR (16)
° Under the last paragraph listing other actions, delete Precise Plan of
Development and add Plot Plan. Building permits and minor grading
permits (not subject to CEQA review) are not discretionary actions as
implied by this paragraph.
Hydrology/Flood Control (20)
The following camuents are on paragraph 2 of page 20:
° Regarding the raising of building pads for flood protection, the height
of the pads are not a minimum 2 feet above grade, but a minimum of 2
feet above flood level. This has resulted in some pads being raised
5 feet above street level.
° The additional cost to the developer of a single-family lot in the
cove is $1,500 to $2,500 for engineering, purchase and transport of
fill and construction of retaining walls.
° Regarding the second to the last sentence, property located in the
extreme southeasterly portion of the cove is subject to severe flooding
(as per Exhibit 8). Also, while the property in the southern portion
of the cove is not subject to the ponding of drainage because of the
slope, there is a significant problem with the unchannelled drainage
runoff causing erosion and leaving debris.
° Figure 8 (21) does not show the most current flood designations for
that area north of Calle Tampico.
Traffic/Circulation (49-56)
° Regarding Washington Street, while it does have a tqo-lane bridge
across the La Quinta Stornwater Channel providing an all-weather
crossing, it is subject to severe flooding hazards south of Avenida
Ultimo (as per Figure 8).
° Avenue 50 is also the major link between La Quinta and Indio. It
crosses the flood evacuation channel at grade and therefore is subject
to flooding and closure.
° Avenue 52 is designated on the Master Plan as an arterial highway east
of Washington Street and as a major highway west of Washington Street
to Avenida Bermudas. An approved roadway specific plan provides for
Avenue 52's extension westward to Eisenhower Drive. As described in
the hydrology section of this report, Avenue 52 is subject to severe
flooding which has resulted in its closure. In addition, the flood _
waters have seriously damaged the roadway in the past and in a number
of incidences have completely severed the street.
Bill Mayer, Project Manager
ISA, Inc.
October 28, 1983
Page Three.
Eisenhower Drive is both the major north -south street for traffic
travelling to and fran the cove and downtown areas and also a major
route used by motorists travelling within the cove area. Ulile it
does have a two-lane bridge over the La Quinta Stormwater Channel,
it is subject to flooding south of Calle Tampico to near Calle
Hidalgo.
° Add Calle Tampico, a designated major highway (100-foot wide right
of way) which serves as the major link between Washington Street and
Eisenhower Drive through the downtown area. As commercial development
in the downtown area and residential development south of the La Quinta
Stormgater Channel occurs, this will serve as a major inner city traffic
route. This roadway is currently a two-lane facility, with a portion
classified as one lane with two-way traffic due to its substandard
improved width. Current daily traffic volumes are approximately 3000.
The roadway is subject to severe flooding.
° Regarding impacts, an important beneficial impact which must be added
is that reduced street flooding will significantly improve both access
into and circulation within the City during and immediately following
storms. This is extremely important with respect to the movement of
emergency vehicles. Under the current conditions, flooding restricts
or hinders direct access by emergency vehicles, significantly increas-
ing their response time.
° Regarding Exhibit 14, the alignment of Avenue 52 west of Washington
Street parallels that of Avenue 50, meeting with Calle Sinaloa, one
block north of Calle Durango and extending to Washington Street.
° Regarding Table E (55), there is a typographic error with Jefferson
Street being listed as a cross street of Washington Street. Also,
the anticipated lane improvements of all streets, with the exception
of Madison, is four lanes.
° Regarding mitigation measures, add the upgrading of all streets in
the cove area to City standards through the formation of an assess-
ment district or other forms of financing.
Noise (58)
�• ° Regarding mitigation measure 18, Section 6.08.050 of the Municipal
Code limits the hours for construction activities as follows:
October 1st Thru Monday - Friday: 7:00 a.m, to 5:30 p.m.
April 30th.... Saturday: 8:00 a.m, to 5:00 p.m.
Sunday: None
Govt. Code
Holidays: None
May 1st Thru
September 30th.... Monday - Friday: 6:00 a.m, to 7:00 p.m.
Saturday: 8:00 a.m. to 5:00 p.m.
Sunday: None
Govt. Code
Holidays: None
Bill Mayer, Project Manager
IM, Inc.
October 28, 1983
Page Four.
Cultural Resources (81)
° Regarding mitigation measure 31, we recommend that this section specify
that archaeological surveys and assessments be performed during the
preliminary engineering and design phase.
land Use (83-91)
° Regarding the table on existing residential characteristics (83), make
the following corrections or additions: 103 single-family attached
units and 18 single-family detached units are under construction; the
20 houses located in the rural agricultural areas (identified incorrectly
in the table as "farm houses") have already been included in total for
single-family detached units.
° Regarding paragraph 1, page 84, no accurate information is available on
the actual number.of developed residential lots in the cove. Because of
the small lot size (generally 50 feet by 100 feet), it is common that
houses are built on two lots. This is also true for ocnmercial lots
where the lot sizes are 25 or 50 feet by 100 feet.
° Regarding paragraph 2, page 84, the commercial buildings have space for
43 tenants, with the current total number of tenants being 35.
° Mention should be made that a development of the downtown commercially
zoned property has been extremely slow due to the following factors:
° Substandard lot sizes (25 or 50 feet by 100 feet)
° Substandard water system with inadequate fire flow
(and added construction costs of fire sprinkling
and fire walls)
° No sewers (due to the small lot size, there generally
is no or little space for a commercially -sized septic
system)
° Difficulty in assemblying adjacent parcels for new
structures
In addition, the substandard water system and lack of a sewer system
currently limits the types of commercial uses which can locate in the
downtown area. Businesses requiring a large fire flaw, such as a paint
store, could not currently locate here without substantial improvements
to the water system. Also, uses which generate a large amount of waste-
water, such as a laundranat, would have difficulty assemblying enough
land to allow for the large septic tank system.
° Regarding paragraph 4, approximately 600 units were constructed prior
to 1972. An estimated 300-400 units were constructed prior to 1969,
when seismigraphic safety standards were imposed under the Uniform
Building Coale.
Exhibit 15 showing existing general plan is not up to date.
° On page 86, paragraphs one and two amend the general plan description
to conform with the current general plan designations.
Bill Mayer, Project Manager
LSA, Inc.
October 28, 1983
Page Five.
° Regarding impacts, the increase in residential units, the upgrading of
public services and utilities, and the elimination of the flooding
hazard in the downtown area would increase the rate of commercial
development in the city center.
° Also, regarding impacts, the increased development will substantially
reduce the amount of open space within the city, greatly changing the
character of La Quinta fran a rural to an urban area. As a mitigation
measure, we recommend that future development's compliance with the
open space element as currently adopted, or later revised, to preserve
the hillsides and encourage open space areas.
° Concerning mitigation measure 41 (90), this appears to be a result of
redevelopment rather than a mitigation measure.
Ctnuunity Services (92-99)
° Regarding fire (92), mention should be made that:
° The fire station is located in a severe flooding area and
is subject to restricted access and damage during times of
heavy flooding.
° The station is operated 24-hours a day by a single paid
firefighter on each of three shifts; he is supported by a
15-member volunteer firefighter crew. Equipment at this
station includes one 1000-gallon-per-minute pumper and one
10 750-gallon-per-minute pumper. Response time to the site
will vary between two and four minutes.
° With respect to fire flow, the City has amended the 1979
Uniform Fire Code, as adopted by the City, decreasing the
fire flow requirenent for new single-family detached units
from 1500 GPM to 500 GPM. This was done because adherence
to the stricter requirement would have stopped all new
development of this type in the cove.
° Regarding police protection (92), the City will contract for increased
services as the area develops.
° Regarding schools (94), include discussion of the Coachella Valley
Unified School District.
° Regarding school impacts (96 and 98), the City does not currently
collect a school mitigation fee on new development. The City .is
currently discussing with the Districts other acceptable means of
mitigating the impacts of this anticipated growth in student numbers
n' and also for providing schools within our community.
Public Utilities (100-108)
Regarding water (100), contamination of the water supply by septic
tanks has not been documented.
° Regarding paragraph 3, amend the statement from "hot water" to warm
water.
Bill Mayer, Project Manager
I® Oct Inc.
October 28, 1983
Page Six.
' ° The source of Table H should be corrected to: State Department of
Health Services, Sanitary Engineering Branch, Exhibit No. 7 in the
I April 1, 1982 Public Utilities Cormission brief relating to a system
deficiency record report on Southern California, dated February 25,
1982.
I ° Regarding wastewater (100, 103), note the following: Page 100,
paragraph 2, change this to state that there have been instances
where septic tank systems have failed and the rate may increase over
time for the older systems with metal tanks.
I. A temporary sewage treatment facility is located approximately
one -quarter mile south of Avenue 50 along the Adams Street alignment.
I The effluent is disposed of via a leach field; the ground over the
leach field is planted in alfalfa.
° SCWC does not provide septic tank sewage disposal.
I ° Regarding impacts on the water (104), add to the second paragraph
that the cost of improving or expanding the water systems owned by
either CVWD or Southern California Water Campeny is paid by the
I developer.
° Regarding Mitigation Measure 73 (106), add mention of Southern
California Water Campany.
Alternatives to the Proposed Project (109-111)
° on page 109, paragraph 2, amend the last statement to read that impacts
would be less since area development will continue at a slower rate.
° On page 109, paragraph 4, the above statement also applies.
Additional Comments
° On page 2, paragraph 3, make the following correction: The area
contained within the redevelopment area is 1705 acres, with 1.196
acres located outside the current City limits.
Very truly yours,
CCMn7NITY DEVELOPMENT DEPART=
a L. Bonner
Principal Planner
° SLB:dmv
Q cc: Allan Robertson
LSA, Inc.
September 30, 1983
Frank M. Usher, Executive Director
La Quinta Redevelopment Agency
La Quinta City Hall
78-105 Calle Estado
La Quinta, CA 92253
RE: La Quinta Redevelopment Project Draft EIR
Dear Mr. Usher:
Thank you for the opportunity to review
La Quinta Redevelopment Project No. 1.
the following comments pertaining to the
Blight
RECEIVED OCT 3 1983
the Draft Environmental Impact Report for
The Riverside County Planning Department has
Draft EIR and the project.
In the comments provided by the Planning Department in response to the Notice of
Preparation it was requested that,"detailed information should be provided to
document the incidence of blight within the redevelopment area. The California
Health and Safety Code Section 33032 identifies a blighted area when one or more of
a number of characteristics exist." Nowhere in the draft EIR is this information
provided. The determination regarding the incidence of blight is crucial to any
redevelopment project. In order to determine that the intent of Community Redevelopment
Law is met, the existence of blight must be found and documented.
When redevelopment is discussed it is the context of rehabilitation, revitalization
or redevelopment. Inherent in this concept is the idea that something is being done
to bring about an original or former state of being. However, in reviewing the
draft EIR, it is stated that 'open -space and watershed uses are the mose predominent"
(page 83).in the project area. While development of a flood control system may be
desirable, it is generally not recognized as an eliminator of blight in open -space or
watershed areas. The primary purpose of a redevelopment project is the elimination of
blight, not a mechanism to finance desired public improvements.
Project Objectives
One of the stated project objectives is
their properties in accordance with the
the primary purpose of a redevelopment
of the general plan is accomplished by a
and zoning.
for "project -area property owners to develop
La Quinta General Plan" (page 5). However,
project is the removal of blight. Implementation
city through its general powers such as planning
4080 LEMON STREET, 9T" FLOOR
RIVERSIDE, CALIFORNIA 92501
46-209 OASIS STREET, ROOM 304
INDIO, CALIFORNIA 92201.
i September 30, 1983
Page
Mr, Frank M. Usher
t Approval of a redevelopment project for the implementation of the general plan
would be a misuse of the redevelopment process.
Alternatives
In accordance with the California Environmental Quality Act, each EIR must contain
eight areas of description and analysis. One of these areas is Alternatives to the
Proposed Action [Section 15143 (d)]. In this section viable alternatives should be
included. One such alternative would be the formation of a benefit assessment
district. The benefit assessment district mechanism could provide flood control
facilities that would eliminate the "impact of storm and floodwaters on the proposed
project area".(page 5). The elimination of this impact is one of the stated project
objectives.
Also, in the response to the NOP, it was requested that there be a discussion of
alternative financing methods such as the Roos Assembly Bill No. 3564, Community
Facilities Act and the Mello -Roos Senate.Bill No. 2001. This discussion is noticeably
absent.
Effects on Taxing Jurisdictions
One of the significant cumulative impacts the creation of this redevelopement agency
will have is on other taxing jurisdictions. However, nowhere in the EIR is this
impact identified. Tax increment financing does have costs to other taxing agencies
in the form of lost revenue. In order to weigh the redevelopement agency's benefits
against its costs, for both the short and long-term, this cumulative impact should
be further expanded upon.
It is hoped that these comments will be of assistance to you in the preparation of
the final Environmental Impact Report. If you have any questions, do not hesitate
to contact Linda Sarnoff at (714) 787-2297.
Very truly yours,
RIVERSIDE COUNTY PLANNING DEPARTMENT
Roger S. Streeter - Planning Director
Josgph A: Richards, Deputy Director
JAR/LBS/rk
CC: Tim Davis, Deputy County Counsel
Linda Thomason, Community Development
4PN Cq[iF
1� 00
V�i 9
SOUTHERN CALIFORNIA WATER COMPANY
3525 WEST SIXTH STREET • LOS ANGELES, CALIFORNIA 90000 • TELEPHONE (213) 366-7600
October 18, 1983
Is Quinta Redevelopment Agency
78-105 Calle Estado
Is Quints, California 92253
Attention: Mr. Frank Usher
Executive Director
Gentlemen:
We have reviewed your Draft Environmental Impact Report for the La Quinta
Redevelopment Project (State Clearing House No, 830,72017) and wish to take
exception to a few of the comments contained therein,
The draft EIR states, "CVWD serves most of the remaining city including all
new development." Our records indicate that new development in the South-
ern California Water Company service area for the last four years has been
approximately 61 services annually, or a growth rate of about 3.4%.
The draft EIR states, "...contaminants from septic tank leakage have infil-
trated into the water lines. To overcome this health hazard, the water is
heavily chlorinated, resulting in poor taste," 2 This statement is both
untrue and irresponsible, A modicum of chlorine is added as a preventative
measure against any bacterial growth under normal conditions.
The draft EIR states, "To provide pump pressure to the upper portions of the
Cove, the water is pumped through water pumps that have grown old with age.
In addition, sand and other debris washed into the pumg area from flood
runoff has caused pump failure and system down time, 3 The first sentence
is obvious and would hold true for any system supplying water to the upper
portions of the Cove. It should be noted that Southern California Water
Company has repaired or replaced 83.3% of the system operating pumps since
1979; the one remaining unit to be worked on is part of our 1984 maintenance
budget. The second sentence is not true in that sand and debris have never
caused a pump failure since we acquired the system.
1 LSA, Incorporated, "Draft EIR La Quinta Redevelopment Project",
® September 1983, Page 100.
2 Ibid.
3 Ibid
La Quinta Redevelopment
Agency -2- October 18, 1983
The draft EIR states, "Another problem relates to the shallow depth of
water line. In the summertime, many residents turn off their crater heaters
to save energy costs. Hot water is delivered to their homes from the solar
heating of the ground surface transferred to the water lines supply domestic
drinking water." 4 This statement is not true; our records indicate that
the temperature of the water coming from the wells is normally 80' Fahrenheit
or more.
The draft EIR states, "...many of La Quints's residences are provided septic
tank dewage disposal by SCWC". 5 This is not true.
The draft EIR states, "All sources need complete che!,_ical analyses for
General Mineral, General Physical, and Inorganic Chemicals." 6 Thi-- has been
done.
The draft EIR states, "Well 3 - Velasco - The open hole in,the casing needs
plugging". 7 This has been done.
The draft EIR states, "The system has inadequate storage capacity"'. 8 Our
records and analysis indicates that the supply and storage for La Quinta
meets the minimum standards established by the Public Utilities Conmiission
per General Order No. 103.
The draft EIR states, "Reservoir No. 1 - North M-dera - Roof in need of
repair". 9 This has been fixed.
The draft EIR states, "There may be inadequate pressurTOat meters in some
areas of the South Pressure Zone during peak demand This problem has
been corrected.
The draft EIR states, "The Well Drillers Report for all sources have not been
submitted." 11 When Southern California Water Company purchased the La Quinta
system, the well drillers' reports were not in the engineering records we
received, making it impossible for us to submit same.
4 Ibid. 10 Ibid.
5 Ibid 11 Ibid., Page 102.
6 Ibid. P. 101.
2 Ibid.
8 Ibid.
9 Ibid.
5_y
La Quinta Redevelopment
Agency -3- October 18, 1983
The draft EIR states, "A master plan for orderly development of the system
to meet needs of the service area has not been prepared and submitted to
this office." 12 This past week we took delivery on a microcomputerwhich
we intend to use for systems analysis and master planning; a master plan
for the City of La Quints is one of our higher priorities, and should be
completed within one year.
We appreciate being given the opportunity to comment on the Draft Erwiron-
mental Impact Report for this Redevelopment Project.
Sincerely,
C. Ross Burke, P.E.
Chief Engineer
SOUTHERN CALIFORNIA WATER COMPANY
CRB/las
12 Ibid.
riu
N'E IE6
} 1 I JC1
=` = Desert Sands Unified School District
U BERMUBA DUNES o
`RANCHO MIRAGE 42-87DHI4H•AY 111 • INDIO. CALIFORNIA 92291 • 1714) 34)-9931
INDIANKELLS
0,11 PALM DESERT �
P LA OUINTA ,�
INDIO
July 25, 1983
Frank M. Usher
City Manager
City of La Quinta
78-105 Calle Estado
La Quinta, California 92253
RE: La Quinta Redevelopment Project No. 1
Dear Frank:
The student population in the Coachella Valley has steadily increased
over the past number of years. This continued growth is anticipated
with the approval of each tentative tract. Population increase means
increased school enrollment. Currently our schools are housed in per-
manent and portable facilities to capacity and any additional housing
units will have a serious impact on school facilities.
Since we are unable to absorb any additional student enrollment without
additional school facilities, we can only advise that approval of ten-
tative tracts within the boundaries of Desert Sands Unified School
District is made with the understanding that there are no financial
resources at this point in time to provide additional school facilities.
Our mitigation statement filed with the County of Riverside and soon to
be acted upon by the Board of Supervisors asks for a mitigation fee of
$628 per dwelling unit or mitigation under CEQA. We would expect the
same mitigation within the City of Indio.
Sincerely,
I '
John D. Brooks
Assistant Superintendent,
JB/lr
Business Services
CI VNtFtfo
u
(619)
POST OFFICE BOX 947 / THERMAL, CA. 92274 / 12,UI 399-5137
Frank M. Usher, Executive Director
La Quinta Redevelopment Agency
City of La Quinta
P.O. Box 1504
La Quinta, California 92253
September 9, 1983
so
: co,6:D SY 2
RE: Document Transmittal and Notice Pursuant to Section
33327 of the California Community Redevelopment Law
Dear Mr. Usher:
Your letter dated September 6, 1983 on the above referenced document has
been reviewed and I would like to notify you that I am the officiel you
should contact to arrange for consultation with respect to the Pedevelopment
Plan for the proposed La Quinta Redevelopment Project. You may contact
me at the District Service Center, 87-225 Church Street (P.O. Box 847),
Thermal, California 92274, or by telephone at (619) 399-5137 Extension 24.
If I can be of further assistance to not hesitate to contact me al. the
above address of phone number.
ms
9
Sincerely,
- ` v,�y✓I'��
Dennis J. Leann
Assistant Superintendent
Business Services
Frank M. Usher
Executive Director
La Quinta Redevelopment Agency
City of La Quinta
P.O. Box 1504
La Quinta, Ca. 92253
83-180 Requa Ave., Suite #3
817jq}D-yKigSyPf1 - Indio, California 92201
September 12, 1983
RECEIVED SEP 1 4 1983
Dear Mr. Usher,
Our Board received your Redevelopment Agency information.
advise you that the person to contact on this project is:
Sam Aslan
District Conservationist
Soil Conservation Service
83-180 Requa Ave., Suite R3
Indio, Ca. 92201
Mr. Aslan has our copy in his office.
Sincerely,
Marty Walton
President, CVRCD
This letter is to
ESTABLISHED IN 1918 AS A PUBLIC AGENCY
COACHELLA VALLEY WATER DISTRICT
POST OFFICE BOX 1058
DIRECTORS
RAYMOND R. RUMMONDS. PRESIDENT
TELLIS CODEKAS. VICE PRESIDENT
JOHN P. POW ELL
PAUL W. NICHOLS
STEVE D. BUXTON
Frank M. Usher
COACHELLA, CALIFOaMIA 92236 . TELEPHONExx64r 398-2551
(619)
September 9, 1983
Executive Director
La Quinta Redevelopment Agency
78105 Calle Estado
La Quinta, California 92253
Dear Mr. Usher:
OFFICERS
LOWELL O. WEEKS. GENERAL MANAGER -CHIEF ENGINEER
BERNARDINE SUTTON. SECRETARY
VICTOR B. HARDY, AUDITOR
REDWINE AND SHERRILL. ATTORNEYS
10 Subject: Redevelopment Agency
In response to your letters to the Board of Directors of the Coachella
Valley Water District, Lowell 0. Weeks will be the contact person for the
District.
Yours very truly,
�4
Lowell 0. Weeks
eneral Manager -Chief Engineer
TEL:ra
TRUE CONSERVATION
USE WATER WISELY
Coachella Valley Resource Conservation District
83-180 Requa Ave., Suite N3 - Indio, CA 92201
Frank M. Usher
Executive Director
78-105 Calle Estado
La Quinta, Ca. 92253
Dear Mr. Usher,
October 5, 1983
RECEIVED OCT 1 0 1983
We acknowledge receipt of the environmental impact report for the La Quinta
Redevelopment Project No. 1, for the City of La Quinta.
We have reviewed the above environmental impact report and find no conflict
with any Coachella Valley Resource Conservation District on -going planned
programs or projects.
The environmental impact report did not adequately address alternatives to
the use of prime agricultural lands in the proposed project.
We appreciate the opportunity to review and comment on this proposed project.
Sincerely,
Marty Walton, President
Coachella Valley Resource Conservation District
9
CONSERVATION - -DEVELOPMENT - SELF-GOVERNMENT