2002 Final Environmental Impact ReportFINAL ENVIRONMENTAL IMPACT REPORT
FOR THE
CITY OF LA QUINTA GENERAL PLAN,
ANNEXATION NO. 12
AND
SPHERE OF INFLUENCE AMENDMENT
(SCH NO.: 2000091023)
Prepared for:
City of La Quinta
78-495 Calle Tampico
La Quints, CA 92253
Prepared by:
Terra Nova Planning & Research, Inc.
400 S. Farrell, Suite B-205
Palm Springs, CA 92262
TN1City of La Quints
Ceneral Plan Final Elk
Response to Comments on DEIIR
FINAL EIR
RESPONSE TO COMMENTS
ON
DRAFT ENVIRONMENTAL IMPACT REPORT
FOR THE
CITY OF LA QUINTA COMPREHENSIVE GENERAL PLAN,
ANNEXATION NO. 12 AND SPHERE OF INFLUENCE AMENDMENT
FEI3RUARY 1.4, 2002
CITY OF LA QUINTA
RIVERSIDE COUNTY, CALIFORNIA
STATE CLEARINGHOUSE No. 2000091023
AGENCY COMMENTS/RESPONSE 'I'0 COMMENTS
The Response to Comments on the Draft. EIR for the La Quinta Comprehensive General Plan has
been prepared in accordance with Section 15088, 15089 and 15132 of the California
Environmental Quality Act (CEQA) Guidelines. The fallowing agencies and interested parties
have commented on the Draft h1R.
Please note that Section 1 contains agency comments and subsequent responses. Section II
contains the full text of commenting agency correspondence.
SECTION 1:
The following comments were received on the Draft EIR transmitted to various public agencies
and interested parties. These comments concern aspects of the DEIR, including clarification of
information, limits of Comprehensive General Plan applicability, and similar issues. The
following responses have been prepared to address issues raised in the agency/interested party
comments,
A. Coachella Valley Water District 4
B. Coachella Valley Mosquito And Vector Control District I 0
C. Sunlinc Services Group 11
D. Riverside County Sheriff's Department 12
E. Southern California Gas Company 13
F. Southern California Asscciation Of Governments 15
Ci. The Vista Santa Rosa Association 31
I1. City Of Coachella 46
I. City Of Indian Wells 58
J. Gary Mitchell & Associates 60
K. Building Industry Association 74
1., U.S. Department Of The Interior, Bureau Of Land Management 77
I 1. ZI.S, Fish And Wildlife Service And California Department Of Fish And Game 81
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TN/City of La Quinta
General Plan Final FIR
Response to Comments on DETR
N. Lcc Anderson, Jr. 90
O. Kay Wolff 91
P. Jesse M. Mckee- er 95
0, Richard M. Foxx 38
R. Coachella Valley Archaeological Society 99
S. Ellen Lloyd Traver 100
T, Vic Broder 101
II Coley Linfoot & Kathy Linfoot 102
V. Sun Country Ranch, Norman And Gayle Cady l03
W. Matthew P. Wiedlrn 106
X. B. Mangan Smith 107
Y, Vista Santa Rosa Planning Committee, Ellen Lloyd Troyer 112
Z. Iris Capital Group 120
AA, City of Indio 130
SECTION II: All letters included in Section I, above, are provided in their original form, in
the following order:
Beginning on page 171
A. Coachella Valley Water District
B. Coachella Valley Mosquito And Vector Control District
O. Sunline Services Group
D. Riverside County Sheriffs Department
E. Southern California Gas Company
F. Southern California Association Of Governments
G. The Vista Santa Rosa Association
H. City Of Coachella
I. City Of Indian Wells
J. (iary Mitchell & Associates
K. Building Industry Association
L. U.S. Department Of The Interior, Bureau Of Land Management
M. U.S. Fish And Wildlife Serrric:e And California Department Of Fish And Game
N. Lee Anderson, Jr.
O. Kay Wckl f
P, Jesse M. Mckeevcr
Q. Richard M. Foxx
R. Coachella Valley Archaeological Society
S. Ellen Lloyd Trcver
T. Vic Broder
1 , Coley Linfoot & Kathy Linfoot
V. Sun Country Ranch, Norman And Gayle Cady
W. Matthew P. Wiedlin
XL B. Mangan Smith
Y. Vista Santa Rosa Planning Committee, Ellen Lloyd Troyer
Z. Iris Capital Group
AA. City of Indio
TN/City rxf La Quints
General Plan Final EIR
Response to Comments on DEIR
A. COACHELLA VALLEY WATER DISTRICT
A.1. Comment; This is in response to your transmittal and request for comments for the
above -referenced document dated July 13. We appreciate the
opportunity to respond to this document. The proposed annexation and
sphere of influence amendments are within our service area, Future
development within the subject area will most likely affect all live types
of facilities: domestic water, sanitation, stormwatcr, irrigation supply
and agricultural drainage.
We encourage the city's continuing cooperation in the Coachella Valley
Water Management 1'1an as a means of securing adequate water supplies
fur the future. Our comments can be found in Attachment A, enclosed.
Response: Comment noted.
A.2. Comment: Page 1-27, Water Resources, second paragraph, fourth sentence, please
revise to reflect the follDwing:
The district estimates that 40 percent of the domestic water used in the
upper valley is reintroduced into the groundwater table through
percolation.
In the lower valley (areas south and cast of Point Happy) this number
ranges between 50 percent and 25 percent depending on the
subterranean soil characteristics in the vicinity of a project.
Response: Comment noted, The sentence is hereby revised as follows:
"CVWD estimates that 40 percent of the domestic water consumed in
the upper Coachella Valley (areas west and north of Point Happy) is
reintroduced into the groundwater table through percolation. In the
lower valley (areas south and east of Point Happy), this number ranges
between 25 percent and 50 percent, depending on site -specific
subterranean soil characteristics.°'
A.3. Comment: Page I1-7, Water Quality/Resources, under the subheading of
Whitewater River Subbasin, third paragraph:
This sentence is incorrect. The increased water levels after 1951 was the
result of decreased use of groundwater after Colorado River water
became available for farm irrigation. After Colorado River water
became the primary source of agriculture water and groundwater Levels
4
TN/City of La Quinta
General Plan Final Ells
Resiiortse to Comments on DEIR
began to rise until the 1970's when well water was used for drip
irrigation.
Response: Comment noted. The paragraph is hereby revised as follows:
"Historic data indicate that water levels in the Whitcwater River
Subbasin declined steadily during the first half of the twentieth century.
After Colorado River water became available for farm irrigation around
1951, the demand for groundwater for irrigation purposes decreased, and
water levels in the Whilewater River Subbasin began to rise. Water
lcvcls rose until the 1970s, when well water began to be used for drip
irrigation. However, according to CVWD's Engineer's Report on Water
Supply and Replenishment Assessment (April 2000), water levels in the
lower Coachella Valley (south and east of Point Happy) have again
declined, partly as a result of increased urbanization and groundwater
usage,"
AA. Comment: Page III-75, Soils and Geology, under the subheading iviitigation
Measures, Item A:
'('his section is incorrect in suggesting that Lake Cahuilla may full under
the jurisdiction of the California Division of Safety of Darns. As a
federally owned facility, Lake Cahuilla is not under the jurisdiction of
the State Division of Dams. Lake Cahuilla is operated and maintained by
CVWD and it is the district's responsibility to maintain the structural
safety of the lake.
Response: Comment noted. Mitigation Measure A is hereby revised as follows:
"The City shall coordinate with the Coachella Valley Water District to
assure that the structural integrity of Lake Cahuilla and its levee system
is maintained to resist seismic damage and potential inundation of
adjacent lands."
In addition, page I13-74, first paragraph, last sentence is hereby revised
as follows:
"The Coachella Valley Water District is responsible for operating and
maintaining Lake Cahuilla and its levee system, and the City shall
coordinate with CVWD to assure that its structural integrity is
maintained."
Also, page III-80, last paragraph, the last two sentences, which refer to
the California Division of Safety of Dams, are hereby deleted,
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TN/City of La Quinta
General Plan Final EIH
Response to Comments on DEIR
Also, page III-86, Mitigation Measure B is hereby revised as follows:
"The City Engineer shall routinely consult and coordinate with the
Coachella Valley Water District to assure that the structural integrity of
Lake Cahuilla and its levee system is maintained."
A.S. Comment: Page III-81, Flood Hazard Areas should address the following:
Much of the area within the proposed annexation and the proposed
sphere of influence is currently identified as Zone D on the Federal
Flood Insurance Rate Maps that arc in effect at this time. A zone D
represents areas that have undetermined flood risks. As the city annexes
these areas, it becomes the local NFIP community with jurisdictional
responsibilities, The city should participate with CVWD in funding
flood risk studies for the subject area so that the proper flood risks can
be snapped.
Response: Comment noted. The following paragraph is hcrcby added to the "Flood
Ilazard Areas" discussion on pages III-8] and II1-83:
"Much of the land in the southeasterly planning area, v,ri thin the
proposed annexation and sphere -of -influence, is currently identified as
Zone D on the FIRM maps currently in effect, Zone D represents areas
in which potential flooding hazards have not been determined, Should
the City annex these lands in the future, it should coordinate with
CVWD in the preparation of flood risk studies for these areas so that
flood risks can be mapped and evaluated."
In addition, the following Mitigation Measure is hcrcby added to pa ,e
III-B6:
"Should the: City annex any lands in the southeasterly portion of the
planning area, which are designated as Zone D on FIRM maps, it shall
coordinate with CVY'D regarding the preparation and funding of flood
hazard studies and mapping,"
A.6. Comnrcpt: Page 1I146, Ilydrology, tinder the subheading Mitigation Measures,
Item C:
This paragraph refers to the seismic safety of CVWD's above ground
reservoirs. The water tanks currently meet seismic requirements and are
not in need of seismic retrofitting. District reservoirs are fitted with
seismic couplings to absorb seismic forces. The reservoirs are also fitted
with automatically actuated seismic valves that will shut off within 45
seconds of seismic activity.
TN/City of La Quints
General Plan Final EIR
Response to Comments on DI~IR
Response: Comment noted_ Mitigation Measure C is hereby revised as follows:
"The City shall coordinate with the Coachella Valley Water District to
assure that all future above -ground reservoirs are designed and
constructed in compliance with seismic safety requirements."
Also, on page III-74, first paragraph, the following sentences are hereby
added:
"Above -ground reservoirs in the planning area are owned and operated
by the Coachella Valley Water District and currently meet seismic safety
requirements. They are outfitted with seismic couplings, which absorb
seismic forces, and automatically actuated seismic valves that shut off
within 45 seconds of a seismic event."'
A.7. Comment: Page 111-87, Water Resources./Quality;
This section should refer to the Coachella Valley Draft Water
Management plan, prepared by CVWD, which discusses existing
conditions and mitigation goals for the general plan planning area. The
mitigation measures beginning on page 11I-94, should indicate the city's
support for itnplcrncnting the goals of the water management plan
including source substitution, conservation and groundwater recharge.
Response- Comment noted. The EIR text is hereby amended to incorporate the
following paragraph:
"The Coachella Valley Draft Water Management Plan, prepared by the
Coachella Valley Water District in November 2000, describes existing
and historical water conditions in the Coachella Valley and outlines the.
District's means of meeting water demands through 2035. The Plan
evaluates several alternatives for meeting future water needs and
recommends a preferred alternative, which incorporates a combination
of water conservation, source substitution, groundwater recharge,
additional water supplies, and ongoing groundwater monitoring
programs, The Plan sets goals for improving all components of regional
water management, including urban, golf course, overdraft, groundwater
replenishment, water quality, and agricultural water, and establishes
benchmarks by which progress can be measured. implementation of the
Plan will require the participation and cooperation of local residents and
public and quasi -public agencies serving the Valley, The City of La
Quinta supports the goals established by the Plan and will cooperate in
their implementation,"
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TN/City of LaQuicta
General PIan Pina1 EIR
Response to Comments on DEER
Also, the following mitigation measure is hereby added:
"The City shall cooperate in the implementation of the regional water
management goals established by the Coachella Valley Draft Water
lvlanagement Plan, including recharge, conservation, and source
substitution programs."
A.8. Comment: Page 111-89, Domestic Water Services third sentence:
This sentence identities the Myoma Danes Mutual eater Company as
the domestic water purveyor for all of the Bermuda Dunes area. This is
not correct in that the district has several domestic water customers in
Bermuda Dunes. Some of CVWD's customers are located cast of Adams
Street also on the north and south side of Darby Road and areas along
and adjacent to the east side of Washington Street. The jurisdictional
boundaries between different water agencies will be confirmed during
the city's planning review process for new developments.
Response: Comrncnt noted_ The last sentence of the first paragraph under the
subheading, Domestic Water Resources, is hereby deleted. "1'he
following is inserted in its place.
"CVW17 also serves several customers in Bermuda Dunes at the
following locations: east of Adams Street, along Darby fttiad, and along
and adjacent to the east side of Washington Street. The remainder of
Bermuda Dunes is located within the service area of the Myoma Durres
Mutual Water Company.
A.9. Comment: Page III-183, Domestic Water Service under the subheading Coachella
Valley Water District we recommend the following revisions:
First paragraph, second sentence we recommend the word limited be
deleted. The district serves many square miles of land south of Avenue
58.
First paragraph, third sentence we recommend that the part "A new well
is proposed..," be changed to "A new well has bean constructed."
First paragraph, fourth sentence we recommend that the part "The
existing wells have been drilled to depth ranging from 700 to 800
feet..." be changed to "The existing wells have been drilled to a depth
ranging from 700 to 1000 feet.. _'°
First paragraph, sixth sentence we recommend to he deleted completely.
TWeity of La Quinta
General Flan Final E1k
Kesponse to Comments on DE1R
Second paragraph, third sentence should be revised to affirm that
Reservoir No. 6725 has been constructed with a capacity of 10 million
gallons.
Second paragraph, fourth sentence should be revised to state the
district's plans to construct an additional 5- to 10-million gallon
reservoir near the southeastern edge of the La Quinta cove.
Response: Comments noted. The two paragraphs have been revised as follows:
A.1O. Comment:
"The Coachella Valley Water District (CVWD) is responsible for
providing potable water to the majority of the planning. area. Its service
area generally extends from Washington Street near Interstate-10 in the
north, to Avenue 56 to the south, as well as areas south of Avenue 58.
CV'VD has eleven active wells within the planning area. In addition, a
new well was recentiv constructed at the northeast corner of Airport
Boulevard and Madison Street. The existing wells have been drilled to
depths ranging from 700 to 1,000 feet below the surface. Two inactive
wells exist in the planning area within the PGA West development at the
southwest corner of 54th Avenue and Madison Street.
Domestic water is conveyed through water mains up to 36 inches in
diameter. CV\'V1's water distribution system includes five booster
stations located in the southern portion of the planning arca. L`VWI) also
has eight reservoirs with storage capacities ranging from 250,000
gallons to 10 million gallons. Reservoir No. 6725, which has a capacity
of l0 million gallons, was recently constructed in Lake Cahuilla County
Park. CVWD plans to construct an additional 5- to l0-million gallon
reservoir near the southeastern edge of the La Quinta cove "
Page V-20, Water Resources first paragraph, second sentence refers to
the current overdraft condition of about 0.24 percent per year. We
recommend the report stay consistent with section III-88 and use 0.32
percent for the year 1999.
Response; Comment noted, The sentence is hereby revised to read:
"As discussed in Section III of this document, the subbasin is currently
is an overdraft condition of about 0.32% per year."
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TNICity of La Quinta
General Plan Final RIR
Response to Comments on DEIR
B. COACHELLA VALLEY MOSQUITO AND VECTOR CONTROL DISTRICT
B.1. Comment: In regard to the proposed project, one of the District's concerns is in the
possibility of creating breeding sources for mosquitoes and aquatic
midges by constructing flooding retention basins and drainage systems.
The newly established drainage s}=sterns, although generally limited in
size and location by the plan, could support breeding sources for vector
species of mosquitoes, if not properly designed and constructed, It is a
fact that one of the indigenous mosquito species, C u i e x
quinquefasciatus, is a major- vector for St. Louis encephalitis and
western equine encephalomyelitis in the Coachella Malley.
Response: Comment noted.
B.2. Comment: The District would like to take this opportunity to bring to your attention
the necessity of incorporating our District in the process of evaluating
proposed architectural plans of drainage facilities and retention basins in
order to insure that the public is protected from vectors and nuisance
species that can be created by the proposed project.
Response: Comment noted, The following mitigation measure is hereby added to
Section III-E. Hydrology:
"The City shall consult and confer with the Coachella Valley Mosquito
and Vector Control District during the evaluation of plans for proposed
drainage facilities and retention/detention basins, to assure that the
public is adequately protected from vectors and nuisance species that
may he generated by the project.'°
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TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
SUNLINE SERVICES GROUP
C.1. Comment: Referencing section III page 36 under Public Transportation, changes to
our service in July 2001 included the combination of routes 86 and 91
into one route which will be called the Line 91. The combination of
these two routes will allow for better frequency for residents of the cast
end of the valley.
The Line 91 will operate eight round trips seven days a week.
Also, there were some additions to the Line 111. The Lint 111 now
operates 38 round trips on consistent 25 minute headways Monday
through Friday and 23 round trips on weekends at 44 minute headways.
The Line 70 which operates within La Quinta is scheduled for service
additions next July 2002. Our Planning and Operations Departments are
currently working on this project.
Response: Comments noted_ On page 1I1-36, the following sentence is hereby
added to the second paragraph:
"Line 70 is scheduled for service additions in July 2002."
The following sentences are hereby added to the fourth paragraph:
"In July 2001, Tine 86 and 91 were combined into a single route known
as Line 91. This line currently operates eight round trips, seven days a
week, and provides enhanced service to residents in the eastern
Coachella Valley.
The following sentence replaces the second sentence of the fifth
paragraph:
"Line 111 operates 38 round trips on consistent 25-minute hcadways,
Monday through Friday, and 23 round trips on weekends at 44-minute
headways.
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TN/City of La Quint t
Genera! Plan Final E;IR
Response to Ccrnments on DER
D. RIVERSIDE COUNTY SHERIFF'S DEPARTMENT
D.1. Comment: The Sheriff's Department has the following comments to make
regarding this plan.
Page 1I-15 (Police Protection) — The city currently contracts fir 82 hours
of patrol time per day. They also contract for a three-man special
enforcement unit, a school resources officer, two community service
officers, a motor officer, and a dedicated city sergeant.
Staffing levels and the law enforcement contract are reviewed annually.
Response: Comments noted. On page. 1I-15, the fourth paragraph is hereby revised
as follows:
"The Riverside County Sheriffs Department provides police protection
to the City of La Quinta, its sphere -cal -influence and the planning area.
The sheriff's station is located on Doctor Carreon Boulevard in Indio.
The City currently contracts for 82 Hours of patrol tirne per day, a three-
man special enforcement unit, a school resource officer, two community
service officers, a motor officer, and a dedicated city sergeant. Starting
levels and the law enforcement contract are reviewed annually. Incidents
and patrols within the unincorporated planning area are handled by
County beat cars_"
D.2. Comment: Page II1-172 (Police Protection/Existing Conditions) -- same as above
Response: Comments noted. The first paragraph on page III-172 is hereby amended
as follows:
"The City of La Quinta contracts with the Riverside County Sheriff's
Department for law enforcement services within the City limits. The
sheriff station that serves the City is located at. 82-695 Doctor Carreort
Boulevard in Indio. A ratio of one police officer for every 1,000
residents is considered a desirable standard in many communities
nationwide. The City currently contracts for 82 hours of patrol time per
day, a three-man special enforcement unit, a school resource officer, two
community service officers, a motor officer; and a dedicated city
sergeant. The City's staffing levels and law enforcement contract are
reviewed annually, Deputies currently have a five-minute response time
throughout the City.'
12
IN/City of La Quinia
General Flan Final EIR
- Response to Comments on DEMR
E.1. Comment:
Response:
F.2. Curnui ritr
Response:
E.3. Comment.
E. SOUTHERN CALIFORNIA GAS COMPANY
Thank you for the opportunity to respond to the above -referenced
project. Please note that Southern California Cias Company has facilities
in the area where the above named project is proposed, Gas service to
the project could be provided without any significant impact on the
environment. The service would bc in accordance with the Company's
policies and extension rules on file with the California Public -Utilities
Commission at the time contractual arrangements are made.
Comment rioted.
You should be aware that this letter is not to be interpreted as a
contractual commitment to serve the proposed project, but only as an
informational service. The availability of natural gas service, as set forth
in this letter, is based upon present conditions of gas supply and
regulatory policies. As a public utility, The Southern California Gas
Company is under the jurisdiction of the California Public utilities
Commission. We can also be affected by actions of federal regulatory
agencies. Should these agencies take any action, which affects gas
supply, or the conditions under which service is available, gas service
will be provided in accordance with revised conditions.
Comment noted_
Typical demand use for
a. Residential (System Arca Avcrage(Use Per Meter)Yearly
Single Family 799 therms/year dwelling unit
Multi -Family 4 or less units 482 therms/year dwelling unit
Multi -Family 5 or more units 483 therms/year dwelling unit
These averages are based on total gas consumption in residential units
served by Southern California Gas Company, and it should bc not bc
implied that any particular home or tract of homes will use these
amounts of energy.
b. Commercial
Due to the fact that construction varies so widely (a glass building vs. a
heavily insulated building) and there is such a wide variation in types of
materials and equipment used, a typical demand figure is not available
for this type of construction. Calculations would need to he made after
the building has been designed.
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TNICity of La Quinta
General Plan Final EIR
Response to Comments on DEng
Response: Comment noted.
E.4. Comment: We have Demand Side lanagernent programs available to
commercial/industrial elastomers to provide assistance in selecting the
most effective applications of energy conservation techniques for a
particular project.
ReNponse: Comment noted.
14
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
F. SOUTHERN CALIFORNIA ASSOCIATION OF GOVERNMENTS
F.1. Comment: The Draft EIR does not addresses the relationship of the proposed
project to applicable regional plans as required by Section 15125 [d] of
Guidelines for Implementation of the California Environmental Quality
Ace.
The Final FIR should address the relationships (consistency with core
policies and support of ancillary policies) to SCACi's Regional
Comprehensive Plan and Guide, utilizing commentary from the
following detailed SCAG staff comments. The response should also
discuss any inconsistencies between the proposed project and applicable
regional plans. We suggest that you identify the specific policies, by
policy number, with a discussion of consistency of support with each
policy.
Response: Cornmcnt noted. The responses below address each of the issue areas
raised in SCA.(i's comment letter.
F.2. Comment: The Growth Management Chapter (GMC) of the Regional
Ccrnprchensive Plan and Ciuidt' contains a number of policies that are
particularly applicable to the City of La Quinta Comprehensive General
Plan I Jpdate.
Core Growth A•ariagement Policies
3.111 The population, housing, and jobs- fo recasts, which are adopted by
SCAG's Regional Council and that reflect local plans andpolicies, shall
be used by SCAG in all phases of implementation and review.
SCAG staff comments. The Draft EIR references the adapted RIP 1998
SCAG's Population, Household and Employment forecasts for the City
of La Quinta. The Draft EIR should use growth forecasts from the
adopted 2001 RTP, which were included in SCAG's May 23, 2001 letter
on the Corrected NOP for the proposed Project. The estimates in the
Draft FIR arc slightly above the adopted RTP growth forecasts. The
Project is partially consistent with this core RCPG policy.
Response: Comment noted. Table 1II-44 on page III-198 of the EIR, which
identifies SCAG Growth Forecasts for the City is hereby revised as
follows, to reflect the adopted 2001 RIP forecasts:
15
TN/City of La Quint(
General Plan Final EIR
Response to Comments on DE1R
Table III-44
Growth Forecasts for the City of La Quinta
Years 2000-2020
Projection
Population
I-Iouseholds
Employment
2000
21,194
6,813
6.879
2005
24,452
7,750
S,603
2010jj
30,369
9,490
10,383
2015
36,189
11,154
11,434
2020
44,084
13,199
12,404
Source: Southern California Association of Governments. letter correspondence, May 23, 2001.
F.3. Comment:
3.03 The timing, financing, and location of public facilities,
systems, and transportation systems shall be used by SCAG to implement
the region 's growth policies.
utility
SLAG staff comments. the Drat EtR does not present a discussion on
Project phasing and timing. Tt would be helpful if the Final )EIR would
provide a discussion and address the manner in which the Project is
supportive or detracts from the achievement of this policy. Based on the
information provided in the Draft E1R, we are unable to determine if the
Project is consistent with this core RCPG policy_
Response: The proposed Project is a Comprehensive General Plan with a planning
arca of approximately 53,498 acres. It is difficult to predict the timing,
much less the location and type of financing of future public facilities,
utility infrastructure, and transportation systems, as such information is
entirely dependent upon the location and nature of future site -specific
development proposals, which will be generated over the life of the
General Plan. However, the City has implemented a Developer Impact
Fee Program which provides for the funding of General Plan roadway
improvements on a 'fair share" basis. The future participation of
individual projects in this program will ensure that transportation
facilities are improved as needed to meet the SCAG Plan policy.
The General Plan includes a wide range of policies and programs that
help assure that the community's growth and development will be
orderly and timely. The City will coordinate closely with the Coachella
Valley Water District and numerous other public and quasi -public
agencies (described in Section TIT -I, and throughout the E1R) in the
implementation of public utility programs and infrastructure extensions.
The City will continue to coordinate closely with the Coachella Valley
Association of Governments (CVAG) in the implementation of the
Transportation Uniform Mitigation Fee program, and Caltrans, the
Sunline Transit Agency, Riverside County Airport Authority, and Union
Pacific Railroad regarding the potential expansion and funding
transportation systems in the planning area. Policies and programs are
dispersed throughout the General Plan and EIR.
16
TN/City of LaQuinta
General Plan Final EIR
Response to Comments an DEER
F.4. Comment: The Regional Transportation Plan (RTP) also has goals, objectives,
policies and actions pertinent to this proposed project. This RTP links
the goal of sustaining mobility with the goals of fostering economic
development, enhancing the environment, reducing energy consumption,
promoting transportation -friendly development patterns, and
encouraging fair and equitable access to residents affected by socio-
economic, geographic and commercial limitations. Among the relevant
goals, objectives, policies and actions of the RTP are the following:
Core Regional Transportation Plan Policies
4.01 Transportation investments shall be based on SCAG's adopted
Regional performance indicators.
SCAG staff comments. The Draft Elk does not provide a discussion on
Transportation investments based on the following SCAG adopted
Regional Performance indicators:
Mobility — Transportation Systems should meet the public need for
improved access, and ,tor safe, comfortable, convenient, faster and
econo is movements of people and goods_
• Average Work Trip Travel Time in Minutes' 25 minutes (Auto)
• PM Peak freeway Travel Speed -- 45 minutes (Transit)
■ PM Peak Non -Freeway Travel Speed
• Percent afPM Peak Travel in Delay (Fwy)
• Percent of PM Peak Travel in Delay (1lon-Fwy)
.accessibility — Transportation system should ensure the ease with which
opportunities are reached. Transportation and kind use measures should
he employed ru ensure minimal time and cost.
▪ Work Opportunities within 45 Minutes door to door travel time (Mode
Neutral)
■ Average transit access thne
Environment — Transportation system .should sustain development and
preservation of the existing system and the environment. (All trips)
■ CO, ROG, I rOx, Plv12, 5 — :'lfeet the applicable SIP Emission
Budget and the Transportation Conformity.' requirements
Reiiabidity — Transportation .system should have reasonable and
dependable levels rrf service by mode, (All trips)
■ Transit — 63
■ Highway - 76%
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TN/City aria Quints
General Plan Final DR
Response to Comments on DEIR
Safety - Transportation systems should provide minimal accident, death
and injury. (All Trips)
• Fatalities Per Million Passenger Miles- 0
• Injury Accidents - 0
EguEnvironmentai Justice - The benefits of transportation
investments should be equitably distributed among all ethnic, age and
income groups. (All trips)
• By Income Groups Share of Net Benefits - Equitable Distribution of
Benefits among all Incorne Quintiles
Cost -Effectiveness - Maximize return on trarz.spartaticin investment (All
Trips). Air Quality, Mobility, Accessibility and Safety
• Return on Total Investment - Optimize return on Transportation
Investmennts
The Final EIR should address the manner in which the Project is
supportive of or detracts from the achievement of the eight core RTI'
objectives. Based on the information provided, we are unable to
determine whether the Project is consistent with this core RCPG policy.
Response: The La Quinta and Coachella Valley transportation systems currently
meet the public need for improved access, and will continue to do so in
the future. The General Plan supports and facilitates the safe,
comfortable, convenient and economical movement of people and
goods. As stated in the General Plan Traffic Study (included in the
Appendix of the EIR), work trips originating in La Quinta are projected
to be below the average 25-minute travel time target, and well above the
PM peak freeway travel speed target of 45 mph. PM peak travel delays
are projected to be limited to about 10%.
The General Plan ]sand Use Plan provides a good balance between
employment and housing, and a wide range of work opportunities are
available both within the planning area and surrounding communities.
Nearly all employment opportunities in the Coachella Valley are within
a 25-minute travel distance of La Quinta. Sunline Transit provides
public transit service to major employment, residential, and commercial
centers in the planning area and Coachella Valley.
The existing and planned City and regional transportation systems, as
modeled in the 2020 C.VATS model prepared by SCAG, are expected to
sustain development and preserve the existing system and the
environment. The region is a leader in the use of compressed natural gas
for mass transit (Sunline Transit) and in local government vehicle fleets.
The General Plan includes policies and programs that encourage
IR
TN/City of La Quints
General Plan Final FIR
Response to Comments on DFIR
employers to Lttilize telecammuting and home -lased employment
opportunities, non -peak hour schedules, and multi -occupant modes of
transportation to contribute to further reductions in emissions and traffic
volumes. The Plan proposes a Golf Cart Route System and requires the
City to prcparc and adopt a comprehensive Trails Master Plan of
continuous multi -use trails and bicycle routes, which will provide the
community with additional environment -friendly travel alternatives. The
City and region are expected to meet or better the emission budgets
established by SCAC°.
The General Plan FIR analyses a worst -case scenario with regard to
future traffic volumes and asscciated impacts to local and regional roads.
As shown in the traffic analysis in the I]rall Ilk and Technical
Appendix I7, with few exceptions, the City and regional transportation
system is expected to continue to provide reasonable and dependable
levels of service by all modes. Where exceptions may occur, a variety of
mitigation measures, including roadway classification and cross-section
upgrades, intersection improvements, and monitoring programs at
critical intersections, will provide for acceptable and reliable levels of
service.
The goals, policies, and programs of the Circulation Element and the
mitigation measures set forth in the Draft Elf< are designed to preserve
roadway capacity and minimize the type of conditions most closely
associated with unsafe transportation systems. The proposed Plan does
not introduce any elements which are anticipated to result in unsafe
travel conditions or hinder the City's ability to meet the injury, accident,
and fatality standards set forth by SCAG,
Implementation of the CVATS transportation model and TUMF
program are the first level of assurance that transportation costs tre and
will continue to be equitably distributed across all socio-economic
sectors of the community. In addition, the City has implemented a
Developer Impact Fee Program which provides for the funding of
General Plan roadway improvements on a "fair share" basis. The future
participation of individual projects in this program will ensure that
transportation facilities are improved as needed. Sunline Transit offers
an excellent valley -wide public transit system that provides access to all
sectors of the population and accommodates special needs populations
through its curb -to -curb Sunliial service.. The policies and programs
found in the Circulation Element support and promote the equitable
distribution of infrastructure investment and system availability.
F.S. Comment: 4,02 Transportation nsportation investments shall mitigate environmental impacts
to an acceptable level.
19
TN/City of La Quints
General Plan Final EiR
Response to Comments on DE1R
SCAG staff comments_ The Draft F]R in Section 3-C
(Traffic/Circulation) identifies transportation and circulation impacts,
and details the measures to mitigate these impacts on page III-58. The
Project is consistent with this core RCPG policy.
Response: Comment noted.
F.6. Comment: 4,04 Transportation Control Measures .hall be a priority.
SCAG staff comments. The Draft EIR, on page Ili-58, includes a
discussion en the City's development and implementation of
Transportation Demand Management strategies, to extend of prescrvc
capacity roadways. In addition, mitigation measures support the
implcinentatiun of "Transportation Control Measures. The Project is
consistent with this core RCPG policy.
Response: Comment noted.
F.?. Comment: 4.16 .ifaintairting and rrperating the eaistintg transportation system will
be a priority over expanding capacity.
SCAG staff comments. The Draft EIR, in Section 3-C
(Traffic/Circulation) includes a discussion on the existing circulation
system, and recommends measures to upgrade the existing circulation
system. This should maintain and operate the existing transportation
system. The Project is consistent with this core RTP policy.
Response: Comment noted.
F.8. Comment: The Growth Management goals to develop urban forms that enable
individuals to spend less income on housing cost, that minimize public
and private development costs, and that enable firms to be competitive,
strengthen the regional strategic goal to stimulate the regional economy.
The evaluation of the proposed project in relation to the following
policies would be intended to guide efforts toward achievement of such
goals and does not infer regional interference with local land use
powers.
3,05 Encourage patterns of urban development and land use, which
reduce costs on infrastructure construction and snake better use of
existing facilities.
SCAG staff comments. The Draft EIR in Sections 3-C
(Traffic/Circulation) and 3-L (Public Services and Facilities)
20
TN/City of La Quinta
Genera] Plan Final FIR
Response to Comments on T)EMR
acknowledges that the Project will maximize the use of existing
infrastructure and improve infrastructure deficiencies to meet the needs
of the proposed Project. In addition, increases in demand for services
will occur gradually as additional development takes place. Mitigation
measures recommended in each section would address identified
impacts. The Project is supportive of this ancillary RCPG policy.
Response: Comment noted.
F.9. Comment: 3. 09 Support local jurisdictions' cffir1s to minimize the cost of
infrastructure and public service delivery, and e.fforts to seek new
sources offundingfir development and the provision of services.
SCAG staff comments. See SCAG comments on policy 3,05. The
Project is supportive of the ancillary RCPG policy.
Response: Comment noted.
F.10. Comment: 3,10 Support local jurisdictions' actions to minimize red rape and
expedite the permitting process to Maintain economic vitality and
competitiveness,
SCAG staff comments. The Draft E.IR only addresses subjects that may
have adverse environmental impacts. It is written in a concise manner,
where all possible adverse impacts are mitigated this will help minimize
re tape, and help maintain the economic vitality and competitiveness of
the City of La Quinta. In addition, the Draft EIR. on page I-30, includes
a number of General Plan goals and policies, which will also help to
minimize red tape, and help maintain the economic vitality and
competitiveness of the City of La Quinta. The Project is supportive of
this ancillary RCPG policy,
Response: Comment noted.
F.11. Comment:
The Growth Management goals to attain mobility and clean air goals and
to develop urban farms that enhance quality cif life, that accommodate a
diversity of life styles, that preserve open space and natural resources,
and that are aesthetically pleasing and preserve the character of
communities, enhance the regional strategic goal of maintaining the
regional quality of life. The evaluation of the proposed project in
relation to the following policies would be intended to provide direction
for plan implementation, and does not allude to regional mandates.
3.12 Encourage existing or proposed local jurisdictions' programs
aimed at designing land uses which encourage the use of transit and
21
TN/City of La puinta
General Plan Final ERR
Response to Comments on DER
thus reduce the need for roadway expansion, reduce the number of auto
trips and vehicle Miles traveled, and create opportunities for residents to
walk and bike.
SCAG staff comments. The Draft LIR dues not include a discussion on
land uses that encourages the coordination and implementation of transit
and transit facilities, and bikeways, pedestrian and/or equestrian trails. It
would be helpful if the Final EIR would provide a discussion and
address the manner in which the Project is supportive or detracts from
the achievement of this policy. Based on the information provided in the
Draft EIR, we are unable to determine if the Project is supportive of this
ancillary RCPG policy.
Response: The Land Use Plan of the General Plan is designed to provide a balanced
mix of housing and employment opportunities, which will contribute to
reductions in the number of auto trips and vehicle miles traveled in the
City and the Coachella Valley region. The EIR includes a
comprehensive discussion and mapping of a proposed golf cart route
system on pages III-44 through III-48, which is aimed at encouraging
and accommodating this safe, economical, convenient, and non-
polluting alternative mode of transportation. Furthermore, Mitigation
Measure Items C, D, F., F. 6, and .N on pages 111-58 and i11-59 of the
Draft EIR identify specific rnt chanisms that will encourage the
continued use and future expansion of public transit, multi -use trails,
bicycle routes, and flexible employment opportunities, all of which will
reduce the need for roadway expansion and reduce the number of auto
trips and vehicle miles traveled.
F.12. Comment: 3.13 Encourage local jurisdictions' plans that maximize the use of
existing urbanized areas accessible to transit through i.n, ll and
rc cleveiuprnent.
SCAG staff comments. The Draft ETR does not address the subject of
transit service to serve and provide access to new development and
redeveloped areas. It would be helpful if the Final Ells would provide a
discussion and address the manner in which the Project is supportive or
detracts from the achievement of this policy. Based on the information
provided in the Draft EIR, we are unable to determine if 1l1L Project is
supportive of this ancillary RCPG policy.
Response: Policy 6 on page 1-31 of the Drafi. EIR, and Policy 6 of the General Plan
Land Use Element, clearly state that the City shall promote in -fill
development by prioritizing capital improvements in developed areas of
the City. Furthermore, Mitigation Measure Item D on page ITT-58
requires that, prior to the approval of development proposals, the City
22
TN/Cty of La Quinla
General Plan Final EIR
Response to Comments on 1DEIR
and developers confer with the Sunline Transit Agency to determine
optimal locations for bus turnouts and covered bus shelters within the
project and its vicinity. Implementation of this policy will assure that
transit service is extended to ail new development, to the satisfaction of
(he City and Sunline Transit Agency,
F.13. Comment: 3.17 Support and encourage settlement patterns, which contain a range
of urban densities,
SLAG staff comments. The Draft EIR in Section 3-A (Land Use
Compatibility) identifies a range of urban densities. The Project is
supportivc of this ancillary RCPG policy.
Response: Comment noted.
F.14. Comment: 3.18 Encourage planned development in locations least likely to cause
adverse environmental impact,
SCAG staff comments. The Project is proposed in a manner, which will
minimize adverse environmental impacts, Mitigation measures included
in the Draft EIR have been developed to address identified impacts. The
City of La QuintEL should carefully consider the adequacy of these
measures_ The Project is supportive of this ancillary RCPG policy.
Response: Comment noted.
F.15. Corn meii t:
3.20' Support the protection of vital resources such as wetlands,
groundwater recharge areas, woodlands, production lands, and land
containing unique and endangered plants and animals.
SCAG stab' comments. The Draft EIR in Section 3-0 (Biological
Resources) discusses the Projects' impact on biological resources. The
Draft EIR recommends a number of mitigation measures to address
impacts to plants, invertebrates and reptiles, birds and mammals. The
Project is supportive of this ancillary RCPG policy.
Response: Comment noted.
F.16. Comment: 3.21 Encourage the implernenrcttlon of measures aimed at the
preservation and protection of recorded and unrecorded cultural
resources and archaeological sites.
SCAG staff comments. The Draft EIR in Section 3-H (Cultural
Resources) identifies potential impacts related to archaeological and
historic resources. A number of mitigation measures are recommended
23
TN/City of La Quinla
General Plan Final MR
Response to Comments on DE1R
to address impacts to archaeologic and historic resources. The Project is
supportive of this ancillary RCPG policy.
Response: Comment noted.
F.17. Comment:
3.22 L)i courage development, or encourage the re,se of special design
requirements, in areas with steep slopes, high fire, flood, and seismic
hazards.
SCAG staff comment. The Draft EIR in Section 3-D (Soils and
Geology) identifies potential impacts to soils, seismicity, induced slope
instability, induced inundation and liquefaction. Mitigation measures
recommended include the implementation of building codes, specific
requirements anchor project design. The Project is supportive of this
ancillary RCPG policy.
Response: Comment noted.
F.18. Comment:
3.23 Encourage mitigation measures that reduce noise in certain
locations, measures aimed at preservation of biological and ecological
resources, meas•ur'es that would reduce exposure to seismic hazards,
minimize earthquake damage, and to develop erner'geary response and
recovery plans.
SCAG staff comments. The Draft FAR in Section 1-N (Noise)
acknowledges potential noise impacts related to aviation, traffic,
stationary noise sources and construction activities. Mitigation measures
recommended in this Section have been developed to address identified
impacts. The Project is supportive of this ancillary RCPG policy.
Response: Comment noted.
F.19. Comment:
The Growth Management Goal to develop urban forms that avoid
economic and social polarization promotes the regional strategic goal of
minimizing social and geographic disparities and of reaching equity
among all segments of society. The evaluation of the proposed project in
relation to the policy stated below is intended guide direction for the
accomplishment of this goal, and does not infer regional mandates and
interference with local land use powers.
3,24 Encourage efforts Of local jurisdictions in the implementation of
programs that increase the supply and quality of housing and provide
affordable housing as evaluated in the Regional Housing Deeds
Assessment.
21
TN/City of La Quinta
General Plan Final FIR
Response to Comments on DEIR
SCAC staff comments. The Draft EIR, in Section 3-A (Land Usc
Compatibility) provides a discussion on residential land uses. The
discussion suggests that there is the potential for 78,952 units at
buildout, or an increase of 66,811 units over the long term, The Draft
EIR, however, does not provide a discussion on programs that could
increase thc supply and quality of housing and the provision of
affordable housing. It would be helpful if the Final FIR would provide a
discussion and address the manner in which the Project is supportive or
detracts from the achievement of this policy. Based on thc information
provided in the Draft EIR, the Project is partially supportive of this
ancillary RCP° policy.
Response: The General Plan Ilousing Element is being prepared separately and will
be processed immediately following the General Plan policy document.
The Element will identify and describe specific programs that will
increase the supply and quality of housing in the planning area,
including affordable housing. Potential environmental impacts
associated with future housing policies and programs will also be
evaluated,
However, the General Plan and Draft DR include a variety of
implementation strategics directed at encouraging Frnd maintaining high -
quality residential development within the planning area_ Policy 6 of the
General Plan Land Use Element (Residential, p. 18) clearly states that
the City will use development incentives to achieve a mix of housing,
including affordable housing. Other policies and programs contained in
the Land Usc Element require that the ❑evelopment Code include
design standards which assure high quality development, and require the
preparation of Specific Plans, under certain circumstances, to better
define site -specific design parameters. Other design and performance
standards address the use of building setbacks, height restrictions, pad
elevations, infill development, and density transfers to assure that future
development is compatible with the surrounding environment.
Mitigation Measures described in Section III-K, Visual Impacts, of thc
EIR require that new development complement the existing natural and
built environments through the use of native landscaping materials,
undergrounding of utilities wherever possible, restricting outdoor
lighting and signage, preserving the quality of scenic viewsheds, and
enhancing the character of neighborhoods and street corridors through
urban and architectural design. The above -described policies and
programs are intended to improve the development standards currently
in place,
25
F.2[I. Comment:
TN/City of La Quinta
General Plan Final EIR
Res rise to Comments on DEIR
3,27 Support local jurisdictions and other service providers in their
efforts tv develop sustainable communities and provide, equally to all
members of society, accessible and effective services such as: public
education, housing, health care, socia/ services, recreational facilities,
law enforcement, and fire protection.
.SCAG staff comments. The Draft EIR, in Section 3-L (Public Services
and Facilities) acknowledges that the potential build out of the. General
Plan would have impacts on schools, libraries, police and fire protection,
health care facilities and services. Mitigation measures are
recommended to address impacts to services. The Project is supportive
of this ancillary RCPG policy.
Response: Comment noted.
F.21. Comment:
`1'he Air Quality Chapter (AQC) core actions that are generally
applicable to the Project arc as follows:
5.07 }Determine specific programs and associated actions needed (e.g_,
indirect ,source rides, enhanced use of telecommunications, provision of
community based shuttle services, provision of demand management
based programs, or vehacic:-miles-traveledriemrssiun fees) so that options
to command and control regulations con be assessed.
SCAO staff comments, Sec SCA° staff comments fur policy 4.02. The
Draft EIR, in Section 3-I (Air Quality), includes a number of mitigation
measures that encourages the implementation of measures that focuses
on trip reduction, improving traffic flow, pedestrian movement, biking,
public transit and utilizing alternative methods of transportation. The
Project is consistent with this core RCPcr policy.
Response: Comment noted.
F.22. Comment:
5.11 Through the environmental document review process, ensure that
plans at all levels of government (regional, air basin, county,
subregio;crl and local) consider air quality, land use, transportation and
ecanorrnic relationships to r.'n.sure consistency and minimize conflicts.
SCAG staff comments. The Draft EIR, in Section 3-1 (Air Quality)
discusses the consistency of the proposed Project with regional and local
air quality policies and includes mitigation measures for impacts to air
quality. The Project is consistent with this core RCPG policy.
Response: Comment noted.
2G
TN/City of La quints
General Plan Final FIR
Response to Comments on ❑E[R
F.23. Comment: The Water Quality Chapter core recommendations and policy options
relate to the two water quality goals: to restore and maintain the
chemical, physical and biological integrity of the nation's water; and, to
achieve and maintain water quality objectives that are necessary to
protect all beneficial uses of all waters.
11.07 Encourage water reclamation throughout the region where it is
cost -elective, feasible, and appropriate to reduce reliance on imported
water and wastewater discharges. Current administrative impediments
to increased use of wastewater should be addressed
SCAG staff comments. The Draft EIR does not provide a discussion on
reclaimed water. It would be helpful if the Final EIR would provide a
discussion and address the manner in which the Project is supportive or
detracts from the achievement of this policy. Based on the information
provided in the Draft EIR, we are unable to determine if the Project is
consistent with this core RCPG policy.
Response: The production and use of tertiary treated water by the Coachella Valley
Water District is addressed on pages III-89 and III-90 of the Dram. EIR,
and Mitigation Measure stem G an page III-95 clearly states the City_s
intention to support the continued use and future expansion of tertiary
treated water in the planning area.
F.24. Comment: Outdoor Recreation
9.01 Provide adequate land resources to meet thee: outdoor recreation
needs of the present and future residents in the region and to promote
tourism in the region_
SCAG staff comments. The proposed Project provides for approximately
14,120-acres of open space for park facilities, golf courses, open space
and watercourse. The Project is supportive of this ancillary RCPG goal.
Response: Comment noted.
F.25. Comment. 9.02 Incretise the accessibility to open space lands for outdoor
recreation.
SCAG staff comments. See SCAG staff comment for goal 9.01. The
Project is supportive of this ancillary RCPO goal.
Response: Comment noted.
27
TN•City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
F.26. Comment: 9, 03 Promote self-sustaining regional recreation resources and
facilities.
SCAG staff comments. The Draft L iR does not discuss the subject of
self-sustaining regional resources and facilities. It would be helpful if the
Final EIR would provide a discussion and address the manner in which
the Project is supportive or detracts from the achievement of this policy.
Based on information provided in the Draft EIR, we arc unable to
determine if the Project is supportive of this ancillary RCPG goal.
Response: As described in Section III -A (Land Use Compatibility), the proposed
Plan provides for 14,12O± acres of Open Space lands, including park
facilities, open space, golf course, and watercourse lands. Policies and
programs contained in the General Plan Land Use and Parks and
Recreation Elements support the continued development of public and
private recreational facilities, including golf courses and a range of
neighborhood, community, and regional parks. As per these policies and
programs, the City is required to utilize Quimby Act standards to charge
park fees and facilitate future park development in residential
subdivisions, and to budget for the development and maintenance of
additional parks to meet the future needs of City residents. The City will
also consult and coordinate with local school districts regarding the
shared use of public school, park and recreation facilities_ In this regard,
the General Plan is supportive of the above -referenced RCPG goal.
F.27. Comment: 9.04 Maintain opera space for adequate protection of lives and
properties against natural and roan -made hazards_
SCAG staff comments. The Draft EIR does not discuss the subject of
open space for the protection of lives against natural and man-made
hazards, It would be helpful if the Final EIR would provide a discussion
and address the manner in which the Project IN supportive or detracts
from the achievement of this policy. Based on information provided in
the Draft EIR, we are unable to determine if the Project is supportive of
this ancillary RCPG goal.
Response: The goals, policies, and programs set forth in the Open Space and
Environmental Hazards Elements of the General Plan are supportive of
this RCPG goal. Policies 2 and 5 of the Open Space Element state that
the following hazardous areas shall be maintained as open space, where
appropriate: hillsides and alluvial fans with slopes exceeding 20 percent,
earthquake faults, floodways, unstable slopes, and areas susceptible to
liquefaction. Policy 1 of the Flooding and Hydrology section of the
Environmental Hazards Element requires that major flood control
facilities be designated as Open Spacclatcrcoursc and used only for
28
TN/City cf La Quinta
General Plan Final ER
Response to Comments on DEIR
F.28. Comment:
flood control, open space, and recreational purposes, as appropriate. The
proposed Land Use Plan and corresponding map designate 6021 acres
for Watercourse purposes, including levees, stormwater channels, debris
basins, and other stormwater management facilities_ Finally, the
I l.azardous Materials section and the Emergency Preparedness section of
the Environmental Hazards Element address issues of roan -made
hazards, and the City's ability to respond to these hazards. These
policies and implementation strategics are designed to protect life and
property from the impacts of geotechnical and flooding hazards.
9, 0511}finirnire potentially hazardous developments in hillsides, canyons,
areas susceptible to flooding, earthquakes, wildfire and other known
hazards, and areas with limited access far emergency equipment.
SCAG staff comment. See SCAG staff comments on policies 3.22 and
9.04. The Project is partially supportive of this ancillary RCPG goal.
Response: The Gcnaral Plan land use map, as well as the flooding and geotechnical
maps provided in the EIR; clearly delineate the constraint areas cited in
the comment. Most areas of potential flooding arc designated as
Watercourse, and according to Policy 8 of the Flooding and Hydrology
section of the Environmental Hazards Element, the construction of new
critical facilities shall be prohibited within the boundaries of the 100-
year f1oodplain. Several General Plan policies reiterate the City's
continued commitment to and implementation of the Hillside Zoning
Ordinance, which prohibits development on steep slopes and hillsides.
Also please see Response 27, above.
F.2•9. Comment: 9,08 Develop well -managed viable ecosystems or known habitats of
rare, threatened and endangered species, including wetlands.
SCAG staff comments. See SCAG staff comments on policy 3.20. The
Project is consistent with this core RCPG goal.
Response: Comment noted.
F.30. Comment:
As noted in the Summary of SCAG Staff Comments, the Final FIR
should address the relationships (consistency with care policies and
support of ancillary policies) to SCAG's Regional Comprehensive Plan
and Guide and discuss any inconsistencies between the proposed project
and applicable regional plans,
Response: As notcd in the responses provided above, the Draft Comprehensive
General Plan and EIR arc consistent with and responsive to the core and
ancillary policies of the SCAG Regional Comprehensive Plan and
29
F.31. Comment:
'TN/City of La Quinta
General Plan Final EIR
Response to Comments on DER
Guide. No meaningful inconsistencies exist between these two sets of
documents.
All feasible measures needed to mitigate any potentially negative
regional impacts associated with the proposed project should be
implemented and monitored, as required by CEQA.
Response: The General Plan and EIR include policies and programs requiring the
City to continue to coordinate efforts in the areas of air quality,
transportation, flood control and hydrology, open space, land use, water
resources, public education, hazardous materials and emergency
preparedness, among others. Further, the General Plan reiterates the
Gity's commitment to regional government, in the form of the Coachella
Valley Association of Governments throughout. The EIR and General
Plan clearly include all feasible measures to mitigate regional impacts.
30
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TN/City of La Quints
General Plan Final EIR
Response to Comments on DEIR
G. THE VISTA SANTA ROSA ASSOCIATION
G. t.. Comment: We are concerned not only about the impact of the General Plan on the
areas east of the current City limits of La Quinta, but also the cumulative
impact of the Plan on the region, including the current incorporated city.
Respon§e: Comment noted.
G.2. Comment: As a general observation, it is our opinion that there is insubstantial
evidence presented and inadequate analysis of Project Alternatives. With
respect to the "Preferred Plan:"
Section III A&B: Land Use and Agricultural Resources: It is our opinion
that the LOW Density and Very Low Density designations for the land
east of the city limits would encourage urban sprawl which is
specifically discouraged by State Statute.
Response: Although implementation of the proposed General Plan will facilitate the
development of low and very low -density residential development in the
easterly portion of the planning area, General Nan land use policies and
programs are responsive to the need to prevent urban sprawl. Policy 6 of
the General Plan Land Use Element requires the City to prop -ale in -lilt
development by giving top priority to capital improvement projects in
developed areas of the City. Similarly, Residential Policy 2 of the band
Use Element encourages development adjacent to existing
neighborhoods and infrastructure, and Residential Policy 3 indicates that
the City will discourage scattered development of residential
subdivisions by requiring necessary roadway and infrastructure
improvements and extensions to serve new development. The
Agricultural Overlay is another planning mechanism designed to
implement these strategies. As described in 'Fable 1II-9 of the Draft. EIR,
the Agricultural Overlay has been applied to 17,615d acres of lands in
the easterly portion of the planning area, and will allow for the
continuation of existing agricultural operations, as long as the property
owner so desires.
C.3. Comment: Furthermore, the absence of any specific wording of the "Agricultural
Overlay" makes it impossible to determine and analyze the impact on
existing land uses. It is our belief that the wording of Agricultural
Overlay may significantly limit the current agricultural uses, especially
animal husbandry.
Response: The Agricultural Overlay, as defined on pages 1-15, II1-2,1, and III-28 of
the DEIR, recognizes the importance of the agricultural community in
31
TWCity cf La Quinta
General Plan Final FTR
Response to Comments on DFTR
the south-central and southeasterly portions of the planning area, and
demonstrates the City's commitment to maintaining existing agricultural
operations. Any agricultural land use within this overlay arca shall be
allowed to continue until such time as the landowner chooses to develop.
The intent of the proposed General Plan is clearly to allow existing
agricultural interests to continue, regardless of the specific type of
activity. Potential impacts to existing land uses are analyzed in Section
ill-B of the EIR.
The General Plan is a broad -reaching policy document, and as such, it is
beyond the scope of the General Plan to address specific standards of the
Agricultural Overlay. As described in Policy 7 and Program 7.1 of the
General Plan (page 19), specific protocols and standards of the
Agricultural Overlay will be addressed in the City's zoning ordinance
after adoption of the General Plan. The hearings held in September,
November and December of 2C01 by the Planning Commission and City
Council included presentation of text for this zoning section, which is
closely modeled after the County zoning ordinance currently in effect.
The Commission and Council will continue their consideration of this
text throughout the adoption process of the Plan. In addition, the City's
Transfer of Development Rights provisions (Section 9.190) shall be
considered for inclusion in the Agricultural Overlay district, thereby
providing an incentive for the long-term preservation of agricultural
parcels in the planning area.
G.4. Comment: Furthermore, it appears that home occupancy business uses under the
city plan would be more restrictive than the current regulations under
Riverside County zoning regulations, and the resulting impact is not
addressed in the Draft E1R.
Response: The General Plan does not impose any limitations on home occupations
or home businesses. Issues concerning home occupations are currently,
and will continue to be addressed in the City's zoning ordinance (Title 9
of the Municipal Code). However, the proposed General Plan supports
the continued operation of home occupations, as described in Program
5.1 of the Traffic and Circulation, Element, which encourages the City to
facilitate use of the home occupation ordinance. Similarly, according to
Mitigation Measure F (Draft EIR, page III-59), the City shall encourage
the utilization of home -based employment as a means of minimizing the
number and length of vehicle trips traveled within and in the vicinity of
the City.
G.S. Comment: An additional issue of concern is that the "Kohl Ranch" development is
not included in the Agricultural Overlay which means that if the City
32
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEll
should annex that area also, it could not be continue to be cultivated
pending development.
Response: The Kohl Ranch Specific Plan was approved for mixed -use urban
development by Riverside County before the City of La Qui nta included
the site in the City's General Plan planning area. Exhibit [11-2
(Recommended Alternative land use plan) reflects projects as they have
been approved by Riverside County, and therefore, the Kohl Ranch
Specific Plan is not included in the Agricultural Overlay.
Any existing land use, regardless of whether it is permitted under the
land use designation in which it occurs. can continue as a legal non-
conforming use. If the Kahl Ranch site remains in agriculture at the time
another jurisdiction annexes it, existing on -site activities would he able
to continue as a non -conforming use indefinitely.
G.G. Comment: The entire premise of the General Plan and Draft h1R seems to be that
the areas east of the city limits will be developed at an average of 3 units
per acre at a fairly steady pace; however, as the economy of the region
would be drastically altered by the conversion of agricultural laud to
"country club" or standard subdivisions, the impact of the region is not
adequately addressed.
Response: 1'he General flan and Draft EIR make llcl assumptions about the future
rate of growth in the planning area. Itn fact, they clearly state that,
although the General Plan will provide opportunities for development on
these lands, it is unclear whether or to what extent the conversion of
agricultural lands to urban development will actually occur (EIR page
[I1-26, paragraph; page 1II-162, paragraph). For analysis purposes,
the EIR assumes that future residential development will occur at a rate
of 75% of the maximum density permitted. Where the maximum density
is 4 dwelling units per acre (LDR), the EIR assumes that 3 units will be
constructed per acre at General Plan buildout. Where the maximum
density is 2 units per acre (VLDR), the EIR assumes that 1.5 units per
acre will be developed al buildout. These assumptions have been made
to reflect actual levels of development in the planning arca and broader
Coachella Valley.
The potential economic impacts of the proposed Plan are addressed in
Section I1I-M of the Draft EIR, including analysis of potential costs and
revenues associated with buildout of land in the easterly portion of the
planning area. The City has identified that the impacts associated with
the long-term loss of agricultural lands will be significant (FJR page III-
28, 2"d paragraph, last sentence) and may not be rnitigatable. According
to Section 15093 of the California Environmental Quality Act, when
33
TNfCity of La Quints
General Plan Final EIR
Response to Comments on DEW
deciding whether or not to approve a proposed project (in this case, the
proposed General Plan) the City must balance the benefits of the project
against its unavoidable environmental risks. Where the decision of the
City Council allows the occurrences of significant effects which are
identified in the E1R, but are not mitigated, the City must prepare a
written Statement of Overriding Considerations, which explains the
specific reasons for its action based on the EIR and/or other information
in the record. The City Council, therefore, will be uhimatcly responsible
for weighing the benefits and risks of the proposed Plan and deciding
whether or not to adopt it.
G.7. Comment: Additionally, the report states that "Farmers and ranchers may be
exposed to increased noise associated with household mechanical
equipment and traffic generated by new residences. Residents of low -
density developments may be exposed to operational noise generated by
farm equipment, odors from farm animals and organic or chemical crop
applications, and airborne sand and/or dust generated by plowing and
harvesting activities," The mitigation measurers en these issues are
inadequate to address the problems.
On page 11I-140, the draft EIR states: "Land use incompatibilities may
arise where urban and agricultural lands are adjacent to one another.
Fugitive dust generated by disking, plowing, and other agricultural
operations could create a nuisance for neighboring development, and
fugitive dust generating during the grading and construction phases of
new development could adversely impact neighboring farmlands." A
100 toot buffer would be inadequate to prevent these incompatibilities as
anyone who has been in the Coachella Valley on a breezy, riot even
windy day, can attest.
Response: The General Plan includes a wide range of mitigation measures, which
will minimize potential land use incompatibilities to acceptable levels,
(see Sections III-B'Agricultural Resources, I11-l1Air Quality, and III-
JeNoise). The preservation of a minimum 100-foot open space buffer,
where residential development is proposed immediately adjacent to
agricultural lands, is only one component of a broader mitigation
package. The 100-font buffer represents a minimum. Ultimately, the
standard will be established in the Toning ordinance and may exceed 100
feet.
The Coachella Valley has a history of exceeding federal fugitive dust
(PMI1) emissions standards and, as mentioned in the comment above, its
natural wind events further exacerbate this condition. All urban and
agricultural development is and will be required to comply with local
and regional fugitive dust control plans set forth by the City, Coachella
34
INCity of La Quinta
General Plan Final EIR
Response to Comments on DEIR
Valley Association of Governments, South Coast Air Quality
Management District, and other public agencies to mitigate cumulative
air quality impacts. However, severe wind events sometimes create
temporarily unacceptable conditions both in urban and in agricultural
areas. The mitigation included in the EIR will provide sufficient
protection against typical conditions, and will therefore lower impacts
from and to urban and agricultural land uses.
GG.8. Comment: At the very least, the City should adopt a "Right to Farm" ordinance.
Response: Comment noted. At hearings held by the Planning Commission and City
Council in September, November and December, zoning ordinance and
'`right to farm" ordinance text was presented and discussed, respectively.
In addition, the City's Transfer of Development Rights provisions
(Section 9.190) shall be considered for inclusion in the Agricultural
Overlay district, thereby providing an incentive for the long-term
preservation of agricultural parcels in the planning area. The City has
clearly stated that these municipal code anicndnucnts will be needed in
the Future to accommodate agricultural land uses. All ordinances
pertaining to agricultural activities will be adopted after adoption of the
General Plan, Please also see responses to Comment #3, above_
G.9. Comment: 1t is our opinion that the Plan is inadequate its it indicates that "most" of
the roadway segments will operate at Levels of Service "D" on building
of the proposed General Plan. Additionally, the need to move tractors
and other agricultural equipment is not adequately analyzed, nor are the
provisions for regional horse trails, and their impact on circulation taken
into consideration. Certainly one of the most glaring problems with
traffic plans in the City is the recent installation of the traffic circle at
Ave. 52 and Jefferson Streets which has potential catastrophic
consequences for anyone attempting to transport horses, other livestock,
or heavy equipment via trailer through the intersection.
Response: The La Quinta General Plan Traffic Model analyzed buildout traffic
levels for approximately 278 roadway segments in the planning area, Of
these, 263 (94.6%) are projected to operate at acceptable levels -of -
service "D" or heitur, and 15 (5.4%) are projected to exceed typical
Average Daily Trips (ADT) capacities. It is worth noting that 8 of these
15 roadway segments are projected to exceed capacity by only 3% or
less of roadway capacity. All 20 intersections modeled are anticipated to
operate at acceptable levels -of -service "D" or better. Although a
roadway segment may be identified as exceeding the allowable capacity,
intersection improvements may allow the endpoints of a segment to
operate acceptably. Recommended intersection geometries provided in
Exhibit 11I-14 and cross -sections described in Exhibit 111-12, and
35
G.10. Comment:
TN/City oftaQuinLa
General Plan Final EIR
Response to Comments on UE1R
numerous programs and policies described in the General Plan Traffic
and Circulation Element, arc expected to reduce potential traffic impacts
along these roadway segments to acceptable levels.
The General Plan Traffic and Circulations Element is responsive to the
potential need for equestrian trails, and requires the City to develop and
encourage the use of continuous and convenient multi -purpose trails,
with the potential for increased bicycle, equestrian, golf cart and other
non -vehicular use (Policy 7). F,xhibit 3.10 illustrates proposed trail
routes in the planning area. Policies and programs set forth in the Open
Space and Parks/Recreation Elements also address the need for a
comprehensive multi -purpose trails nctwerk, and specifically advocate
the consideration of a trail that links the eastern half of the planning area
with existing and planned equestrian trails, as well as coordination with
adjoining communities and other appropriate agencies, including the
Coachella Valley Trails Council, in planning optimal trail routes and
connections.
The City is responsible for monitoring local traffic conditions and safety
concerns, and making periodic adjustments to its roadway network
through capital improvements and maintenance management prugratns.
This includes routine monitoring of local intersections, including the
roundabout intersection at Jefferson Street and 52'd Avenue. The
roundabout offers several benefits to the local circulation network,
including slower traffic speeds and rcduetions in unnecessary stop
delays. The Vehicle Code allows all types of vehicles on public
roadways. This is currently the case under County jurisdiction, and uri11
not change under City jurisdiction, The General Plan and EIR include a
wide range of policies and programs directed at preserving the safety of
the local transportation network and minimizing potential traffic
conflicts.
The General Plan's anticipated buildout at an average of 3 houses to the
acre is excessive and irresponsible until, and unless, the dangers of
collapsible soils and ground subsidence are demonstratively solved,
Although CVWT] has operated a pilot recharge facility, it is still in the
experimental stage and even if successful, a full-scale facility is years in
the future. Indeed, CVWD has just received a grant from the State for
further study.
Response: i'he General Plan does not anticipate that buildout will occur with an
average of 3 houses per acre. It is understood that residential
development in the City and broader Coachella Valley generally has not
occurred at the maximum densities permitted. To provide an adequate
representation of actual levels of development in the planning area, the
3b
TN/City of La Quints
General Plan Final LIR
Response to Comments on DEIR
Cr.11. Comment:
EIR assumes that buildout will result in development at 75% of the
maximum density permitted. The General Plan Land Use Plan includes 5
residential land use designations, each with its own range of permitted
densities, Where the maximum permitted density is 4 units per acre
(GDR), the General Plan assumes buildout will result in the development
of 3 units per acre. However, where the maximum permitted density is
16 units per acre (F [DR), the General Plan assumes buildout will result
in the development of 12 units per acre, This pattern of assumptions is
applied to ally residential land use. designations.
The potential hazards associated with collapsible soils and ground
subsidence have been addressed in detail in on pages III-64, I1I-65, and
11I-89, and Appendix ( of the Draft EIR. Appropriate and applicable
mitigation measures to minimize these risks, including hut not limited to
Mitigation Measure Items F, P, and Q. are identified on 111-75, The EIR
explains that ground subsidence is a valley -wide problem, and
mitigation of this hazard will require a regional approach to groundwater
conservation. General Plan policies and programs indicate the City's
continued support of the groundwater recharge program, the use of
recycled and tertiary treated water, and other water conservation
measures,
The issue of wind erosion and damage from blowing sand arc grossly
under -rated. Reduction of the flood potential of the Whitewatcr River
will not solve the existing prohlcros.
Response: The regional wind erosion and blowsand hazard is described on pages
111-65, 111-127, 111-128, 111-129, I11-130, and I11-132, and Exhibit III-18
identifies various wind hazard zones within the planning area. This
hazard is described in greater detail in Appendix G, "Seismic, Geologic,
and Flooding Hazards Sections of the Technical Background Report for
the Safety Element for the City of La Quinta," Neither the. General Plan
nor the Draft EIR imply that reduction of the flood potential of the
Whitewater River will solve the existing problem; however, it is
expected to contribute to a reduction in local blowsand hazards.
Mitigation ltetn U on page 111-75 identifies a number of other measures
for reducing fugitive dust, requires approval of a soil erosion prevention
plan prior to the issuance of grading permits, and refers the reader to
Section III-1 (Air Quality), which identifies additional mitigation
measures.
G.12. Comment:
While improved building codes have reduced the potential for collapse
of buildings and deaths as a result of seismic activity, significant damage
to structures, city infrastructure, and community social life are
inescapable in the event of a major tremor. The Draft EIR anticipates '`a
37
I(/Gilt' of La Quinta
General Nan Final EIR
Response to Comments on DETR
22% probability of the San Andreas Fault generating a magnitude 7.0
earthquake before the year 2024" and "the slip rate of the San Jacinto
fault is estimated at between 7 and 17 mmlycar, and is capable of
generating magnitude 6.5 to 7.5 earthquakes." Added to the initial
impact of the tremor are liquefaction, settlement, slope instability, and
inundation. All of these issues are inadequately analyzed and mitigated,
not to mention their cumulative impacts. To encourage urbanization of
an area subject to these factors is insupportable.
Response: Comment noted. Section III-D (Soils and Geology) of the Draft EIR
includes detailed descriptions of the above -described gcotechnical
hazards, mapping of various geotechnical hazards areas in the planning
area, and numerous mitigation measures designed to reduce potential
impacts to acceptable levels. Further detail and explanation of potential
hazards and appropriate mitigation measures is provided in Appendix G,
the background geotechnical report for the General Plan Update, All
development shall be required to comply with the mitigation measures
established in the EIR and all policies and programs set forth in the
General Plan, Cumulative geologic/seismic impacts are addressed on
page VIII-4 of the EIR,
G1.3. Comment: As shown above, the Draft E1R fails to view the hydrology issues in the
context of cumulative impacts. At the present time, residential
development will place an additional burden on the over drafted water
table, as residential uses (including potable water) are served by water
purnped from the aquifer.
Response: Cumulative hydrologic and water resources impacts are addressed on
pages VIII-4 and V11I-5 of the EIR. The General Plan acknowledges that
future residential development will result in increased demand for
groundwater resources and identifies a wide range of appropriate
mitigation measures on pages 111-94 and I11-95.
G.14. Comment: The engineering firm for the Coral Mountain Project analyzed the water
supply demands of that project, which is a country club/residential
development of the type that can be anticipated to be built throughout
the annexation and planning area. They calculated that development
alone would contribute an additional average demand of 1.8 acre-feet
per year on the groundwater. That project is only the "tip of the iceberg,"
Response: Comment noted. The commentor incorrectly interpreted the content of
the letter. The letter specifically states that the Coral Mountain project
will utilize 391 acre feet of groundwater, and 1,341 acre feet of canal
water for irrigation annually. (Source: Letter dated June 7, 2001, Pacific
38
TN/City of La Quinla
General Plan Final LIR
Response to comments on DER
G.15. Comment:
Advanced Civil Engineering. Inc.) On a per unit basis, this represents
0.32 acre feet per year.
The residents of the Vista Santa Rosa have reported that the water levels
in their wells have been dropping for years, with a significant
acceleration of the rate since PGA West was approved. The draft
Coachella Valley Water Management Plan states that groundwater
demand in the lower valley currently exceeds recharge by 41,700 acre
feet per year and that groundwater levels have decreased 60 feet or more
in seine parts of the lower val ley; our residents can verify those findings
froth empirical experience.
The draft Water Management Plan states that "it is clear that the
continued decline of groundwater levels is unacceptable" and that "the
continued overdraft will have serious consequences for the Coachella
Valley". Short term impacts include increased groundwater pumping
costs, and the cost of deepening wells and installing larger pumps.
"Continued decline of groundwater levels could result in substantial and
possibly irreversible degradation of water quality in the groundwater
basins."
Areas of the lower Coachella Valley are already experiencing
subsidence by excessive groundwater overdraft, As the water in the
aquifer is depleted, the space between soil particles is loss, which leads
to compaction, which CVWD representatives admit could permanently
reduce the capacity of the aquifer. If capacity is diminished, ever, if a
way to recharge the aquifer is found, its ability to receive the water will
be significantly reduced or lost. As stated above, CV WL) has not proven
the physical ability to adctluate]y recharge the aquifer. Indeed, the
CVWD Draft Water Management Plan states "the maximum amount of
potential recharge in the lower valley is not known at this time,"
Additionally, this Water Management Plan is itself only a draft, the EIR
not to be issued until late in 2001, then it must undergo comment, Public
Hearing, and must be adopted by more than one agency; it also seems
fated for challenge in court. There is no guarantee•that the plan will he
adopted as currently written, when it will be implemented, that it will be
successful, or if it does stop the overdraft that it will do so in time to
prevent significant subsidence.
The draft Water Management Plan notes that the Coachella Valley does
not currently have water rights to imported water sufficient to satisfy its
current and future demands. The issue of imported water is especially
complex as seven states share the Colorado which, like all rivers, is
subject to reduced capacity due to climatic conditions. While CVWD
39
TN/City of La Quinta
General Plan P i nal E1R
Response to Comments on DLIR
has made an outstanding attempt to acquire additional sources, those
efforts have not yet reached fruition. Major urban areas like Los Angeles
and Phoenix may not have the "federal water priority" of the Coachella
Valley water project, but it is a policies reality that such concentrations
of population and industry vital to the economic health and defense
capability of the nation will have their basic needs placed in higher
priority for delivery, although probably not price.
Response: Comments noted. The draft EIR and General Plan address the current
state of overdraft, water quality degradation, CVWD's groundwater
replenishment program, the production and use of tertiary treated water
in the planning area, and other water conservation measures supported
by the City. CVWD's Water Management Plan contains a greal deal of
information regarding current conditions, historic usage, and potential
solutions to the overdraft currently being experienced. As such, it
represents a valuable tool in the analysis of water usage in the City and
its planning area.
G.16. Comment:
The Mate is under directive from the Secretary of the Interior to reduce
its use of Colorado River Water by nearly 1,000,000 acre feet annually.
If this area does not significantly increase its conservation of water, even
without growth, we may have our current allotment reduced. 'While an
argument is made that an acre of agriculture uses the same amount of
water as an acre of golf course, or an acre of residential use, that does
not mean: that each of these uses depends on water from the same
sources; that is could or would be recycled the same way that the
drainage impact on the Salton Sea, a federal concern, would be the
same; that the development of currently non -farmed land would not
increase the demand on the water supply; that the impact on the nation's
food supply would be the same, etc. The effects of urbanization of the
planned area are far, far more complex than what is addressed in the
draft EIR and any plan based upon this report is fatally Clawed.
Response: Comment noted. The Draft FIR addresses groundwater supply,
overdraft, replenishment, demand, quality, and conservation from a local
and regional perspective in Section III-F. Analysis and mitigation
measures contained therein are based on the most current information
provided by the Coachella Valley Water District. They are currently the
most accurate and up to date source of information relating to water
usage in the Valley. As additional information is developed in the future,
individual projects will be reviewed using that information.
G.17. Comment:
While extensive coverage has been given to the biological resources and
concerns. This is a regional issue, and development of a plan for
expansion of the City is premature until CVAG completes its study.
4D
1NfCity of La Quinta
General Plan Final EIR
Response to Comments on DEIR
Many forms of animal life can and do co -exist with existing agricultural
use of the land which cannot exist with urbanization. Personal
observation has acquainted me with the objections of residents of one
local country club to the use of their swimming pools, etc. by birds
protected by the federal migratory wildlife laws These same birds cause
no problems when they use agricultural reservoirs.
Response: Comment noted. The City is a signatory to a Memorandum of
Understanding for the preparation of the "Multiple Species Habitat
Conservation Plan" (MSHCP) and will continue to participate in its
development. Until such time as the MSIICI' is completed, however, the
City is not capable of adopting or implementing it. The use of swimming
pools or reservoirs by migratory birds may be a temporary nuisance to
the pool or reservoir owner, but does not represent an environmental
impact.
G.18. Comment:
As stated in the EIR, La Quinta contains "one of the most dense
concentrations of archaeological sites in California." Additionally, since
1981, "over 120 historic buildings and sites have been recorded in the
General Plan planning area." Farming may "turn" the land, but does not
pulverize artifacts as development would, as a result the area is
culturally extremely sensitive. Additional studies would be necessary to
determine to what extent urbanisation would destroy sites that future
generations could more adequately preserve and/or document.
Additionally, the Torres -Martinez and Augustine tribes should be
consulted regarding planning urbanization. Until and unless potential
impact studies and adequate mitigation measures are developed, the area
of potential development should not be expanded.
Response: Both a cultural resources sensitivity analysis and a paleontological
resources mitigation plan were prepared for the General Plan planning
area and are contained in Appendices B and D, respectively, of the Draft
EIR. Potential impacts associated with General Plan huildout are
evaluated in Section III-H of the EIR. Given that site -specific cultural
resources may not be discovered until future development occurs, the
EIR requires that all development projects, which require discretionary
city action, be reviewed by a qualified archaeologist or other
professional. The EIR also establishes a number of other mitigation
measures on pages III-123 and III-124, which will minimize potential
impacts associated with General Plan buildout. The General Plan .I;II( is
responsive to the need for Native American participation in preserving
cultural resources, and Mitigation Item F clearly states that a Native
American representative shall he included in monitoring ground
disturbances in areas of high sensitivity.
Al
G.19. Comment:
TN/City ufLa Quinta
General Plan Final Elk
Response to Comments on DEIR
As slated in the draft EIR, "winds suspend and transport large quantities
of sand and dust, which can reduce visibility, damage property and
constitute a significant health threat." Additionally, "the Coachella
Valley is also susceptible to air inversions, in which a layer of stagnant
air is trapped near the ground where it is further loaded with pollutants.
When combined with chemical aerosols and other pollutants emitted by
automobiles, furnaces and other sources, this process can result in
substantial haziness and a deterioration in ambient air quality." The
mitigation measures are inadequate in addressing these conditions.
Response: The mitigation measures set forth in Section III -I (Air Quality) of the
Draft EIR are responsive to the most recent air quality studies and
directives issued by the South Coast Air Quality Management District,
Coachella Valley Association of Governments, California Air Resources
Board, and the U.S. Environmental Protection Agency. They address air
quality pollution control issues from both a local and regional
perspective and are believed to be adequate in mitigating potential
project -related impacts. Individual project proposals shall be reviewed
on a case -by -case basis to assure the implementation of site -specific dust
control measures.
G.20. Comment:
Merely looking at the chart on page 111-150, leads one to know that the
impacts of the General Plan are staggering. Anyone who has visited a
large urban area knows that is would be impossible to maintain
acceptable noise levels when increasing the size of a city from
approximately 24,000 to 207,000.
Response: Comment noted. All development in the planning area shall be required
to comply with the standards and provisions of the City's noise
ordinance.
G.21. Comment.
The impact of the planning is difficult to assess when viewed in light of
the recent decisions of the City Council to allow a significant variance
for the new hotel from its "Cove" height restrictions, and to allow a
berm of up to 19' tall on Avenue 54, a street that was to be designated an
agrarian corridor. The mitigation measures indicate that the "City shall
establish and implement urban design standards which protect scenic
viewsheds and enhance community cohesion." Absent precise wording
on these standards and guarantees that the standards will be followed, it
is impossible to analyze the impact of the new General flan.
Response: The existing General Plan does not provide the standards which would
aid in implementing viewshed protection. The new proposed General
Plan establishes programs which will require subsequent adoption of
zoning standards to allow such protection. It is beyond the scope of the
42
TN/City of La Quints
General Plan Final L1R
Response to Comments on DEMR
Gcncral Plan to establish specific urban design standards for various
neighborhoods and districts within the planning area. These efforts have
been and shall continue to be addressed in the City's zoning ordinance.
The adoption of these standards will occur through the public hearing
process, which will allow the public to contribute to the new standards.
G.22. Comment: Section L. Public Services and Facilities:
This entire section is based upon conjecture about future development of
a huge land area.
Response: The Public Services and Facilities section includes detailed discussion of
Existing Conditions, Project impacts, and Mitigation Measures_ Like
other sections of the, FIR, project impacts are based on rational
assumptions about future levels of development in the planning area at
General Plan buildout. It is impossible to anticipate whether and to what
extent future development will actually occur, and it is beyond the scope
of the General Plan to analyze project -specific impacts to public
facilities and services,
G.23. Comment:
Significant developer fees or new community facilities districts would
be necessary to adequately provide for the increase in student
population,
Response: Comment noted. The Mitigation Measures section on pages III-169 and
111-170 of the EIR states that developers will continue to be assessed
statutory school mitigation fees, and it cites additional funding
mechanisms available to school districts.
G.24. Comment:
The city library is currently significantly under -served by County
standards, which even with the new building plans, would be exacerbate
by the buildout and the plan is vague on its correcting these problems.
Response: Comment rioted, A number of policies and mitigation measures
regarding the provision of library facilities are clearly stated on page III-
171 of the EIR, and page 71 of the General Plan. These statements are
responsive to the need for 'expanded library space and resources.
G.25. Comment:
Policing, fire protection and healthcare projections are woefully
inadequate and likely to remain so with the fiscal shortfalls projected in
the draft EIR,
Response: As described by the policies and programs in Chapter 7 of the General
Plan, and the Mitigation Measures in Section II3-L of the EIR, the City
shall be responsible for routinely assessing staffing and facilities levels
41
TN/City of La Quints
General Plan Final IsIR
Response to Comments on DEIR
as the planning area builds out to assure that adequatc police and fire
services are provided. Although the City can consult and confer with
local and regional healthcare facilities, such facilities are privately
owned and operated and will continue to plan for growth as demand
requires. General Plan buildout is anticipated to result in a positive
annual cash flow of approximately $20 million, not a fiscal shortfall
(please see Table 111-46 and Section 11I-M of the MR).
G.26. Comment: Once again, the plan covers too large an area to adequately project and
plan for waste water disposal.
Response: Pages I1I-181 and I11-182 address existing wastewater collection and
treatment services and projected impacts associated with General Plan
buildout. It is beyond the scope of the General Plan to analyze project -
specific impacts to pubic facilities and services, and at this time, it is not
known whether and where future development will occur. Therefore, the
General Plan requires the City to consult and coordinate with the
Coachella Valley Water District to assure that adequate waste water
facilities and services are provided.
C.27. Comment:
Basically, the planning area is simply too large fur adequate planning of
infrastructure for a city of the size of La Quinta. Far too many
projections are based on "developer fees" and not on sustainable revenue
sources. Maintenance of services must be an extreme consideration
when the buildout of Annexation No. 12 would result in an annual
shortfall of approximately $5,387,982, and buildout of the SOI
amendment would result in a negative annual shortfall of $1,998,748.
Response: The General Plan is intended to function as a broad -reaching, long-range
planning document that addresses future development in a relatively
large arca. Given that it is impossible to determine whether and where
future development will occur, the General Plan provides a wide range
of policy directives that require the City and other public service
providers to analyze and provide for public services as demand requires.
No public service provider serving the planning area has indicated that it
will have difficulty serving future development at General Plan buildout.
A wide range of funding mechanisms will be employed to expand
services and infrastructure to new development, including developer
fees, special district assessments, and public investment. Developers are
expected and required to pay their fair share of development
improvements.
Although buildout of Annexation Area No.12 and the SOI amendment
area themselves is expected to result in. annual fiscal shortfalls; when
rolled into the broader General Plan project, buildout of the entire
44
G.28. Comment:
TN/City of La Quinta
General Plan Final FAR
Response to Comments on DEIR
planning area would result in positive annual cash flow of approximately
$20 million (please scc Table III-46).
1'he draft EIR fails to adequately address the current problems inherent
in the infrastructure of the City much less the problems that will develop
if additional area is annexed with the resulting shortfalls; at the very
least, a new EIR should be required for arty annexations or changes of
Sphere of Influence as the current draft does not only fail to fully
analyze alternative plans, it also fails to analyze the impact of changed
land use on the regional economy. The fatal flaw of the General Plan
and draft FIR is the proposed development and enlargement or a city
that already has significant problems, including the fact that
approximately 49° o of the land within the city limits has not been
developed despite a State policy to discourage urban sprawl.
Response: Comment noted. Please see responses to comments 22 through 27,
above, regarding the provision of future infrastructure and fiscal
projections, and response to comment 2 regarding urban sprawl. The
standards by which the City reviews projects and determines whether an
EIR will be required are strictly governed by CEQA,
C.29. Comment: For all of these reasons, and those submitted by Mr. Wiedlin and Mr.
Mitchell, it is our opinion that the Draft FIR is significantly inadequate
to serve as an environmental impact report for any additional
annexations or expansion of the City's sphere of influence to the cast of
the current city limits_
Response: Opinion noted.
Thl. City of La Quinta
Genera/ Plan Final MR
Response to Comments on DEMR
U. CITY OF CHACHEI,LA
11.1. Comment: The City of Coachella is pleased to have received a copy of the above
referenced document for review and comment. Staff has conducted an
initial review of the DER and forwards comments for your
consideration. Staff had requested an extension to October 3, 2001, to
allow time for the City Council of the City of Coachella to review staff
comments prior to submission to you. Since that request was not
granted, the staff comments are being forwarded to you by your
September 10th deadline. Additional comments may be submitted at your
hearing, Review by the City Council of thc City of Coachella will not
occur until their meeting of September 26, 2001. at which time
comments will be forwarded to you.
Response; Comment noted.
H.2. Comment: The proposed general Plan Planning Area, including proposed
Annexation No. 12 is an ambitious one, that could potentially result in
significant impacts to the City of Coachella in several areas of concern.
Response: Comment noted,
H.3. Comment: The preservation of the agrarian and equestrian lifestyle and resources
within the south-central and southeastern portion of the Planning Area is
of major concern. Resulting loss of agricultural lands and resources
through conversion of existing agricultural lands to residential land uses
could pose a significant threat to the traditionally strong economy of the
Coachella Valley, Preservation of these areas is vital to the economic
well-being of the agricultural community of thc Coachella Valley. From
a preservation standpoint, the proposed Agricultural Overlay (as
depicted in the Recommended Alternative and Alternative I1) is
extremely important to include in the general plan. It is understood that
the proposed Agricultural Overlay will allow current agricultural land
uses to continue until the property owner chooses to develop the land,
However, it is not clear whether vacant agricultural lands will be
allowed to begin agricultural activities at the property owners'
discretion.
Response: Comment noted, Currently, the City has no jurisdiction over land in the
south-central and southeasterly portions of the planning area, and any
land use permitted by Riverside County will continue to be allowed.
Should the City annex these lands in the future, new agricultural
activities would be allowed subject to the provisions of the zoning
46
TN/City of La Quints
General Plan Final EIR
Response to Comments on DEIR
ordinance. Lands lying fallow at the time of annexation would be
considered to he agricultural land uses.
11.4. Comnnent. The proposed 100-foot minimum buffer between agricultural land uses
and proposed residential areas and other lands uses seems too little to
realistically mitigate the typical agricultural activities (pesticides,
fertilizers, dust, noise, odors, etc,) upon residential areas. Some crops
require activities and techniques done at night-time and early morning
hours, using both manual labor and machinery that can be quite noisy at
100-feet away. Rather, it is suggested that a minimum 300 to 500 foot
buffer might be considered a more adequate mitigation measure_
Response: The proposed 100-foot buffer would be required in addition to any
landscape easements, roadways, greenways. and building setbacks
required by the City during the project review process, "Therefore, the
actual buffer zone between agricultural activities and urban development
is likely to be much larger, and the 100-foot buffer represents a
minimum. Ultimately, the standard will be established in the zoning
ordinance and may exceed the above -referenced mitigation measure,
The City has also committed to the addition of right to farrn ordinance
text in hearings held before the Planning Commission and City Council
in September, November and December of 2001. In addition, the City's
Transfer of Development Rights provisions (Section 9.190) shall be
considered for inclusion in the Agricultural Overlay district, thereby
providing an incentive For the long-term preservation of agricultural
parcels in the planning area.
ki. . Comment: Preservation of the equestrian lifestyle in the Nanning Area should be a
priority to retain existing equestrian properties and to provide for the
development of new properties as desired by landowners.
Response: The Agricultural Overlay applies to both agricultural and equestrian land
uses. The General Plan and Draft E1R clearly indicate the City's
commitment to maintaining these existing land uses until such time as
the landowner chooses to develop.
H.6. Comment: With a 113% increase in dwelling units (at 75% maximum densities at
build -out) there will be significant impacts to the local roadway system
and to airport traffic, with increased daily trips and airport service
expansion. The projected increase in residential, commercial and
industrial vehicular traffic, will potentially overburden roadways,
bridges, and intersections adjacent to and within the City of Coachella.
Specific mitigations such as improvements to the streets, interchanges,
bridges, and grade -separations arc not identified in the Draft EIR making
it impossible; to identify the level of significance of the impacts after
47
'TN/City of La Quinta
General Plan Final EIR
Response to Comments on T)F.UR
mitigation. `1 his needs to be corrected prior to the adoption of the EIR.
Furthermore, Level of Service D is not acceptable as the standard LOS
for most areas within the City of Coachella as is currently proposed in
the DEIR.
Response: The ultimate improvements required to all General Plan roadways are
illustrated throughout the Circulation Element, and section III-C of the
FIR, including roadway cross -sections at buildout, The General Plan
requires that development which occurs adjacent to those roadways
construct improvements to meet the buildout requirements at the time
development occurs. Furthermore, the City has implemented a
Developer Impact Fee program to address city-wide transportation
needs. All future projects will be required to participate on a fair share
basis, based on impacts of the project. A Program EIR for a General
Plan is not the appropriate location for a discussion of individual
roadway improvements. The individual review of projects as they occur
will require such specific review.
1'he Level of Service for intersections in the General Plan is proposed to
be LOS D. Until such time as the City annexes any property, it cannot
impose its standards on that property. The City's General Plan Level of
Service has not impact on streets currently within the City of Coachella,
where that City's standards are currently entbreible_
11.7. Comment: Considering the high number of dwelling units proposed by the
Recommended Alternative, the consumption of -water and water
availability is of major concern on a valley -wide scale, given the current
overdraft condition. This begs the question of whether there is enough
water for the projected growth in the Planning Area. The 55% reduction
in water consumption at build -out as described for Alternatives I and II
are preferable to that described for the Recommended Alternative.
Response: Comment noted. The General Plan and draft EIR include numerous
goals, policies, programs, and mitigation measures which reflect the
City's commitment to conserving regional groundwater resources.
Among these are the City's continued participation and cooperation in
expanding CVWD's local groundwater recharge program, the use of
recycled and tertiary treated water, the use of native drought -tolerant
landscape materials, and the implementation of water conservation
measures. As described in Mitigation Item C on page III-85 of the
DEIR, all future development proposals shall be analyzed by the City,
Coachella Valley Water District, andior Myoma Dunes Mutual Water
Company to determine potential project -specific impacts on
groundwater resources.
4g
TN/City of La Quints
General Plan Final EIR
Response to Comments on DEIR
H.S. Comment: There is also concern for water quality, as each alternative discussed in
the document results in additional urban development and potentially
new pollutants to the groundwater supply, It is agreed that conversion
from private septic systems to a sewer system could reduce the threat of
groundwater contamination, Additional discussion of potential impacts
to water supply and systems adjacent to the Planning Area should be
included, especially as it impacts the City of Coachella.
Response: The draft EIR addresses applicable water quality regulation and potential
impacts to water quality on pages 111-90, I[!-91, and V-21. The draft EIR
and General Plan contain a variety of policies, programs, and mitigation
measures that apply to future development in the planning area. The City
will continue to review all development proposals for their potential to
contaminate surface and ground waters, and will continue to implement
federal, state, and regional water quality standards pertaining to the
discharge and treatment of pollutants in surface water, both on private
lands and public facilities, Additionally, the City will continue to require
the development of on -site stormwater retention andior detention basins
to enhance the filtration of runoff and mininli?e adverse impacts to local
and regional water quality. The City shall require, wherever feasible, the
extension of the community sewer system to serve new development and
minimize the potential risks of groundwater contamination from septic
tanks and sccpagc pits_ given these measures, no significant adverse
water quality impacts are expected to affect the City of Coachella or any
other community.
EI.9. Comment: It is clear that there could be significant adverse impacts to the local air
quality from the build -out of the proposed Planning Arca under all
project alternatives. Traffic emissions, site disturbance, grading and
construction activity, and increase in utility consumption will lead to an
increase in air pollution for the valley.
Response:
11.10. Comment:
Response:
Comment noted, The Draft FIR addresses potential air quality impacts
generated by each of the above -cited sources in Section III -I (Air
Quality) and Section V (Project Alternatives).
Projected development within the Planning Arca under any of the
project alternatives will result in a significant increase in population
which will be subject to potential seismic geological hazards.
Comment noted, The Draft ElR addresses potential geotechnical hazards
in Section Ill-D (Soils and Geology) and Section V (Project
Alternatives).
49
TN/City of La Quinta
General Plan Final EIR
Response to Comments an ❑EIR
H.11. Comment: Projected development of the Planning Arca under any of the project
alternatives will result in the need for additional flood protection
facilities and improvements.
Response: Comment noted, Potential impacts to flood control facilities are
addressed in Section TTI-E (Hydrology) and Section V (Project
Alternatives) of the Draft EIR.
I4.12. Comment: Projected development of any of the project alternatives could result in
potential ad -verse impacts to wildlife and native plants. Exotic plant
species will be introduced into the areas as development occurs that
could dominate plant communities. Domestic pets could intrude into
remaining natural habitat areas and adversely impact wildlife.
Response: Comment noted. Potential impacts to biological resources, including
plant and animal species, are addressed in Section III-0 (Biological
Resources), Section V (Project Alternatives), and Appendix C of the
Draft H R. The [hmcral plan also includes a program which will result in
the development of a prohibited plant list. Individual project mitigation
measures will include fencing to limit domestic animals if such a
mitigation measure is needed at that particular project site.
H.13. Comment:
There will he an increase in various noise generators in the proposed
Planning Area that could adversely impact the Planning Area as well as
adjacent communities. Vehicular traffic will be the dominate (sic) source
of the noise impacts, Thcrc could be incompatibilities and conflicts
between agricultural land uses and proposed residential land uses if a
larger buffer area is not required.
Response: Comment noted. Potential noise impacts associated with General Plan
buildout are addressed in Section 111-J (Noise). Section V (Project
Alternatives), and Appendix E of the Draft EIR. Sec response to
Comment 4, above, regarding required buffer areas between agricultural
and residential land uses, The right to farm ordinance text being
considered by the City includes notification of property buyers to alert
thcrn to the occurrence of agricultural activities. Furthermore, future
projects are required to conduct noise studies prior to construction to
ensure that exterior noise levels will not exceed 65 dBA CNEL. Should
a project be proposed adjacent to existing agricultural development, the
impacts associated with the agricultural activities would be analysed in
the site specific noise study, and appropriate mitigation measures would
be imposed on the residential development.
H.14. Comment: The proposed Recommended Alternative wilt result in a 113% increase
in dwelling units at build -out (at 75% maximum densities) which is a
50
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
significant increase in dwelling units and population for this area,
Alternative ii will result in 41,605 fewer dwelling units than the
Recommended Alternative and correspondingly result in fewer adverse
impacts between land uses within the proposed Planking Area and
tidjacent communities.
Response: Comment noted_
11.15. Comment:
The City of La Quinta has a wealth of prehistoric and historic resources
that should be given the highest level of consideration before they are
adversely impacts by the proposed develcprncnt strategy. Avoidance
should be the preferred alternative for preserving these resources
wherever possible.
Response: Comment noted. Section III-H, Section V, and Appendices B and 1 of
the Draft EIR acknowledge the wealth of cultural resources which occur
in the planning area and address potential impacts associated with
[general Plan buildout. The paleontological and cultural resources
programs and policies provided in Chapters 6 and 9 of the General Plan,
as well as the mitigation measures identified on pages I11-1 2.3 and II1-
124 encourage the preservation of sensitive cultural resources.
Furthermore, the City will continue to require site specific cultural
resource studies as projects art proposed. These studies will include
mitigation measures specific to the project and site, in order to protect
the cultural resources found on the site,
H.16. Comment:
There is a potential for significant adverse impacts to vistas and views of
the Santa Rosa Mountains, from the City of Coachella, if stringent
controls are not placed upon projected development within the proposed
Planning Area. The undcrgrounding of utilities should be a priority
within the proposed Planning Areas. Wireless communication towers
and monopoles, utility towers and poles, signs, and multi -story
buildings, should be subject to strict development standards that will
ensure minimal impacts to viewsheds, The City of Coachella requests
building heights to be limited to protect view corridors of the Local
mountains from properties within the La Qui nta.
Response: Comment noted. Potential visual impacts associated with General Plan
buildout are addressed in Section III-K of the Draft EIR. Implementation
of the mitigation measures provided on pages 111-162 through 111-164,
which address signage, outdoor lighting, utility undergrounding and
equipment design, and other aspects of community design, will reduce
these impacts to acceptable levels Policies 13, 14, and l5 of the Traffic
and Circulation Element of the General Plan establish primary,
secondary, and agrarian Image Corridors throughout the planking area to
51
TN/City of La Quints
General Pian Final EUR
Response to Comments en DEIR
further protect the aesthetic value of regional viewsheds (see also
Exhibit 3.6 of the General Plan). Policies 3 and 4 on page 73 of the
General Plan address undergrounding of utility and electrical wires, and
the design and integration of utility equipment into the surrounding
environment. Individual development plans shall continue to be
reviewed for their compliance with the standards sct forth by the City's
zoning ordinance. The existing General Plan does not provide the
standards which would aid in implementing viewshed protection. The
new proposed Ci-eneral Plan establishes programs which will require
subsequent adoption of zoning standards to allow such protection.
1I.17. Comment: The City of La Quinta is currently underserved in fire, police, and
library services. With such a large proposed Planning Area, it will be
critical that adequate services are provided as development occur so that
there will not he adverse impacts upon adjacent communities and their
service resources,
Response: Comment noted. The policies and programs set forth in Chapter 7 of the
General Plan, and the mitigation measures described in Section 111-L of
the Draft FIR, require the City to routinely evaluate the provision of
public services and infrastructure, and to closely coordinate with public
service providers to assure that new and existing development is
adequately served.
11.18. Comment: Adverse impacts to the agricultural and equestrian lifestyles is
potentially significant unless the proposed Agricultural Overlay is
adopted as indicated in the Recommended Alternative and Alternative
11. 'There has been a lengthy tradition of these lifestyles in the south-
central and southeastern areas of the Planning Arca.
Response: Comment noted. The Agricultural Overlay is a proposed land use
overlay in the General Plan Land Use Element.
11.19. Comment: The Environmental Summary Matrix does not include a column for the
discussion of significance after mitigation for each issue area. Without
this information, how can overriding findings be made?
Response: The information is contained in each of the categories listed in the
Matrix, in the right hand column. However, the CIR will be amended to
include an additional (fourth) column for each category, titled "Level of
Significance After Mitigation." The California Environmental Quality
Act (CEQA) requires that the Environmental Summary Matrix include a
brief sun unary of the proposed action, its consequences, proposed
mitigation measures, and the relative significance of each project
altcrnativc. Detailed analysis of each issue of environmental concern and
52
H.20. Comment:
TN./City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
the significance of the proposed action is provided in Section III, and an
analysis of each project alternative is provided in Section V. The
information provided within the EIR as a whole is of sufficient detail for
the City to determine whether a Statement of Overriding Considerations
is necessary and appropriate.
There is no discussion about impacts and mitigation measures under
Traffic/Circulation [in the Environmental Summary !vial -ix.' for the
Desert Resorts Airport.
Response: Comment noted. The Traffic/Circulation portion of the Environmental
Summary Matrix is hereby modified to include the following:
11.21. Comment:
Project Impacts
Buildout of the planning area is expected to contribute to a regional
increase in air traffic at the Desert Resorts and Bermuda Dunes Airports.
Forecasts of future activity at the Desert Resorts Airport indicate that it
is expected to accommodate a substantial increase in annual operations
and may be capable of accommodating larger aircraft.
Mitigation Measures
The City shall maintain close, on -going consultation with the Riverside
County Airport Authority regarding the future expansion of the Desert
Resorts Airport and the facilitation of commercial air traffic in the
eastern Coachella Valley.
Significance levels are not clearly stated for several of the areas of
concern. These should be added to the document and to the Project
Impacts column of the matrix.
Response: Comment noted. Please see response to Comment 419, above.
H.22. Comment:
Discussion needs to be added to the DEIR that identifies specific
impacts to the Cities oflndiu and Coachella, and quantifiable mitigation
measures.
Response: The General Plan and draft EIR include extensive mitigation measures
that will directly apply to future development in the planning area, but
will indirectly benefit the Cities of Indio and Coachella and other
neighboring communities. Among these are the required construction of
on -site retentionldetention basins to contain and minimize the adverse
impacts of urban runoff, the continued maintenance and improvement of
local roads and intersections, and the extension of public services and
facilities to the southeasterly portion of the planning area, Given the
implementation of these and numerous other mitigation measures,
53
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
policies, and programs described in the General Plan and draft EIR,
implementation of the proposed Plan is not expected to result in
significant adverse impacts to neighboring communities. The City shall
continue to consider potential impacts to neighboring jurisdictions on a
casc-by-case basis, as future development proposals are reviewed, and
shall continue to consult and coordinate neighboring jurisdictions,
wherever necessary.
H.23. Comment: The energy crises need to be discussed in the DEIR, including both
electrical supply and natural gas resources.
Response: Comment noted. The Electricity, Existing Conditions portion of Section
III-G of the EIR (pages III-185 and III-186) is hereby amended to
include the following:
"In 1998, the State of California implemented legislation that
deregulated its electric power industry. The legislation mandated rate
reductions from some electric companies and allowed consumers of
large, investor -owned utilities the option to choose alternative electricity
providers. Smaller, community -owned utilities (Like Iill) were not
required to offer their customers alternatives at that time. The primary
goal of deregulation was to enhance competition in the electric industry
and bring choices to consumers_
The legislation froze rates charged by investor -owned utilities at 1996
price levels. By winter 2000, a significant price gap emerged between
wholesale electricity prices and maximum retail prices that utilities were
permitted to charge. Wholesale prices typically exceeded the maximum
permitted retail prices, making it cheaper not to provide electricity to
consumers. Subsequently. many California communities experienced
rolling blackouts to save cm the state's power grid, Coachella Valley
customers that signed up for voluntary service interruptions, in exchange
for price discounts, also experienced occasional power outages.
A true electric power supply problem may exist in California, and the
demand for electricity in California appears to be outstripping the
combination of state and interstate electricity supplios. Interstate
suppliers that sold electricity to California utilities in the past have
experienced low winter temperatures and precipitation in recent years.
As a result, hydroelectric and other power resources are not as readily
available as they once were. Significant federal and state participation in
the environmental review process makes permitting difficult in some
cases, particularly in meeting applicable air and water quality
standards."
-4
TN.City of La Quints
General Plan Final EIR
Response to Comments an DEIR
H.24. Comment: Page I-13: Table I-2, Land Use column, 0 Officeg4. Is this a typo?
Response: Yes. The spacing of the table has been amended as follows:
Total Dev. Vacant Existing Future Total
Land Use Acres Acres Acres Sq.Ft.' Sq.Ft.7
0 Office 84 44 40 421,661 383,328 804,989
H.25. Continent: Exhibit III-1: City of La Quinta Existing General Plan. This exhibit is
confusing with the County designations included.
Response: The exhibit accurately depicts existing land use designations in the
entire planning area. Land use designations within the City limits are
those assigned by the current City of La Quinta General Plan. Land use
designations outside the City limits are those currently assigned by the
County of Riverside Comprehensive General Plan,
H.26, Comment: Page III- 16 is printed twice.
Response: Comment noted.
H.27. Comment: Page III-21: paragraph 1, line 1, "of" should be or,
Response: Comment noted. The sentence is hereby amended as follows:
":The City shall identify potential adverse or unacceptable noise
exposures, analyze and assure the efficacy of mitigation programs, and
assure construction is in accordance with the approved noise mitigation
plan."
H.28. Comment: Page III-26: Indirect Environmental Impacts section should include
discussion on specific impacts to the Cities of Indio and Coachella.
Response: Please see response to Comment #22, above.
11.29. Comment:
Pages I1I-91 and 92: Is there a conflict with the nurnhcr of dwelling units
indicated on Page 91, Paragraph 5, line 2, "78,952 dwelling units...",
and Page 92, paragraph 5, line 2, "...66,811 new dwelling units"?
Response: No. "78,952" represents the total number of dwelling units anticipated at
General Plan buildout, including new and existing units. "66,811"
represents the number of new units that could be facilitated by the
Recommended Alternative (please refer to 'fables I-2 and III-2 of the
DEIR).
55
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
H.30. Comment: Page III-121: paragraph 4, consider stating that the City was actually
certified as a CLG in April of 1995; Also, the reference to Appendix K
is obsolete.
Response: Comment noted. A discussion of the City's becoming a Certified Local
Government (CLG) is provided on page 93 of the General Plan. The
reference to Appendix K is hereby deleted from the draft E1R.
H.31. Comment: Page Ili-143: Subsection Q, should include the requirement that truck
loads be covered.
Response: Comment noted. The statement has bean amended as follows:
H.32. Comment:
Q.
To minimize construction equipment emissions, developers shall:
• Wash off trucks before leaving the site
• Require trucks to maintain two feet of freeboard
• Properly tune and maintain construction equipment
• 1;se low sulfur fuel for construction equipment
• Require that dump truck loads be covered
Page 111-166: paragraph 1, this discussion should be updated as the
Mountain Vista School opened September of 2000 and is in full
operation,
Response: Comment noted. References to lvlounlain Vista Elementary have been
deleted from paragraph 1 on page 111-166, and 'fable 111-33 his been
modified to include the following information.
H.33. Comment:
Grade Current Max
School Name Level Enrollment Capacity
Mountain Vista Elem. K-6 502 750
Page III-170: Existing Conditions, Since the existing library in La
Quinta is currently underserved, and the proposed new library will not
meet the planning standard, will there not be an impact upon other
adjacent libraries?
Response: General Plan Policies 5 and 6 (page 71) and the mitigation measures
described on FIR page II1-171 require the City to continually monitor
library needs and assure that adequate library facilities and services are
provided to City residents. Impacts to libraries in adjacent communities
are not expected to be significant.
5(
TN1City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
H.34. Comment: Page III-185: paragraph 1, line 2, GTE is now Verizon.
Response: Comment noted. A11 references to "CITE" have been amended to read
" Verizon.°'
1I.35. Comment:
Page I11-185-186: Electricity: Consider adding a discussion under
Existing Conditions on the current power crises and the proposed power
plants in the valley.
Response: Comment noted. See response to comment # 23, above,
H.36. Comment:
Pages 1II-188-1 89: Natural Gas: Consider adding a discussion regarding
the current supply of natural gas in light of the power crises under
Existing Conditions,
Response: Comment noted. The following is added to the last paragraph of the
Existing Conditions discussion on page I11-189:
H.37. Comment:
"The provision of natural gas may be affected by the electrical power
shortages currently being experienced in California (please see pages II1-
185-184"
Page III-195: 'Fable III-41: Why are employers outside the City of La
Quinta included in this table when the title indicates that they are inside
the City boundary`?
Response: Comment noted, The title of the table is hereby modified to read "Major
Employers in the Eastern Coachella Valley."
H.38. Comment: Page V-9: Table V-2: The Commercial Subtotals on this table and Table
V-3 are different. Is there a reason?
Response: Yes. Table V-2 represents the land use buildout scenario for Alternative
I, the More Intense Alternative. Table V-3 represents the land use
buildout scenario for Alternative II, the Less Intense Alternative. These
alternatives involve different land use patterns, which result in different
land use acreage summaries.
57
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
Y. CITY OF INDIAN WELLS
I, 1. Comment: The descriptions of the adopted land uses in the City of Indian Wells on
Page No. 1-10 and 111-7 arc inaccurate. The area west of Fred Waring
Drive adjacent to the Garden of Champions, is currently zoned for
Resort Commercial uses and not Community Commercial. Please see
attached exhibit.
Response: Comtnent noted. The statements found on page 1-10, 2°d paragraph, 2nd
sentence; and page III-7, 2" paragraph, 2" sentence are hereby revised
as follows:
"Land along the northwest boundary of the General Plan planning area,
south of Fred Waring Drive and adjacent to the Garden of Champions, is
designated for Resort Commercial development."
E. 2. Comment: The existing hillside areas (between Indian Wells and La Quinta) are not
appropriate for the proposed Community Commercial and High Density
residential Land Use designations as depicted in the Recommend Land
Use Plan illustrated in Exhibit II1-2. Any development within this arca,
as proposed, would severely impact the adjacent residential areas within
the City of [ndian Wells. A Hillside Overlay designated should be
placed on these areas to protect the resources.
Response: Comment noted, The Community Commercial designation is applied
only to the existing shopping center at the southwest corner of
Washington Street and Highway 11 J The Medium Density Residential
designation occurs only below the toe -of -slope. The City maintains a
Hillside Conservation Ordinance, which strictly regulates hillside
development. As shown in Exhibit III-2, land along the La Quintallndian
Wells boundary to the west and south of the area is question is
designated as Open Space with a Hillside Overlay.
I.3. Comment: As per our prior discussions, staff has observed Peninsular Big Horn
Sheep on the hillside area adjacent to Point Happy Ranch. This
information should be included in Exhibit 1[1-22. See attached color
photos dated 5/9195.
Response: The data provided in Exhibit III-22 was taken directly from the official
species mapping database of the Coachella Valley Multiple Species
Ilabitat Conservation Plan (MSIICP). By inclusion in this Final EIR, the
above -referenced sighting at that location is noted. The City
recommends that the commentor send the above -referenced photos to
the Bureau of Land MMIanagement or Coachella Valley Mountains
58
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
Conservancy so that these observations can be included in the I ISHCF
mapping database. As shown on Exhibit III-2 of the draft EIR, the Point
Happy ridge is designated as Open Space with a Hillside Overlay under
the Recommended Alternative ]and use plan.
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
J. GARY MITCHELL & ASSOCIATES
J.1. Comment: The proposed project represents a fundamental transformation from a
low density, equestrian -oriented and agricultural -related pattern of land
uses which have existing for many decades to a highly developed urban
pattern of land use allowing up to 16 dwelling units per acre. The
socioeconomic impacts of this project to the existing community have
not been adequately addressed in this draft EIR.
Response: As sho=is on Exhibit I11-1 and described in Table III-1, the existing La
Quinta General Plan currently provides for residential densities of up to
16 dwelling units per acre, In this regard, the proposed General Plan
does not represent a radical departure from the existing Plan. The
proposed High Density Residential (HDR) land use designation is the
only designation that allows for up to 16 dwelling units per acre. As
described in Table 1-2 and illustrated in Exhibit 11I-2, under the
Recommended Alternative, this designation is applied to 282 acres,
which represents only 0.5% of the entire General Plan planning area.
Approximately 105 (37%) of these acres are already developed.
Furthermore, the Recommended Alternative land use plan does not
propose any High Density Residential land uses in the south-central or
southeasterly portion of the planning area, other than those already
approved by Riverside County. Instead, it restricts future residential
development to a maximum of 2 dwelling units per acre or 4 units per
acre, depending on location, and applies an Agricultural Overlay to
allow for the continuation of existing agricultural activities at the
landowner' s discretion.
A detailed fiscal analysis of the potential costs and revenues associated
with General Plan buildout is provided in Section I11-Nt, Svciu-
Economic Resources, of the EIR. The City recognizes that the impacts
associated with conversion of agricultural lands to urban development
constitute a significant impact (EIR page III-28) and may not be entirely
rnitigatable.
J.. Comment: Analysis of required project alternatives, (including "no project"), arc
ranked as having similar impact levels to various environmental
resources, This statement deserves to have greater description and needs
to be able to justify this blanket conclusion.
Response: Section V of the MR contains thorough analysis of three project
alternatives, including the No Project Alternative," "More Intense
Alternative," and "Less Intense Alternative." Anticipated impacts of
each project are described for all environmental areas of concern
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Response to Comments on DI;IR
addressed for the Recommended Alternative in Section III. For each
subject area, the EIR clearly describes anticipated levels of impact
associated with huildout of each land use alternative, and quantifies
these impacts where possible. It also compares them with the
Recommended Alternative; although some anticipated impacts are
expected to be "similar" to those of the Recommended Alternative,
others are expected to be different, as described throughout Section V.
.J.3. Comment: The draft EIR does net adequately assess the fiscal impacts of (his
project upon the community. No fiscal impact analysis has been
provided that specifically addresses the direct as well as indirect fiscal
costs and benefits of the proposed project. The public infrastructure
investment to support the magnitude of the proposed development is
enormous in comparison to the maintenance of current development
intensity. If the draft EIR is correct in its projected budget shortfall of
$5.387 Million per year, then how can the "no project" alternative be
dismissed as to fiscal impact analysis'? Furthermore, if this fiscal
assessment is accurate, then what incentive is there for the City of La
Quinta to pursue the proposed development, annexation, and expanded
City General Plan planning area?
Response: A detailed fiscal analysis, which describes anticipated costs and benefits
associated with the proposed actions, is provided in Section III-M of the
draft filR. It is important to remember that the General Plan is a broad -
reaching policy document, and General Plan huildout will occur over
many years. The FIR fiscal analysis, therefore, estimates projected costs
and revenues to the greatest extent possible at this time, Project -specific
fiscal analyses may be required as future development is proposed.
Future extensions of public services and infrastructure will be largely
financed by developer impact Fees, as developers are expected and
required to pay their fair share of these improvements.
Huildout of the General Plan planning area, as proposed, is anticipated to
result in a positive annual cashflow of approximately $20.5 million, as
shown in Table 1EI-46, The projected shortfall of $5,387 million cited
above by the cornmentor represents the estimated annual shortfall of the
Annexation No. 12 component of the proposed project, as described in
Table III-47. An explanation of why a budgetary shortfall may occur in
the proposed annexation area is provided on page III-206. While the
annexation itself may result in negative annual cashflow, when rolled
into the broader General Plan project, the anticipated positive fiscal
impacts are considerable,
J.4. Comment: The noise impact analysis appears to be inadequate as to the expected
growth of the Thermal Airport. The noise contours depicted in the draft
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General Plan Final EIR
Response to Comments on DEIR
EIR appear to have been borrowed from previous studies which were
prepared with the assumption that the current low -density agricultural
land use pattern would be continued. The incremental increase of
permitted development proposed, (up to 16 dwelling units per acre),
would be expected to have more severe impacts from noise as the
Thermal Airport continues its expansion and air traffic volume.
Response: The exhibit is duplicated from the airport's master plan, approved by the
FAA. Future expansion of the Desert Resorts (Thermal) Airport is under
the jurisdiction of the Riverside County Airport Authority. Although the
City of La Quinta routinely consults and coordinates with this agency
regarding general airport service to the eastern Coachella Valley, it has
no direct control over airport expansion or operations, Anticipated Year
2010 noise levels associated with planned expansions ut Desert Resorts
Airport are described on pages 32-24 of Appendix E, and illustrated on
Exhibit 111-29 of the EIR. As described in Mitigation Measure L on page
III-59 of the EIR, and Program 10.1 on page 40 of the General Plan, the
City will continue to coordinate with the Airport Authority regarding the
updating of the Desert Resorts Air ort Master Plain and future expansion
of airport facilities to serve the eastern Coachella Valley. The location of
the noise contours will be considered in any future development
proposed near the airport, however, given that the 65 dBA noise contour
occurs almost entirely within the airport's boundary, future project in the
area may only have to provide certain construction improvements to
mitigate interior noise levels.
J.S. Comment: Loss of prime agricultural land and production area will be very
substantially and negatively impacted by this project. The draft FIR does
not adequately assess these impacts, nor does it provide effective
environmental mitigation measures to lessen these impacts. Loss of
prime, productive agricultural lands is a permanent impact with long-
term implications. Agricultural soils cannot be reclaimed for future use;
therefore the assessrnenf of the preservation and enhancement of prime
agricultural soils is vital to the assessment of this project and its impacts
to the cotrununity.
Response: Comment noted. Section III-B of the FIR is entirely dedicated to the
subject of potential impacts to agricultural lands, and it includes a
detailed description of applicable agricultural land classifications and
their soil and production characteristics. The City recognizes that the
potential impacts associated with the conversion of agricultural land to
urban development will be significant (EIR page TTI-28) and may not be
entirely rnitigatable. The Agricultural Overlay has been applied to
approximately 17,615 acres of land in the south-central and
southeasterly portion of the planning arca to support the continuation of
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General Plan Final EIR
Resaonse to Comments on DEIR
existing agricultural activities at the discretion of landowners, The City
shall also require a minimum 100-foot buffer between residential
development and agricultural lands to minimize land use
incompatibilities. A wide range of other applicable mitigation measures
are described on page 1II-28 ate EIR, and all are expected to minimize
impacts to agricultural lands and future residential development in the
vicinity.
J.6. Comment: The anticipated real effects to current residents and landowners
concerning the keeping of horses, raising of agricultural crops, and
operation of businesses related to open space have not been assessed.
There is inadequate provision made for the "grandfathering" of current
land uses, structures, and investments made by the many farming
businesses and others who have lived in the community for many years.
Response: The General Plan is a broad -reaching policy document, and as such, it is
beyond the scope of the General Plan to identify detailed standards
associated with the proposed Agricultural Overlay. Specific standards
and protocols will be addressed in the City's zoning ordinance, which
includes right to farm provisions, "grandfathering" and legal non-
conforming provisions, after adoption of the General Plan,
J.7. Comment: There is no environmental analysis reviewed which speaks to the issue
of how a proposed development project can attain a density of up to 16
dwelling units per acre. In lieu of such development standards, the draft
HIR must assume a "worst ease" development scenario of 16 units per
acre for the entire planning area. That analysis has not been done.
Response: The High Density Residential land use designation is the only proposed
designation that permits up to 16 dwelling units per acre. As illustrated
in Exhibit III-2 and described in Table 111-2, the Recommended Land
Use Plan assigns the High Density Residential designation to
approximately 282 acres, 105 of which are already developed, and 177
of which are vacant. It does not apply this designation throughout the
entire planning area, and therefore, is not required to assume a
development scenario of maximum 16 units per acre for the entire
planning area. The City's Zoning Ordinance provides specific
development standards and criteria for all development proposed within
the City limits, as it is beyond the scope of the Uencral Plan to do so.
Site -specific development plans are subject to applicable environmental
review and City approval.
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Cieneral Plan Final EIR
Response to Comments on DEIR
J.S. Comment: Summary Matrix
'fhe area of the proposed build -out is described as 53,498 acres. What is
the proposed build -out population, in terms of dwelling units and
residents?
Response: As mentioned throughout the EIR, the anticipated number of dwelling
units at General PIan buildaut is 78,952 (including 12,141 existing units
and 66,811 potential/future units), and the anticipated buildaut
population is 207,970 residents (please refer to pages I-13, II1-8, JI1-92,
and all of Section
J.9. Comment: The EIR summary mentions "moderate" increases of residential and
commercial uses. What is meant by "moderate"? Define in terms of
maximum build -out scenarios, and relate by % to current City of La
Quinta land use mix to assess the use of the term "moderate".
Response: The Environmental Summary Matrix is intended only as a summary of
existing conditions, anticipated project impacts, and mitigation
measures. Detailed analysis and buildaut projections are provided within
the main body of the E1R, 'Tables 11I-1 and V-I provide a statistical
analysis of current land use and development conditions in the General
Plan planning area. Tables 1-1 and 1-2 provide a statistical summary of
anticipated land uses at buildaut of the Recommended Alternative.
Further comparison of the current General Plan and Recommended
Alternative is provided on pages V-2 and V-3 of the EIR.
J.10. Comment:
The Summary mentions the proposed General Plan forecasts residential
densities tip to sixteen units per acre, How is this level of density
consistent with the statement "...continue the low intensity development
pattern already established in the City"?
Response: Despite the City's predominantly low -density character, it does contain
pockets of medium and high -density development. The current La
Quinta General Plan Land Use Plan includes approximately 101 acres of
land designated for residential densities up to 16 units per acre (HDR
High Density Residential, 12-16 duiac). The current Riverside County
Comprehensive General Plan facilitates residential densities up to 15
units per acre (RH, 15 dulac), and the County recently approved two
Specific Plans (Coral Mountain and Kohl Ranch) that include medium
and high -density residential development in the south-central and
southeastern portions of the planning area. Please refer to Exhibit III-1
and Table III-1. The Recommended Alternative does not introduce any
land use densities which exceed currently established densities within
the City.
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General Plan Final EIR
Response to Comments on DEIR
J.11. Comment: The draft General Plan forecasts 6.280 acres for "very low density
residential" development, even though the planning area comprises
53,498 acres. How does the EIR base its statement that land use
compatibility is assured by the General Plan?
Response: The very low -density residential acreage estimate stated in the cornment
is erroneous. As described in Tables 1-2 and III-2 of the E1R, and Table
2,2 of the General Plan, the Recommended Alternative designates
7,0891 acres for Very Low Density Residential development.
The proposed land use plan (Exhibit J[1-2) has been developed
specifically with land use compatibility in mind and locates sensitive
receptors away from noise and/or air pollution generators to the greatest
extent practical. With the exception of lands included within the
Agricultural Overlay, proposed residential densities and land use
patterns are largely consistent with those assigned by the existing City
and County General Plans. The proposed General Plan includes
extensive mitigation measures which will reduce potential land use
incompatibilities. Among these arc the continued implementation of the
City's noise and fugitive dust ordinances, a minimum 100-foot buffer
between agricultural lands and urban development, limitations on
outdoor lighting, the continued use of native, drought -tolerant
landscaping materials, the shielding of public utility equipment, and the
continued implementation of urban design and development standards.
The City shall continue to review future development proposals to
assure that any potential project -specific land use incompatibilities are
identified and mitigated.
J.12. Comment: Traffic/Circulation impacts are described in a separate study. What is the
assumption of traffic operating levels shade in that study? Is traffic level
"C' being assumed? The FIR describes operating levels at level "D"
currently exist in the City of La Quinta, What is being proposed to
mitigate this significant adverse impact?
Response: The General Plan Update Traffic Study is included in its entirety in
Appendix p of the draft EIR, Anticipated traffic and circulation impacts
are addressed in both the traffic study and Section III-C of the EJR. As
explained on page III-30 of the EIR, the General Plan traffic analysis
designates level -of -service (LOS) "D" and/or a maximum volume to
capacity ratio of 0.90 as the peak hour performance standard or design
guideline for traffic volumes on the roadway system. LOS D represents
high -density but stable traffic flow, with tolerable operating speeds.
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General Plan Final EIR
Response to Comments on DEIR
The (raffle study and EIR indicate that all modeled intersections in the
General Plan planning area currently operate at LOS D ur bolter. The La
Quinta General Plan Traffic Model analyzed General Plan buildout
traffic levels. The results indicate that all 20 intersections modeled are
anticipated to operate at acceptable levels -of -service "D" or better_ Of
the 278 roadway segments modeled in the planting area, 263 (94.6%)
are projected to operate at acceptable levels -of -service "D" or better,
and 15 (5.4%) arc projected to exceed typical Average Daily Trips
(ADT) capacities. It is worth noting that 8 of these segments are
projected to exceed capacity by only 3% or less of roadway capacity.
Although a roadway segment may be identified as exceeding the
allowable capacity, intersection improvements may allow the endpoints
ofa segment to operate acceptably.
The General Plan and draft EIR identify numerous programs and
mitigation measures that will reduce these potential impacts to
acceptable levels. Among these are implementation of the intersection
geometries provided in Exhibit 111-14 and cross -sections described in
Exhibit 1I1- 12, development of a municipal master plan or roads,
maintenance of a balanced mix of housing and employment
opportunities, and promotion of non -motorized transit.
113. Comment: The trafCicicirculation section makes no mention of comprehensive
multipurpose trails or related circulation improvements other than a golf
cart route system. How can the proposed development be consistent with
the environmental character ut' the area without a trails system Linking
equestrian and _jogging areas with other areas located in the City and in
adjacent areas, i.e. polo club area?
Response: The General Plan and E1R are clearly responsive to the need for a
comprehensive multi -use trail system, which facilitates pedestrian.
bicycle, equestrian, and other non -motorized traffic. A proposed multi-
purpose trail system is illustrated on Exhibit 3.10 of the General Plan.
Please also sec the following references: 1) Mitigation Measure G on
page 111-159 of the EIR, 2) Policy 7 and its programs on pages 39 and 40
of the General Plan, 3) Policy 4 and its programs on pages 47 and 48 of
the General Plan, and 4) Policy 6 and its programs on pages 43 and 44 of
the General Plan, all of which address the need for a coordinated, multi-
purpose trails system.
.1.14. Comment:
The E]R states that "...Less Intensive Alternatives would result in all
intersections operating at Isevel of Service D or better. What is the
justification for this conclusion? The EIR seems to suggest that only the
intensive development scenario will improve this circulation system.
Wily wouldn't a lower level of dwelling units and population require a
66
TATICity of La Quinta
General Plan Final E1R
Response to Comments on DEER
lower level of traffic and circulation improvements? The Indio General
Plan, whose planning area is contiguous to the proposed project area,
assumes level "C" for traffic improvements, Has the draft EIR analyzed
the inconsistency between the proposed project and the existing adopted
land use plan of a neighboring city?
Response: The General Plan Traffic Study is included in its entirety in Appendix F
of the EIR. The study, in conjunction with the summary provided in
Section III-C of the EIR, provides a complete explanation of the
conclusions reached by the traffic engineer, and incorporated into both
the fieneral Plan and FIR.
The impacts associated with the recommended alternative, as well as
three other alternatives, are fully analysed in the EIR. Section V of the
EAR identifies impacts associated with all alternatives relating to traffic
generation, including most significantly for the comrnentcr's comment,
Table V-4, Comparison of Intersection Impacts For Each Project
Alternative_ This 'Table, and the associated text, demonstrates that the
Low Density Alternative generates 14° o fewer trips than the
recornrnended alternative_
The standards and policies of surrounding jurisdictions have been
incorporated into all modeling efforts for transportation facilities within
the City.
J.15. Comment: Soils & Geology- The. EIR concludes that "...build -out of the General
Plan is not expected to significantly increase risks associated with
groundshaking and other seismically induced hazards..." What is the
evidence analyzed that would support this conclusion?
Response: Please refer to the "Technical Background Report for the Safety Element
for the City of La Quinta" (Appendix G) and Section III-D of the EIR,
both of which provide extensive discussions of potential geologic and
seismic hazards in the planning area, and offer numerous mitigation
measures which will reduce these risks to acceptable levels. A reference
list of more than 130 sources analyzed to reach these conclusions is
provided in Appendix A of the Technical Background Report for the
Safety Element,
J.16. Comment:
Visual Impacts. What development standards does either the proposed
General Plan or draft EIR. provide to ensure the preservation of the
unique and valuable visual resources of the Santa Rosa Mountains and
viewshed?
67
TNICity of La Quints
General Plant Final EIR
Response to Comments on DEIR
Response: The General Plan and EIR propose numerous policies and programs
designed to mitigate potential adverse impacts to valuable regional
viewsheds. The Mitigation Measures provided on pages 111-163 and 111-
164 address outdoor lighting, undergrounding of utilities, appropriate
landscaping materials, design and screening of utility equipment, and
signage. The General Plan Land Use Plan designates the Santa Rosa and
Coral Reef Mountains as Open Space with a Hillside Overlay. General
PIan Policies 13, 14, and 15, and their corresponding programs, establish
primary, secondary, and agrarian Image Corridors throughout the
planning area, Site -specific setbacks, height restrictions, and
architectural regulations are addressed in the City's zoning ordinance, as
it is beyond the scope of the General Plan to do so.
J.17. Comment:
Uround surface disruption will result in substantial wind erosion and
related environmental damage to the community, What mitigating
measures are proposed to alleviate this unavoidable impact?
Response: The General Plan and IIR propose a wide range of policies, programs,
and mitigation measures which reduce wind erosion hazards. Mitigation
Measure G on page 111-75 of the EIR requires that all grading permit
requests include a soil erosion prevention plan, which includes a variety
of fugitive dust control measures to be implemented before, during, and
after development. Mitigation Measure E on page 111-142 of the EIR
encourages the phasing of development projects to reduce construction -
related emissions, and requires the use of water trucks, temporary
irrigation systems, and other measures which limit fugitive dust
emissions resulting from site disturbance. According to Mitigation
Measure M on page I11-142, the City shall support the air quality control
measures identified in the Coachella Valley PMl 0 State Implementation
Plan, Mitigation Measures 0 and Q (page III-142 and 1I1-143) describe
specific dust control management controls that may be submitted with
development proposals. Per Program 6,2 of the General Plan, the City
shall continue to maintain and enforce its Fugitive Dust Control
Ordinance. Please also see Programs 6.4 and 7.2 on page 51 of the
General Han.
118. Comment:
hydrology. The EIR states that conversion of low density agricultural
land to urban development could result in increased run-off. What
analysis has been performed that contrasts the project alternatives? The
EIR consistently states that "only the Recommended Altemative" would
result in acceptable environmental risks, and that impacts of other
alternatives would result in the same levels of impact. How is this
conclusion supported by a reasonable alternative comparative analysis?
68
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General Plan Final EIR
Response to Continents on DEIR
Response: Section V of the EIR evaluates the same range of environmental issues
for three project alternatives that were evaluated for the Recommended
Alternative in' Section ill, It compares and contrasts the anticipated
impacts associated with buildout of each project alternative. A
comparison of the anticipated hydrologic impacts associated with each
project alternative is provided on page V-19. Since all development
results in increases in impermeable surfaces, the No Project is the least
impacting to hydrological resources. The next least impacting would be
the Less Intense Alternative, which results in fewer buildings, and
therefore fewer impermeable areas.
J.19. Comment:
The commcntor's suggestion that the "EIR consistently states that `only
the Recommended Alternative' would result in acceptable
environmental risks, or that impacts of other alternatives would result in
the same levels of impact" is entirely unsubstantiated. In fact, on pages
V-13 and V-15, the EIR indicates that the No Project and Less Intense
Alternatives will result in moderately reduced levels of future
Y
development than the Recommended Alternative. On pages V,16 and V-
17, the EIR indicates that buildout of the No Project and Less Intense
Alternatives will result in fewer trips generated and overall better levels -
of -service than the Recommended Alternative. On page V-19, the E1R
states that "none of the four alternatives is expected to have any
significant effect or advantage with regard to the efficacy of these
[hydrology] facilities." On page V-20, the EIR states that "from a water
consumption perspective, the No Project Alternative is the superior
project alternative, closely followed by the Less Intense Alternative." On
page V-23, the EIR states that "the No Project Alternative is expected to
generate the least [air quality] pollutants, closely followed by the Less
Intense Alternative." On page V- 30, the EIR states that the No Project
and Less Intense Alternatives "appear to be the favorable project
alternatives in that they will place the fewest demands on local schools."
Numerous other examples of objective comparisons between the four
project alternatives can be found throughout Section V of the HR.
Biological Resources, The EIR states that the low -density development
(up to 16 dwelling units per acre) pattern proposed by the General Plan
is not expected to result in adverse impacts to existing biological
resources. What is the justification of this conclusion?
Response: As shown in Tables 1-2 and III-2, the General Plan facilitates the
development of up to 16 dwelling units per acre on only 282 acres
(0.5%) of the planning area. In fact, the majority of residential lands
(22,705 acres or 42.4% of the planning area) are designated for Low
Density development of up to 4 units per acre.
69
TN/City of La Quinta
General Plan Final EIR
Resp use to Comments on DEIR
J.20, Comment:
Although buildout of the proposed General Plan may adversely impact
biological species, these impacts can be adequately mitigated and are not
expected to be significant. Implementation of the mitigation measures
identified in the "La Quinta General Plan Update Biological
Assessment" (Appendix C of the E1R) and Section III-0 of the FiR, and
the policies and programs described on pages 62 and 63 of the General
Plan, will reduce potential impacts to acceptable levels.
Cultural Resources_ The EIR mentions several mitigating measures by
suggesting that the City might consider adopting historic standards and
other non -existing policies relating to preservation of cultural resources.
flow can these mitigation actions be effective if they arc not adopted
prior to development:
Response: As explained o11 page III-I21, the City has already adopted a Historic
Preservation Ordinance and established a Historic Preservation
Commission, which is responsible for the review of proposed
development as it relates to the historic preservation of the community.
Additionally, the City has already prepared a historic resources
inventory, which is provided in Appendix B of the EIR. The mitigation
measures described on pages III-123 and II1-124 are prescriptive and
require the City to take additional actions to preserve and enhance
valuable cultural resources. For example, all development projects
involving discretionary city action shall be reviewed by a qualified
archaeologist, historian, or other approved professional in order to
identify potential impacts to historical resources and appropriate, site -
specific mitigation measures. A qualified archaeologist and/or Native
American representative shall provide on -site monitoring during ground -
disturbing activities. The City shall strictly enforce building codes to
prevent deterioration of historic buildings and districts, and shall
develop and implement a public awareness program regarding local
heritage.
.J.21. Comment: Noise Impacts, The noise estimates for the Thermal Airport
development scenario appear to reflect the continuation of historic land
use patterns. Has the draft FIR adequately taken into account the
proposed urban development scenario as analyzed from noise impacts as
are expected at the Thermal Airport continues to grow and experience
greater air traffic volumes?
Response: Please see response to comment #J.4, above.
J.22. Comment: Fiscal Impacts. 'low have the fiscal impacts been addressed without the
preparation of a new fiscal impact analysis? The public infrastructure
improvements required by this magnitude of development will require
70
TIICity of La Qainta
General Plan Final EIR
Response to Comments on DEIR
substantial investment from both the public and private sectors. The
fiscal impacts of this need to be specifically addressed to the "worst -
case" development scenario, up to 16 dwelling units per acre, If the draft
EIR is accurate in its estimate of an estimated fiscal budget shortfall of
$5 Million for the provision public services to support the required level
of infrastructure improvements, then how can the EIR dismiss the "no
project" alternative?
Response: A fiscal analysis for the Recommended Alternative is provided in
Section 11]-M of the draft EIR, and fiscal analyses for the other three
project alternatives are provided in Section V. While a portion of public
infrastructure improvements required to serve future development will
be funded by public sources, a substantial percentage will lac funded by
developer impact fees, as developers are expected and required to pay
their fair share of such facilities.
J.23. Comment:
The proposed General Plan facilitates the development of up to 16
dwelling unites per acre on only 282 acres (U.5%) of the planning arca_
The remaining 32,669 acres of residential /and are designated for lower
densities, ranging from 0 to 12 units per acre. The fiscal analyses in the
EIR analyze anticipated costs and benefits associated with buildout of
each project alternative. It is worth noting that the General Plan is a
long-range policy document, and is only capable of providing fiscal
projections at this time, Actual revenues and costs will depend upon
future levels of development, and the City may require that project -
specific fiscal analyses be prepared as development is proposed.
As previously explained in the response to Comment #J.3, above,
buildout of the proposed Ciencral Plan is anticipated to result in a
positive annual cash flow of approximately $20,5 million, as shown in
Table I11-46, The projected shortfall of $5 million cited by the
commcntor represents the estimated annual shortfall of the Annexation
No. 12 component of the proposed project (Table I1I-47). An
explanation of why a budgetary shortfall may occur in .the proposed
annexation area is provided on page 111-206. While the annexation itself
may result in negative annual cashflow, when rolled into the broader
General Plan project, the anticipated positive fiscal impacts are
considerable.
Agricultural Resources. The Coachella Valley is world -recognized as a
leading agricultural production area, Why have existing valuable
agricultural soils and production lands not been adequately identified by
mapping or other means by this draft EIR?
71
'IN,City of La Quints
Genera! Plan Final EIR
Response to Comments on DEIR
Response: Section I1I-B of the EIR is entirely dedicated to the subject of
agricultural lands. A detailed description of existing agricultural land
classifications, soil characteristics, production suitability, and
corresponding acreage estimates for the planning area is provided on
pages 111-22 and I1I-23. The provisions of the Williamson Act are also
explained, and the number of acres subject to Williamson Act contracts
within the planning area is provided.
J.24. Comment: Biological Resources. The draft EIR references the preparation of the
Coachella Valley Multiple Species Habitat Conservation Plan (CV
MSHCH). Has a separate biological assessment, including field
assessment, habitat survey, and field observation been performed for this
environmental study? Since this work is currently being undertaken by
the public agencies identified, how can the project impacts to existing
biologic resources be adequately assessed until the CV MSHH has been
adopted?
Response: The La Quinta General Plan Update Biological Assessment was
prepared on June 1, 2001 and is printed in its entirety in Appendix C of
the drab. EIR.
J.25. Comment:
The. Coachella Valley Multiple Species Habitat Conservation Plan
(SHCP) has not been completed or adopted by the Coachella Valley
Association of Governments (CVAG) or its member jurisdictions. The
City of La Quinta is a signatory to the MOU for the preparation (Attie
Plan and has cooperated and participated in its preparation. Upon
completion of the Plan, the City shall carefully consider its adoption and
implementation.
Water Quality/Resources. The EIR needs to state the comparative
demand for water resources and concomitant adverse environmental
impacts to be related to the Project Alternatives in a more
comprehensive manner
• What is the impact of the project to the contamination of the
Salton Sea drainage area?
w Has the EIR taken into account the recent groundwater recharge
program utilizing "tiling" for the lower Thermal water sub basin?
What are the impacts of the continued use of this water
management system to the proposed project?
• How does the draft EIR analyze the expected impacts of the
wastewater effluent to be generated by the project as to existing
and future groundwater quality and quantity?
Response: The EIR addresses potential impacts to water quality in Section III-F.
The EIR arid General Plan include numerous policies, programs, and
72
TNICity of La Quinta
General Plan Final I R
Response to Comments on L)Ellt
mitigation measures designed to reduce potential impacts to acceptable
levels. The City's commitment to connecting all future development to a
community -wide sewer system is one of the most important mechanisms
to reduce future groundwater contamination generated by urban
development. The City shall also require the construction of on -site
retention/detention basins to enhance filtration of urban runoff and
groundwater recharge. The City will continue to work closely with the
Coachella Valley Water District (CV V4'D) to assure that adequate
wastewater collection and treatment facilities are maintained and
sufficiently treated to meet the standards of the California Regional
Water Quality Control Board and other regulatory agencies. The City
will continue to support and promote groundwater recharge efforts in the
Coachella Valley, as well as the use of rceycicd and tertiary -treated
water. All development proposals shall he reviewed on a case -by -case
basis for their potential to create surface and groundwater contamination
hazards from point and non -point sources.
It is worth noting that the application of fertilizers, pesticides, and other
chemical agents to agricultural land is known to be one of the primary
contributors to bang -term 'groundwater quality degradation in the
Coachella Valley..According to CVWD's "Coachella Valley Wetter
Management Plan" (draft, November 20U0, 'fable 3-8), in 1999, the total
amount of salt added to the groundwater basin from the Lower
Coachella Malley (which includes General Plan planning area) was
356,000 tons per year. This is about 74% more than was added from the
Upper Coachella Valley (91,000 tons per year), and is largely associated
with agricultural activity, which predominates in the Lower Valley. Of
this, approximately 251,(100 tons of salt were contributed by canal water
imported for agricultural irrigation, and 16,000 tons were contributed by
fertilizers. Only 7,000 tons were contributed by domestic uses. Although
agricultural drains generally prevent approximately 2,8 tons of salt per
acre-foot from percolating into the aquifer, 25 of these drains empty
directly into the Salton Sea (CVWD, p. 3-29), further contributing to
rcgionai water quality degradation, Implementation of the General Plan
programs and mitigation measures described above can be expected to
Contribute to overall improvements in surface and ground water quality,
TN.City of La Quints
General Flan Final EIR
Response to Comments on UE1R
K. BUILDING INDUSTRY ASSOCIATION
K.11. Comment: Page M-l0 and other sections in the document You appear to consider
data only through 1998 and do not take into consideration that the valley
is presently in a serious non -attainment status and in danger of being
reclassified as a serious non -attainment area. There is no reference to
increased requirements for dust control and more specific dust control
plans.
Response: Comment noted. Table 111-18 is hereby amended, as shown on the
following page, to include PMio emissions data for 1999 and 2000.
Additionally, the following paragraph will replace the 3rd paragraph on
page 111-128 of the P.1R, in order to provide the most accurate, up-to-date
portrayal of the PM10 non -attainment situation itt the Coachella Valley.
"Although the Coachella Valley achieved the federal PM10 standard for
several years in the mid-1990s, it was unable to achieve the annual
average standard far a sufficient, extended period of time. The region
continues to be designated a "serious" non -attainment area for Plviio,
with grading and construction activity representing the most significant
source of fugitive dust emissions, In an effort to remedy this situation.
the SCAQNIDD and CVA[i jointly developed "Guidelines for Dust
Control Plan Review for Coachella Valley Jurisdictions" in November
2000. The guidelines are intended to supplement local dust control
ordinances and assist local government staff in reviewing dust control
plans submitted for construction projects in the valley. In addition,
SCAQMD employs a Coachella Valley P ° Air Quality Inspector, who
advises and coordinates with developers and city staff regarding site -
specific methods of reducing local PM1q emissions. Each city in the
valley has appointed a staff member as the city's "PMt0 dust czar," who
serves a5 a single point of contact for local PAO, issues. Should the
region continue to fall short of federal PMI0 standards, the U.S. EPA
could impose more stringent regulations or sanctions."
74
TN/City of La Quinta
Genera] Plan Final EIR
Response to Comments on DEIR
Table 1111-18
Coachella Valley Air Quality Trends
Exccedances of PMI) Standards
Maximum Na. (%) Samples Annual Average
Monitoring Concentration Exceeding 24-hr, Standards (pg/m)
Station Year (µgim3/24hours) Federal' State.' AAMa AGM'
Palm Springs 1990 83 0 (0.0%) 9 (15.3%) 34.5 30.5
1991 197 1 (1.8%) 14 (25.0%) 42.9 36.6
1992 175 1 (1.7%) 4 (6.7%) 29.6 24.3
1993 58 0 (0.0%) 1 (1.7%) 27.0 23.6
1994 97 0 (0_0%) 23 (38.3%) 48.7 45.3
1995'' 199 1 (1.6%) 27 (44.3%) 52.0 47.2
1996 130 0 (0.0%) 2 (3.3%) 29.3 25.2
1997a) 63 0 (0.0%) 1 (1, 8%) 26.4 23.6
1998 72 0 (0.0%) 3 (5,2%) 26.4 23.8
1999 104 0 (0.0°43) 3 (5,0%) 28.E 26.1
2000 44 0(0.0%) 0(4,0%) 24A 22.7
ludin
1990 520 4 (6_8%) 41 (69,5%) 79.3 64_9
1991 340 3 (5.1%) 37 (62.7%) 69.0 59.8
1992. 117 0 (0.0%) 18 (30.5%) 43.4 39.2
1993 125 0 (0.0%) 25 (41,0%) 46.4 40.6
1994 97 0 (0,0%) 23 (38.3%) 48.7 45.3
1995'' 199 1 (1.6%) 27 (44.3%) 52.0 47.2
1996* 117 0 (0.0%) 29 (50.0%) 50.8 46.1
1997')* 144 0 (0.0(%%) 23 (42.6%) 49.1 44.2
1998 114 0 (0.0%) 32 (40.0%) 48.1 43.8
1999 119 0 (0,0%) 30 (54.0%) 52.7 49.8
2000* 114 0(0.0%) 52(50,0%) 51.9 48.4
t = > 150 *gfrn' in 24 hour period
2 = > 50 pgfm3 in 24 hour period
3 Federal Annual Average Standard = AAM > 501.tglm r
t State Annual Average Standard = AGM > 30µg4m3
A Includes high -wind natural event days
"l Les than 12 full months of data; may not tte representative.
* Data for samples collected on high -wind days were exciuded in accordance with EPA's Natural Events Policy.
Source: Annual air quality site monitoring reports, prepared by South Coast Air Quality Management District,
75
TN/City of La Quinta
General Plan final E1R
Response to Comments on DELR
K.2. Comment: Page III-115: Paragraph "K" is badly worded in that it would require a
"barrier" around the entire site, not just that portion that "borders" the
hillsides. It would require a "barrier" only if the sheep are "demonstrated
to occur on the project site" not on the adjacent hillside What is the
reason for the informal consultation? To provide the basis for need?
Fence design?
Response: Comment noted. Mitigation Measure "K" on page 111-115 is hereby
amended as follows:
"To reduce the impacts of urbanization on bighorn sheep, the City shall
consider requiring barriers between future development projects and the
adjacent hillside if bighorn sheep are demonstrated to occur on the
subject property or adjacent hillside. Informal consultation anchor review
by the U.S. Fish and Wildlife Service and California Department of Fish
and Game shall be completed prior to construction of any barrier, so as
to assure appropriate, safe, arid effective barrier design."
76
IN City {f LA Quints
General Plan Final FIR
Response to Comments an DEIR
L. U.S. DEPARTMENT OF THE INTERIOR
BUREAU OF LAND MANAGEMENT
L.I. Comment: We ask that the plan identify BLM-managed public lands within the City
limits as being under the jurisdiction of the BLM and to acknowledge
the management responsibilities of the BLM on these lands under
Federal Land Policy Management Act of 1976, wilderness designations
under the California Desert Protection Act of 1994, and the Santa Rosa
and San Jacinto Mountains National Monument Act of 2000, (Page I-3,
1-9, 11-9, 111-7, 111-12, 111-10. exhibit I-3, Map 2 within Appendix C,
Biological Report).
Response: Comment noted. The following exhibit, which illustrates BLM-managed
lands in the General Plan planning area is hereby incorporated into the
Existing Conditions portion of Section 1II-A (Land Use Compatibility)
of the draft EIR,
In addition, the following paragraph is added to the Surrounding Land
Ilse discussions on pages 1-10 and 111-7:
"A substantial portion of public land within the Santa Rosa and Coral
Reef Mountains adjacent to the General Plan planning area is managed
by the l_I,S, Bureau of Land Management (BLM) (please see Exhibit III-
?). BLNT's land management responsibilities are authorized by several
federal land management policies, including the Federal Land Policy
and Management Act of 1976, which established general policies for the
management, protection, development, and enhancement of public lands
in the United States. Under the California Desert Protection Act of 1994,
certain lands in BL 's California Desert Conservation Area, including
the Santa Rosa Mountains, were designated as "wilderness" areas. This
designation assures the highest level of preservation and protection from
development and human disturbance and is directed at preserving the
primitive and undisturbed character of designated lands. The Santa Rosa
and San Jacinto Mountains National Monument Act of 2000 designated
more than 272,000 acres of land in the Santa Rosa and San Jacinto
Mountains as a national monument. This designation demonstrates the
value of the mountains, as recognized by Congress, and provides further
protection of these, unique lands for biological, cultural, recreational,
educational, and scientific purposes. The Monument provides extensive
habitat for more than 500 plant and animal species, including a number
of special -status species, such as the Peninsular bighorn sheep, desert
tortoise, Southern yellow bat, and Least Bell's vireo."
77
-
*
�vr
TN/City of La Quinta
General Plan Final EIR
Response to Comments cm DEIR
L.2. Comment: The city's Hillside Ordinance protects the mountains "above the toe -of -
slopes", page V1[1-5, which means the alluvial fans would be developed.
We suggest that this be considered as an impact to bighorn sheep and as
a cumulative impact throughout the Coachella Valley.
Response: The General Plan planning area contains two undeveloped alluvial fans:
one at Bear Creek and one adjacent to the Travertine site. As illustrated
.in Exhibit 111-2, the Recommended Alternative land use plan dcsiF,nates
the Bear Creek alluvial fan as Open Space, which precludes
opportunities for future urban development (as described on page 1-18).
The 'Travertine site occurs adjacent to, but outside of the Peninsular
Bighorn Sheep Critical IIabitat boundary, In addition, the Travertine
project is an approved Specific Plan.
1..3. Comment: On page III-101, third paragraph, the document states "Projects
receiving federal funding will be required to initiate consultation with
the t1St- WS to determine if the proposed activities will adversely modify
(bighorn sheep) Critical I labitat." It is our understanding that all projects
affecting critical habitat, regardless of the funding source, require
consultation with the U.S. Fish and Wildlife Service.
Response: According to the U.S. Fish and Wildlife Service (as described in Federal
Register, Vol. 66, No, 22, February 1, 2001, 50 CFR, Part 17), "critical
habitat receives protection under section 7 of the [Endangered Species]
Act through the prohibition against destruction or adverse modification
of critical habitat with regard to actions carried out. funded, or
authorized by a Federal agency. Section 7 also requires consultation on
Federal actions that are likely to result in the destruction or adverse
modification of critical habitat... Because consultation under section 7
of the Act does not apply to activities on private or other non -Federal
lands that do not involve a federal nexus, critical habitat designation
would not afford any additional protections under the Act against such
activities."
In light of the ahove-referenced statements, the last sentence of the third
paragraph on page 11I-10I is hereby amended as follows:
"All projects with a federal nexus, including actions carried out, funded,
or authorized by a Fedcral agency, shall be required to initiate
consultation with the IJSFWS to detcrminc if the proposed activities will
adversely modify Critical IIabitat."
L.4. Comment: In addition, we recommend the addition of bighorn sheep to page IV-3,
second paragraph.
79
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEII
Responses
L.5. Comments
Response:
The second paragraph on page IV-3 addresses unavoidable significant
impacts as they relate to traffic and circulation in the General Plan
planning area and does not refer to biological species or habitat
preservation.
We recommend a feral cat control program and dog leash requirements
within the Santa Rosa and San Jacinto Mountains Monument to
discourage pets from preying on wildlife at the wildland-urban interface
and other areas (page III- i 14).
The Santa Rosa and San Jacinto Mountains Monument are under the
jurisdiction of several public and quasi -public agencies, including the
Bureau of Land Management, U.S. Forest Service, and California
Department of Fish and Game. While the City supports the
implementation of the above -referenced animal control programs, it has
no purview to regulate activities on these lands. The City enforces a
leash law and operates an animal control program within its boundaries,
both of which will help control animals within the City limits,
80
IN/City of La Quinta
General Plan Final EIR
Responxc to Comments on DEIR
M. U.S. FISH AN1) WILDLIFE SERVICE AND CALIFORNIA DEPARTMENT OF
F1SIl AND GAME
NI.1. Comment: The U.S. Dish and Wildlife Service (Service) and the California
Department of Fish and Game (Department) have reviewed the subject
document, We provide these comments based on our respective
administration of the Endangered Species Act of 1973, as amended
(ESA) and the California Endangered Species Act (CESA). Take of
listed species is prohibited under section 9 of the USA and 2C80 of the
CESA but can be authorized under sections 7 (Federal consultation) and
10 (incidental take and recovery permits) of the ESA, and sections
2080.1, 2081 and 2835 of the CESA.
Response: Comment noted.
M.Z. Comment; The General flan area contains a unique assemblage of wildlife plants,
including many declining, endemic, and listed species. For desert floor
species dependant [sic] upon sandy habitats on the desert floor, the
Coachella Valley Fringe -toed Lizard Habitat Conservation Plan and
CVAG's multispecies (sic) planning effort are primarily focusing on
bioregional strategies that would conserve larger blocks of intact habitat
in other jurisdictions outside the City of La Quinta. These planning
efforts do not include habitat conservation objectives within the City
because remaining patches of sandy habitats are becoming too small and
isolated for species to survive over the long-term. As such, the plans
have and are identifying mechanisms for the City to participate by
offsetting the adverse effects of implementing its General Plan by
collecting fees to acquire offsite habitats in other areas that have higher
probabilities for species' long -tom survival.
Response: Comment noted.
M.3. Comment: We support the City's proposed adoption of policies that would require
surveys for projects that may adversely affect the various species
proposed for conservation coverage under CVAG's rnultispecies (sic)
planning effort. '1 hough most of these sensitive species are not currently
afforded State of Federal protection, most arc endemic to the Coachella
Valley and have declined significantly in their distribution and
abundance, primarily from habitat loss and degradation. For example,
the geographic extent of species dependant [sic] upon active sandy
habitats have declined historically by over 95 percent in recent decades.
The biological information compiled and analyzed by CVAG's
muitispecies (sic) planning program documents current threats and the
status of these species relative to their modeled historical distribution.
The rnultispecies (sic) program is treating these species as though they
81
TN/City of La Quinta
General Plan Final EIR
.Response to Comments on DEIR
were listed by the State or Federal governments and is, . therefore,
formulating conservation strategies based on the premise that they
warrant protection_ Therefore, we recommend that the City adopt a
policy to consider those plants and animals that occur within the City
and are proposed for conservation coverage under CVAU's multispecies
(sic) planning program to be endangered, rare, or threatened species,
pursuant to section 1538O(d) of the CFQA Guidelines. This would
provide the City a more effective mechanism to offset the most severe
biological effects of implementing its General Plan and also help
assemble a regional habitat reserve system in the Coachella Valley
before those opportunities are foreclosed elsewhere.
Response: Comment noted. Both the proposed General Plan and its EIR arc
responsive to the protection and conservation needs of sensitive plant
and animal species occurring within the planning area. It should be kept
in mind that the General Plan FIR is a programmatic document and, in
conjunction with the policies and programs set forth in the General Plan,
provides broader directives than project -specific regulatory documents.
M.4. Comment:
The City is a member of the Coachella Valley Association of
Governments (CVAG) and is signatory to the Memorandum of
Understanding (lvIOU) for the Coachella Valley Multiple Species
Habitat Conservation Plan (MIIP) The General Plan EIR directs the
City to continue to participate in the development of the MSHCP, Until
such time as the MSI1CP is completed and adopted, City staff shall
continue to review development proposals on a case -by -case basis to
assure that appropriate and effective mitigation measures are established,
in compliance with all applicable laws, to protect plant and animal
5pccies.
Other General Plan policies and programs, which direct City
conservation efforts, include Policy 2 and its programs (General Plan,
page 62), which address the need for focused species surveys, and Policy
4 and its programs (General Plan, page 62), which require that unique
andfor valuable biological resources be preserved as Open Space. The
EIR also directs the City to establish a system of multi -use corridors for
wildlife interconnection between open spaces, provide an effective
buffer between urban development and sensitive wildlife lands, and
preclude the use of non-native, invasive vegetation.
We generally concur with the intent of the draft goals, policies, and
programs to conserve biological resources in the draft Comprehensive
General Plan (pp. 62-63). However, in many cases, these biological
objectives likely will not be realized , given the stated language caveats
(e.g,, "to the greatest extent practical" and "shall consider requiring")
82
TN/City of La Quinta
Ciener►I Plan Final MR
RenownRunown to comments on DLIR
and several zoning contradictions. for example, despite the stated goals
expressed in Policy 4, Program 4.1, and Policy 5 (pages 62-63 of the
draft Comprehensive General Phin), the proposed zoning{land uses fail
to provide for conservation of unique and/or valuable biological
resources in several important areas, protection of the Peninsular
bighorn sheep, and buffering of sensitive habitats from urban
development (see discussion below for more details). The draft EIR
briefly discusses the effects of habitat loss of bighorn sheep but does not
analyze how the proposed mitigation measurer would ameliorate
significant impacts. 'I he offered mitigation measures (policies on open
space and hillside development) should be analyzed relative to
recommended conservation program in the Recovery Plan for Bighorn
Sheep in the Peninsular Ranges, California (USFWS 2000), 'The
disparity between implementation of the draft Comprehensive General
Plan and the conservation objectives in the Recovery Plan indicate that
conflicts with bighorn sheep would be significant and likely would
preclude achieven}ent of the recovery objectives for the ewe group in
question (see discussion below).
Response: Both the General Plan and draft E1R are responsive to the need to
preserve and protect bighorn sheep habitat. Among these are Mitigation
Item A (EIR, page 1II-114), which requires the City to designate all
areas above the toe of slope of the Santa Rosa and Coral Reef Mountains
as Open Space, and Mitigation /tern K (EIR, page T1I- l l 5), which is
consistent with the Recovery Plain's description of project -specific
fencing to help mitigate the adverse effects of adjoining land uses.
Critical Habitat boundaries, as established by the U.S. Fish and Wildlife
Service, are illustrated on Exhibit III-22. Projects with a fedora] nexus
shall he required to initiate consultation with the USFWS to determine if
the proposed activities will adversely modify Critical Habitat. In this
regard, no disparity between the General Plan and Recovery Plan is
anticipated,
M.5. Comment:
Water courses and alluvial fans in the planning area support Desert Dry
Wash Woodlands, which represent a rare plant community recognized
by the State. This plant community is comprised of several species that
are protected under the California Desert Native Plants Act Division 23
of the Food and Agricultural Code (Fish and Game Code Sec. 1925).
These desert woodland habitats support a greater diversity and
abundance of wildlife than other desert habitat types (England 1984). In
addition, these areas also provide criticat and essential habitat for the
endangered peninsular bighorn sheep.
The Department encourages the conservation of these watercourses and
apposes their elimination, channelization, or conversion to subsurface
83
TN/City o F La Quint'.
General than Final B.]R
Response to Comments on DLIR
drains. All uretlands and watercourses, whether intermittent or perennial,
must be retained with substantial setbacks that preserve riparian and
aquatic values and maintain their value to on -site and off -site wildlife
populations. The fluvial channels on alluvial fans are considered
regulated water courses.
Response: The General Plan is a long-range and broad -reaching policy document,
which is responsive to the need to protect sensitive habitat in the
planning area. The Recommended Alternative land use plan designates
602+ acres of floodways and drainage channels as Open
Space/Watercourse (W)_ Not only does this designation protect the
population and structures from flooding hazards, it also preserves and
enhances the value of riparian habitat in the planning area. General Plan
Policy 6 (page 87) requires major drainage facilities to provide for the
enhancement of wildlife habitat, to the greatest extent possible, while
still maintaining their functional qualities.
The planning area contains two undeveloped alluvial fans: 1) Dear
Creek, and 2) one adjacent to the Travertine site. As shown on Exhibit
1I1-2, the Recommended Alternative land use plan designates the upper
Bear Creek Channel system as Open Space/Watercourse and
surrounding land as Open Space. These designations preclude future
development within and adjacent to the channel, Similarly, the Dry
Wash Woodland community adjacent to the Travertine site is designated
as Open Space/Watercourse. The Travertine Specific Plan was reviewed
under an. Environmental lmpuut Eteport cedi1ied by the City Council,
and which included a requirement for a habitat conservation plan to be
submitted to CDFG prior to development. Future development projects
involving a streambed alteration or other impact to fluvial channels, are
required to obtain the necessary permits (i.e. 1603 or 404 permits) from
the appropriate regulatory agency,
I I.6. Comment: The Department has authority under fish and Game Code § 1600 et seq.,
regarding any proposed activity that would divert, obstruct, or affect the
natural flow nr change the bed, channel, or bank of any water course or
body of water. A discussion of potential impacts from any filling,
grading, increased runoff, sedimentation, soil erosion, and/or pollutants
on water bodies on or near project sites, with mitigation measures to
alleviate such impacts, must be provided to meet permit issuance
criteria. We, therefore, recommend that the City adopt a policy that
would complement this trust responsibility of the State.
Response: Comment noted. The following mitigation measure is hereby added to
page III-86 (hydrology) of the EIR:
54
M.7. Comment:
TN. City of lMa Quinta
General Plan Final Ells
Response to Comments on D)~IR
"En accordance with California Department of Fish and Game Code §
1600 et seq., any proposed development which may divert, obstruct, or
affect the natural flow or change the bed, channel, or bank of any water
course or body of water shall be required to obtain a permit and/or other
appropriate authorization from the California Department of Fish and
[lame prior to development. Other approvals may also he required from
the U.S. Army Corps of Engineers, Regional Water Quality Control
Board, and other regulatory agencies."
Page I11, 112-113. The section on "Potential Impacts to Mammals" does
not adequately address the cumulative effects of building -out the
proposed General Plan. The extent of urban development contemplated
in the Travertine specific plan and up to 4 units per acre (low density
residential zoning) in the adjoining section 5 would eliminate many
hundreds of acres of bighorn sheep habitat and introduce high levels of
human disturbance into remote and sensitive areas that currently support
a stable bighorn sheep populatiun. Zoning at up to 4 units per acre in
designated critical habitat conflicts with Biological Resources Policy 5
by not providing for a biologically appropriate transition of buffer
between urban land uses and mountainous/alluvial bighorn sheep
habitat. To address this conflict, we recommend that the City identify
strategies, such as more biologically appropriate zoning, and a habitat
acquisition program, for conserving these and other private lands in
bighorn sheep habitat that arc vulnerable to and zoned for future
development.
Response: Comment noted. The 'travertine Specific Plan is a City -approved
Specific Plan which was reviewed under a certified EIR. The EIR
includes a mitigation measure requiring the preparation of a habitat
conservation plan to be submitted to CDFG prior to development.
As shown in Exhibit III-1, approximately 75% of the Land in Section 5,
adjacent to the Travertine Specific Plan, is currently designated fur low -
density residential development (2-4 duiac) under the existing General
Plan, The Recommended Alternative land use plan, shown in Exhibit
III-2, provides for the continuation of this existing land use designation.
Through its development review process, the City shall continue to
evaluate proposed projects for their potential to adversely impact
sensitive biological species and habitat. The City supports the
acquisition of land in bighorn sheep habitat by public laud trusts and
other agencies capable of managing these lands effectively. Please also
see response to Comment .8, below.
85
MI/City of La Quint]
General Plan Final JIR
Response to Comments on DEIR
M.S. Comment: As described in the Recovery Plan, alluvial fans provide important
foraging habitat for bighorn sheep, and the numerous canyons draining
into the Travertine fan provide important perennial water sources along
their lower reaches, as well as lambing and rearing habitat. Increased
levels of human recreation, including the focused attraction of humans to
desert water sources and oases by the many thousands of new residents
supported by the planned urban developments (in the alluvial fan in
question and throughout the General Plan area at large), likely would be
sufficient to displace future bighorn sheep use of Guadalupe, Devil, and
Bear canyons, which are critical to maintaining a stable population in the
local ewe group. Please refer to the numerous citations in the Recovery
Plan that document the adverse behavioral reactions of sheep to human
disturbance. Given the inability to replace the functional loss of these
scarce, yet critical foraging, watering, lambing, and rearing habitats, the
proposed General Plan would reduce the size of the remaining home
range of this ewe group, and consequently reduce the capability of the
diminished home range to sustain future populations at current levels.
Such a population destabilization and associated decline would
constitute a significant adverse effect resulting from implementation of
the proposed General Plan.
Response: Comment noted. While gradual increases in human recreational activity
can be expected over the life of the General Plan, recreational access to
wildlands will not be uncontrolled. The public and quasi -public agencies
that manage the Santa Rosa and San Jacinto Mountains National
Monument, in which Guadalupe, Devil, and Bcar canyons arc located,
will continue to monitor and control trail access through designated
bighorn habitat, and the public will be permitted only un trails which are
open for use. The City will continue to participate and cooperate in the
BLM's trails planning effort currently underway, which involves the
trails component of the California Desert Conservation Area (CDCA)
Plan and addresses trails crossing through bighorn habitat.
14 .9, Comment: Similarly, the recreational and other potential land uses designated for
sections 13 and 24, immediately south of La Quinta Cove, have the
potential to disrupt bighorn habitat use patterns in surrounding areas. For
example, the mountainous peninsula bordering the Cove on the east
currently is used as lambing habitat, and its use could be discouraged or
eliminated if human uses in the area south of the Cove are not properly
managed. The draft EIR or subsequent document should more carefully
address and offset these significant adverse effects to bighorn sheep.
Response: As shown on Exhibit III-2, the Recommended Alternative applies only
the following land use designations to and in Sections 13 and 24,
immediately south of the Cove: Open Space (OS), Clpcn Space with a
86
1 'L10. Comment:
TN/City of La Quinta
General Plan Final EUR
Response to Comments on DEMR
Hillside Overlay. (OS1llillside), Watercourse (W), and Park (P). The
peninsula east of the Cove is primarily managed by the Bureau of Land
Management and is designated as Open Space with a Hillside Overlay.
As described on page 1-18 of' the draft EIR, permitted land uses on such
lands are extremely limited, and future urban development is precluded.
The Open Space designation applies to lands in public and quasi -public
ownership and allows for the discretionary approval of trails, trailhcads,
and related facilities. The hillside Overlay is applied to land above the
toe of slope, to which the provisions of the Hillside Protection
Ordinance apply. The -Watercourse designation applies to floodways and
drainage channels, and the Park designation applies to existing
municipal and regional park facilities.
Project -sped tie environmental analyses shall be required to identify and
mitigate potential impacts to bighorn sheep fo any future development
proposal.
Page 1I1- l 14, Mitigation Measures. To address our concerns described
above, General Plan policies should be adopted that more effectively (i)
conserve bighorn sheep habitat and establish strategies or
implementation mechanisms to accomplish this objective, such as
creation of n habitat acquisition fund, (2) require appropriate avoidance,
minimization, and mitigation measures for proposed habitat losses, and
(3) require completion of a trails management plan prior to the
construction of any further projects in bighorn sheep habitat. The trails
plan should be subject to the review and approval by the Service and
Department and be coordinated with the trails management program in
preparation under CVAG's multispeeies (sic) planning effort. The plan
should include a comprehensive system of appropriate signs, trailheads,
management and anfbrccmcnt capabilities, and other facilities to manage
access along the habitat/urban interlace to afford effective control of
buman uses in adjoining bighorn sheep habitat.
Response: (1) All future development shall be required to establish project -specific
strategies 'that mitigate potential impacts to bighorn, wherever necessary.
The continued implementation of the City's Hillside Conservation
Ordinance and the application of the Open Spacelllillside Overlay land
use designation to sensitive hillside areas and designated bighorn habitat
will further reduce impacts to the species.
(2) Given that the proposed Plan designates sensitive hillside areas as
Open Space, a designation which precludes urban development,
implementation of the General Plan is nut expected to result in any
direct habitat losses for the bighorn. Nonetheless, the City will continue
to participate in the development of the Coachella valley Multiple
>i�
M.11. Comment:
TNT' of La Quinta
General Plan Finai EIR
Response to Comments on DER
Species Habitat Conservation Plan (MSHCP), which will establish
procedures for avoidance, minimization, and mitigation measures for all
species covered by the plan, and will continue to implement the
mitigation measures included in certified EIRs for previously approved
and future projects.
(3) The General Plan is a broad -reaching policy document, and it is
beyond the scope of the General Plan to include a formal trails
management plan. However, the City is currently participating in the
Bureau of Land Management's trails component of the California Desert
Conservation Area Plan, and will continue to participate and consider its
adoption when completed. The plan is being coordinated in conjunction
with the MSHCP, in which the UFWS and CDFG arc already involved.
Page 1II-115, Item H. The recommended burrowing cowl surveys should
be expanded to include other habitats in addition to agriculture, given
the species' widespread occurrence throughout a variety of habitat types
in the Coachella Valley.
Response: Comment noted. The burrowing owl is known to occur in agricultural
areas, which was the basis for the mitigation measure. The owl is also
known to occupy burrows of Palm Springs ('round Squirrel, and the
banks of washes or streams. The mitigation measure is therefore
amended to read:
M.12. Comment:
"Agricultural lands, stream banks and areas napped as potential habitat
for Palm Springs ground squirrel which are being converted to
development shall be surveyed for the presence of burrowing owls,
according to California Department of Fish and (.same protocol."
, Item K. We recommend that the City modify the mitigation
measure and policy to require, not just "consider", a contingency -based
measure, as described in the Recovery Plan. Accordingly, for new
projects that create a potential attraction to sheep for urban sources of
food or water, the City should adopt a policy that would require project -
specific conditions of approval for future fence construction should
sheep become attracted to urban areas_ To be workable, this contingency
mechanism should provide the wherewithal to require future
construction of a fence if sheep problems arise. Providing the
wherewithal would necessitate (1) dedication of a fencing easement, (2)
provision of a funding mechanism, and (3) establishment of a
responsible party, at the time of project approval,
Response: Comment noted. The terminology used in Mitigation Measure K is
consistent with the language used in the Recovery Plan, which states that
88
TNJCity of La Quinta
General Plan Final FT. R
Response to Comments on DEIR
"fencing should be mandatory" (Recovery Plan, page 21 S), but does not
require that it be installed. Nonetheless, Mitigation Measure Item K is
hereby amended, as follows, to clarify the need for fencing adjacent to
sensitive hillside areas.
"To reduce the impacts of urbanization on bighorn sheep, the City shall
consider requiring barriers between future development projects and the
adjacent hillside if bighorn sheep are demonstrated to occur on the
subject property or adjacent hillside. Informal consultation and/or review
by the U.S. Fish and Wildlife Service and California Department of Fish
and Lame shall be completed prior to construction of any barrier, so as
to assure appropriate, safe, and effective barrier design."
Individual development projects shall be conditioned, as necessary,
during the City's project review process. The City has in the past
considered conditions of approval and/or mitigation measures which
established funding mechanisms, responsible parties fo.r ongoing
maintenance, etc, at the time a project was approved, and will continue
to do se as appropriate.
N. LEE ANDER ON, Jot,
TN/City of Lit Quinta
General Han Final EIH
Response to Conirnmts on DEIH.
N.1. Comment: (1) The report states that the agricultural overlay "provides for
continuation of existing agricultural activity at the discretion of the
landowner until he chooses to change its use". This is not good enough.
Let agriculture be a permissive (sic) use in any area, or at least in areas
that have The La Quinta designation of very low density and low density
uses, Agriculture cannot be protected by an agricultural overlay, It needs
its own designation. An agriculture zone should be basic and agriculture
should be a permitted use in any area, Landowners and the city need the
flexibility to use land for agriculture should an economic downturn slow
building development.
Response: The commentor's opinion is noted. In order to impletnent the
Agricultural Overlay, the City will be required to adapt Zoning
Ordinance guidelines and standards. These will be adopted subsequent
to Genes& Plan adoption, and will include land uses currently allowed
under Riverside County zoning ordinance, as discussed in public
meetings field by the City Council and Planning Commission.
N.2. Comment: (2) Under mitigation measures there needs to be added protection for
land that is already in agriculture. La Quinta should enact "Right to
Farm" legislation similar to that in effect in the Riverside County area.
Response: Comment noted_ The following mitigation measure shall be added to
Section
IL Prior to the Conducting Authority Hearing before the Local
Agency Formation Commission which includes any parcel of land
currently in agriculture, the City shall adopt an ordinance whose
intent and content is equivalent to Riverside County ordinance
625.1, including a notification requirement of 300 feet,
N.3. Comment: The study states that it estimates that approximately 40°% of domestic
water consumed would he reabsorbed into the ground water table, This
is not true in the middle valley area due to numerous clay layers that
prevent percolation. This is wlhy much of the farming area contains tile
lines,
Response: The percentage has been provided by the Coachella Valley Water
District, and represents an average for its management area, Although
some areas of the City and its plaruung area include clay, others do not,
and provide a high percolation rate,
90
TNlCity of La Quinta
General Plan Final EIR
Rosponse to Comments on DEM
0. KAY WOLFF
0.1. Comment: 1. The General Plan does not spell out any general locations, acreage, or
percent of acreage for parks, trails or other public use lands. These uses
arc lumped together with golf courses, which are a) mostly private, b)
costly for citizens to use, and c) severely impact our water supply, due to
the residences that typically surround them. In order to insure the quality
of life of our residents, we need to specifically assure that facilities for
youth and adults are abundant and conveniently located_ Where are the
formulas (minimum expectancies) for parks and open space? Open space
needs to be more than mountains and golf courses. We are below our
guidelines for public parks within our current boundaries: let's fix that
first.
Response: The General Plan establishes, by policy, a standard of 3.0 acres per
1.000 residents (Policy 2, Parks and Recreation Element), Exhibit 5.1 of
the General Plan identifies the existing and proposed parks within the
City and its planning area. The General Plan establishes locations for
trails in Exhibit 3.10 of the Circulation Flement. The Master
Environmental Assessment of the General Plan includes quantified
discussion of existing and proposed park lands and dcficicncies within
the City and its planning area. Filially, Programs 2.1 through 2,5 of the
Parks and Recreation Element provide the City with a number of options
for funding park acquisition and improvement.
O.Z. Comment! The verbs used in the General Plan are too loose: "encourage, try to,
evaluate, consider, pursue, etc." How about setting some specific goals'?
How about some "wills and shall"? We can afford to be selective and
make demands on developers.
Response: Comment noted, The General Plan provides both directive and
suggestive policy, based on the policy direction provided_ The City
Council continues to consider text changes throughout the public
meeting and public hearing process. The comrnentor is also encouraged
to articulate proposed changes to General Plan language in public
hearings to be held before the Planning Commission and City Council.
0.3- Comment. In order to avoid the negative impacts of water, traffic, noise, pollution,
and loss of cultural heritage as pointed out in the DEIR, I believe
residential developments should be exclusively "very low density
residential" and interspersed with open space and public parks and trails.
If developers of high, medium, and low density developments don't like
our zoning, let them take their development elsewhere. We can afford to
91
TN/City of La. QuinLi
General Plan Final EIR
Response to Comments on DEIR
be picky. Why become a high density community when
positioned to be the most desirable city the Coachella Valley?
Response: The commentor's opinions are noted.
we ore
0.4. Comment: The DEIR clearly points out the many negative impacts of' the potential
annexation of Annexation No. 12 and the Sphere of Influence. 'These
very negative impacts need to be clearly publicized to the community
before the passage of any plans. For example:
a) The possibility of being a city of some 208,000 is horrifying! Who
moved to La Quinta to be in a big city? Let's take good care of what
we've got, and not plunge into the managerial and safety morass ofa
metropolis! Do we want to be considerably larger than San
Bernardino?
Response: The commentor's opinions are noted. The City Council and Planning
Commission have directed that the planning area boundary he reduced.
0-5. Comment: The annexed areas would be a tremendous financial drain on the current
city, with an annual negative cash flow of almost $7 million (DEIR
Tables 111-46 and 47). Since LAFCa has stated that La Quinta
annexation will not be "pikernea1", that implies that we will have safety
obligations prior to the development of most properties. We will have
financial responsibilities without significant revenue to offset these
costs. With assessments already afoot for police and fire protection
inside our current boundaries, what would that mean for the future?
Most citizens are against assessments for such services, especially when
they may not favor annexation in the first place.
Response: The cornmentor`s opinions are noted. The cost/revenue analysis
represents a buildout analysis based on the land uses proposed within the
Annexation and Sphere of Influence areas described in the EIR. Since
both are primarily residential in nature, and residential devcloprnent
does not generate sufficient revenue to maintain services in most cities,
both the Annexation area and the Sphere of influence represent an
annual lass at buildout. When these two areas are considered as part of
the overall development and buildout of the City, however, a positive
cash flow is expected (see table III-46 of DEIR).
0.6. Comment: The DEIR mitigation measures to resolve water issues are inadequate.
Any residential development will surely jeopardize the fast -receding
aquifer in this Valley. Any governing agency will be faced with its
depletion and must proceed with extreme caution.
92
7NfCity of La Quints
Generat Ilan Final EIR
Response to Comments on DEIR
Response: Mitigation treasures associated with water in the DEIR represent the
City's continued effort to support and assist the Coachella Valley Water
District in protection of the water resource, The District, however, has
control of this resource, and not the City. The City has implemented
ordinances which reduce water usage, and the General plan continues to
support these reductions, and provide the City with policy supporting
conservation efforts both at the local and regional level. The impacts
associated with individual projects which occur after adoption of the
General Plan will he addressed at the time each project is reviewed by
the City.
0.7. Comment: The impact of two airports has not been sufficiently addressed in the
DEIR: noise traffic, safety, and economic impact. No noise study was
conducted on projected expansion runways and larger aircraft. If the
Regional Airport is going to be developed, and owned by La Quints,
what are the costs to develop new runways, terminals, etc.? Even if not
owncdimanaged by La Quinta, the problems of safety and additional
noise will impact those who live in the area. Are these the problems. we
need within the boundaries of La Quinta?
Response: The cornmentor is incorrect. The noise studies prepared for both airports
is referenced in the DEIR, including noise contour maps provided in
each airport master plan. Further, the noise study for the General Plan
monitored noise levels at both airports (monitoring sites 1, 10 and 11,
please see discussion on page III-44 ff. Of the DEIR). `fherc is no plan
for La Quinta to purchase the airport, nor is one considered in either the
General Plan or DEIR. Development is regulated by federal standards
adjacent to airports, and both the existing County of Riverside land use
assignments and those proposed in the General Plan for those portions of
the planning area affected by airports reflect the potential impacts
associated with airport development. Noise and safety issues are also
addressed extensively in both airport master plans.
O.$. Comment: The cultural element of the DEIR seems only to address the 372 Native
American archaeological sites, but does not mention our recent cultural
history of agriculture, equestrian and art. Whcrc is the preservation of
date and citrus groves'? Of equestrian trails and ranches? Where is the
support for the arts? The City has lct a prune location for a citrus
orchard/date grovcipark to slip by (Eisenhower and Tampico): what a
lovely reminder of our past that would have been! The City should have
purchased this, and should purchase the wash along MantezurnaiBike
Path and preserve it for the future. Equestrian trail with parks would be
charming, and a wonderful place for families to experience our cultural
past (just ask Frank Bogert about horseback riding in La Quinta). As for
the Native American sites, where are the trails and parks for people to
9
TN/City of La Quinta
CeneraI Plan Final ER
Response to Comments on DEER
enjoy the petroglyphs, fish traps, and sites where they lived? Instead of
sealing them up, let's work with the local tribes to develop awareness of
their culture, These need to be accessible on site, not just in the
I Cisterical Museum.
Response: The commentcrr's suggestions are noted. The Master Environmental
Assessment of the General Plan includes discussion of the City's
agricultural and ranching heritage, and methods available to preserve
both. The Cultural Resources Element of the General Plan includes
policies and programs to protect and encourage preservation of all
aspects of the City's cultural heritage. The City did not own the land
mentioned by the commentor at the corner of Eisenhower and "Tampico.
The owner of the property made proper application to the City for
development of the site. Public hearings were held on the matter by both
the Planning Commission and the City Council.
The La Quint,' Evacuation Channel is owned by the Coachella Valley
Water District. The City encourages the use of the banks of flood control
facilities for trails, and works closely with the District in the
development of these trails as development occurs adjacent to them.
The current professional practice, due primarily to desecration and theft
of Native American claim -al sites is to either excavate and remove. or
bury resources. The City maintains the exact location of sites
confidential in order to ensure that they are not vandalized, as is the
practice.
0.9, Comment: I believe that the mitigation factors outlined in the DEIR do not resolve
the numerous negative impacts to the degree that we should expect for
our City, We should defer approval of this plan and reject the DEIR until
we can find a balance among size, environmental impact, and amenities
due to our current residents. We cannot be enticed into thinking that
bigger is better, because it usually isn't.
Response: Comment noted,
94
'TN/City ofLa Quinta
General Plan Final E[R
Response to Comments on DE:1R
P. JESSE M.11IUKEEV'ER
P.1. Comment: Upon reading the environmental report on page M-7 tinder Water
Resources, irrii t n water from homes does not acolate to the aquifer.
This statement is untrue as our Thermal area is a non homogeneous
strata, it is made up of many hundreds of feet of very fine sandy clay
barrier, that makes that statement impossible. If that statement was a true
fact then it would be easy to find a location for artificial recharge in our
area. In some areas of proposed annexation, surface water is very high,
as proof the barrier is very efficient.
Response: The statement made on page lvf-7 is:
"1t is estimated that about 40% of domestic water consumed, including a
percentage of irrigation water applied to landscaping, is re -absorbed into
the groundwater table and is not lost."
[ he e❑rnmentor's assumption that the planning area is underlain by a
single clay layer of "many hundreds of feet" is incorrect, The soils
under the City and planning area vary greatly, and resemble a patchwork
of different types of soil, including clay. The statement made in the EIR
stales correctly that a percentage of water used in landscaping percolates
into the groundwater table. In some areas, that percolation is more rapid
than in others, based on the soil layers.
The aquitard -vrhich results in a high water table in some areas of the
planning area was originally a pocket of groundwater isolated by clay
layers which underlie these areas. The high water table has been
exacerbated by agricultural irrigation, which causes higher quantities of
water to be trapped close to the ground. The water found in the aquitard
will eventually percolate to the aquifer, over a long period of time.
The Coachella Valley Water District has identified a recharge location at
Martinez Canyon.
P.2. Coinment: Certainly, the author of the report is misinformed and does not
understand even the basic principle of water recharge_ 1 cannot believe
that the City paid for such a report. How many other errors does it
contain?
Response: As cited throughout the document, all data included in the Draft EIR
regarding water resources was obtained fnirn the C'oacbella Valley
Water District.
95
7N1City of La Quinta
Gcnaral Plan Final EIR
Response to Comments on DEIR
P3. Comment: We live in a DESERT and presently, we have had less rain or snow to
naturally recharge our aquifer recovery, and at present we are lowering
our water table yearly by alarming amounts, and in the City of La Quinta
it is dropping drastically, and the City is not developing fully, how will it
be when fully developed?
Response: The overdraft condition in the Lower Malley is estimated by CVWD to
be 41,700 acre feet annually under current conditions. The District
further estimates that by 2035, the Lower Valley overdraft condition will
be 76,300 acre feet annually, without mitigation. (Source: Coachella
Valley Water District "Water Management Plan," draft November
2000). The "Water Management Plan" includes comprehensive
mitigation contained in several alternatives to alleviate the overdraft,
Once implemented, these mitigation measures are expected by CVWD
to eliminate the overdraft condition.
14. Comment: It is alarming to me to see the waste of good pristine ground water to
irrigate illogical strips of grass along manicured avenues, and are
especially designed at 45 angle or less so it runs off into the gutter, and
as a solvent to destroy the streets.
The City just approved this type of landscaping at Ave 56/Monroe and
Ave 58/Madison. This is a crime and should not be permitted just
because it looks good to the occasional walker, bicyclist and passerby at
55 MPH.
Response: The cammentor's opinion is noted.
P.5. Comment: Please do not annex my property as I DO NOT want to be associated
with this kind of waste. How could learned men design, build and
develop and approve such wasteful things.
Response: The cornmentor's opinion is noted.
P.G. Comment: Our water is ancient, it's being remoed faster than it's capable of being
recharged by man or nature. Seems to me if anything is approved we
will continue groundwater mining at a higher rate than the present, as
according to the proposed map most of this is developed farm land,
using canal water for irrigation_ and the water level continues to drop,
what will happen when four houses per acre is approved?
We will be continuing groundwater reining instead of groundwater
pumping, I know these (sic) From personal experience as a local Water
Wc11 and Puinp Contractor,
`t'N.Cily ()ILA Quinta
General Plan final EIR
Response to Comments on DEIR
Response: Comment noted. The water usage at buildout and the impacts of that
usage are included in section Iil.l~.3. of the EIR.
P.7. Comment: Also what concerns me is new developments i.e. houses and golf courses
install "dry wells" designed to carry run-off of flood water, or
irresponsible irrigated Iandscape, the Iatter is what the dry wells receives
(sic) most and with the waste water goes oil, fertilizer, antifreeze, rotten
grass cuttings from the neighborhood streets.
Response:
P.8. Comment:
Response:
I was appalled when asked to clean out somc of these "dry wells" as it
was polluted and would not absorb anymore run-off. When a water well
is drilled it is required to have the top 200' cemented off to prevent
pollutants from entering the aquifer and the City requires that on
developments to directly introduce the pollutants into the ground, not a
good idea,
Cunnrnent noted. The City does not encourage the use of dry wells for
drainage purposes. The City also implements the standards of the
National Pollution Discharge Elimination System (NPDES) for all
projects, which mandates, among other standards, that drainage be
cleaned on -site prior to discharge,
Please use common sense and take a good look at what lies beneath us
and is very little understood by the majority of the people including the
ones who make major decisions. KEEP THE CITY TILE SIZE IT IS
UidTTLL ALL IS UNDERSTOOD.
The commentor's opinions arc noted.
97
Q.
RICIIARD M. FOXX
TN/City of La Quinia
General Plan Final LIR
Response to Comments on DEIR
Q.1. Comment: I am writing in opposition to the acceptance of the Draft Environmental
Impact Report (SCE NO,, 2000091023).
Response: Comment noted.
Q.2. Comment: This report points up the massive impact on the area in question. The
residents of the City of La Quinta deserve to be fully informed about the
wholesale desecration of this unique area. Such information should he
disseminated by a series of well -publicized public information sessions
with presentation by the appropriate agencies as well as by the planning
and research people. 'this is done in other cities all over California with
far less to lose.
Until and unless this is done, expediting the acceptance of this report
through council constitutes nothing Tess than the most blatant
manifestation of behind -closed -doors government,
Response: Fully advertised public meetings have been held on the General Plan
since October of 1999. The City Council included General Plan
discussion on its agenda on a monthly basis from November of 1999
through December of 2000. The release of the Draft General Plan,
Muster Environmental Assessment and Draft Environmental Impact
Report on July 13, 2001, was advertised and posted, as required, The
Planning Commiswi❑n and City Council liave held joint hearings on the
Draft (.icneral Plan in September, November and December of 2001.
Public hearings will also be held for the final review of the document by
both the Planning Commission and City Council.
TN!City o!'t a Quinta
General Plan Final E7R
Response to Comments on DE1R
R. COACHELLA VALLEY ARCHAEOI.OU IC &L SOCIETY
R.1. Comment: After a review n the above Comprehensive General Plan document, the
Coachella Valley Archaeological Society is in agreement with the
findings, mitigations and recommendations as presented in the Cultural
Resources Element of the Draft Environmental Impact Report,
Response: Comment noted.
R.2. Comment: It was noticed in the Management Summary portion of the Paleontologic
Resources Mitigation Plan the informally designated :Take Cahuilla
beds: arc shown to contain fossils of Pleistocene through early Holocene
age throughout their extent. Yet, based on archaeological dating, many
of the shoreline campsites found in the La Quinta arca were occupied up
until about 300 years ago. This should make the lake bed sediments
present in those areas very late Holocene in age, not Pleistocene through
early 1 toloccne.
Response: The commenter mis-read the sentence_ The statement in the Mitigation
Plan reads:
"The results of this review demonstrate hat two (2) lithologic units that
may be affected by development within the boundaries of the La Quinta
General Plan study area have high potential to contain significant
nonrenewable Paleontologic resources: Pleistocene older alluvium and
the informally designated "Lake Cahuilla beds," (emphasis added)
The statement refers to two types of resources: those found in older
alluvium, primarily associated with alluvial fans in the planning area,
and those associated with ancient Lake Cahuilla.
99
'11%1/City of La Quinta
Gmere Plan Final EIR
Response to Comments on HEIR
S. ELLEN LLOYD TROVER
R.1. Comment: I believe it is premature to issue an LIR on "Annexation No. 12" & SOI
when neither the Agricultural Overlay nor the Equestrian Overlay is
drafted. Further comments forthcoming.
Response: Comment noted. Both overlay texts have been presented to the City
Council, Planning Commission and public at public meetings held in
September, November and December cf 2001.
100
T. VIC BRODER
TN/City of La Qu inta
General Flan Final EIR
Res case to Comments on UEIR
T.I. Comment: It would be wise to expand upon each issue on a website. This makes it
possible for those involved in excess travel during August and
September.
Response. The comn]entor's opinions arc noted,
101
TN/City of La Quinta
Cieneral Plan Final EIR
Response to Comments on DEIR
U. COLEY LJNFOOT & KATHY LFNFOOT
U.1. Comment: Finish one project before you begin another. There are a lot of
uncompleted projects I see as I drive thru (sic) La Quints. We hear for
the Valley & its overpopulation. We've witnessed the rising humidity in
the 20 yrs. We've been in the area. "Sprinkling" is a contributor, no
doubt. All of the new residents want to live on a Fairway.
You truly have "paved paradise and put in a parking lot."
Response: The eornmcntor's opinions are noted.
102
rN city of La Quinta
General Plan Final ElR
response to Comments on DEIR
V. SUN COUNTRY RANCH, NiORMAN AN1) GAYLE CADY
(Emphasis throughout added by comrnentor)
Y.I. Comment: Page I1I-2.8 Section 3-0-EIR: ALL AGRICULTURAL and urban
ACTIVITIES SHALL CONFORM TO THE NOISE STANDARDS
described in Section 9.100.210 of the City Municipal Code and other
mitigation measures set forth in Section III-J (Noise) of this EIR.
Paige I1.1-144, J-Existing Conditions: Evaluation of noise levels within
a community is important to protecting the health and welfare of the
general public, and can help define the need for remedial measures for
existing noise problems and these associated with future development.
Page 111-144, J-Noise Rating System: A number of noise rating scales
arc used in California to evaluate land use compatibility, The equivalent
sound, or i.cq scale, represents average constant noise level over a given
period titnc, and is the basis far the Lein and CNEL scales. LAdn value
represents a summation of hourly Lccl's over a period of 24 hours, Eind
includes a weighting factor or penalty for noise occurring in the
nighttime period of 10:II0 p.m. and 7:00 a.m. The Community Noise
Equivalent Level (CND.) represents a 24-hour average noise level
which includes a 5 dBA penalty for noise occurring during evening
time period (from 7 p.m. to 10_p.m.) and a LUL1BA penalty for noise
occurring during nighttime period (front 10 p.m. to 7 a.m.)
Appendix E-FIR Noise Element Update Technical Report-pg 3:
NOISE, as it has been simply defined is "UNWANTED SOUND." 1t is
an undesirable by-product of transportation systems and industrial
activities within a community that permeate man's environment and
cause disturbance. The full effect of such noise on individuals and the
community will vary with its duration, its intensity, AND THE
TOLERANCE LEVEL OF THE EXPOSED INDIVIDUALS.
Mr. Baker, it is quite apparent La Quinta is making diminutive effort to
accommodate and encourage the current rural, agricultural_ and
equestrian lifestyle and daily routine of Vista Santa Rosa residents.
Expecting this community to arbitrarily accept your token inadequacy
(sic) offering of an "Agricultural Overlay" versus qualified perpetuity
agricultural and equestrian zoning ordinances is absurd. Demanding all
undeveloped open space property immediately conform to "four houses
per acre" zoning designation upon annexation is ludicrous.
Response: Comment noted. 'The General Plan and EIR specifically state that
equestrian and agricultural activities can continue to occur until the
101
TNIC;ity of La Quiata
General Flan Final EZR
Response to Comments on DEIR
landowner chooses to .0 cnvcrt his or her property. The noise generated
on existing equestrian and agricultural land will not result in any
penalties to the use, The language quoted by the comrnentnr relates
specifically to how CNEL noise are calculated, not to specific sites.
The cominentnr is incorrect in assuming that agricultural and equestrian
zoning will not be implemented. Such text has been introduced at
hearings of the Planning Commission and City Council held in
September, November and December. This language includes right to
farm provisions for existing agricultural and equestrian lands.
Furthermore, as a conforming use, agricultural and equestrian land use
can continue to operate as it has in the past. In addition, the City's
Transfer of Development Rights provisions (Section 9.190) shall be
considered for inclusion in the Agricultural Overlay district, thereby
providing an incentive for the long-term preservation of agricultural
parcels in the planning area.
V.2. Comment: Appendix G-Seismic, Geologic and Flooding Hazards ECIt-Pg 1-2, I-
5, I-28. I-29:
"Liquefaction/Ground Failure: Portions of the La Quinta- general plan
are susceptible to liquefaction and landsliding or rockfall, both very
destructive secondary effects of strong seismic shaking. Liquefaction
occurs primarily in saturated, loose, fine to medium -grained soils in
areas where the ground water table is 50 feet or less below the ground
surface.
Liquefaction does not occur at random, but is restricted to certain
geologic and hydrologic environments, primarily recently deposited
sands and silts, in areas with high groundwater levels. Currently, shallow
ground water, within 50 feet of the ground surface, is present ONLY in
the eastern portion of the general plan area, Therefore, at present this is
the only area susceptible to liquefaction.
Four general approaches apply to mitigation of liquefaction hazards: 1)
AVOIDANCE 2) Prevention 3) Engineered Design, 4) Post -Earthquake
Repairs. A prime way to limit the damage due to liquefaction is to
AVOID AREAS SUSCEPTIBLE TO LIQUEFACTION.
Appendix G-Ground Subsidence PE 2-7, 2-9, 2-10; Ground
subsidence is gradual settling or sinking of the ground surface with little
or no horizontal movement. This phenomenon is usually associated with
the EXTRACTION OF oil, gas or GROUNDWATER from below the
ground surface with a resultant Loss in volume. Ground fissures were
observed in the City of La Quinta in 1948. Regional subsidence related
tn4
TN. City of La Quints
General Plan Final EIR
Response to Corrmmcnts on DLitt
to GROUNDWATER WITHDRAWAL is believed to have occurred in
the Coachella Valley,
The GROUNDWATER BASIN IN TIW COACHELLA VALLEY IS
CURRENTLY TN A STATE OF OVERDRAFT.
GROUNDWATER LEVELS IN 'FHE LA QU1NTA AREA ARE
DECLINING AT AN .INCREASING RATE AS A RESULT 0
VALLEY WIDE MINING FOR GROUNDWATER.
GROUNDWATER LEVELS IN 1996 WERE IN MANY AREAS
LOWER THAN THE HISTORICAL LOW GROUNDWATER
LEVELS.
These observed declines in water level have the potential to induce
new or renewed land subsidence in the area affecting the City of La
Quinta.
The timing of subsidence measurements corresponds with water Level
declines. Land subsidence is probably occurring and a significant part of
the measured subsidence likely has occurred since 199 l , about the time
when water levels began declining below their previously recorded low
levels. Land subsidence can result in the disruption of surface drainage,
rcduetion of aquifer system storage, formation of earth fissures, and
damage to wens, building, roads and utility infrastructure. Mitigation ❑f
subsidence requires a regional approach to groundwater conservation
and recharge. Mitigation measures ate expected to be difficult to
implement, _ ..
Response: Comment noted. Please see responses P,1 and P.3., above.
105
V. MATTI-IEWP. WIEDLIN
TN/City of La Quinta
General Plan Final EIR
Respc nss; to Comments an DEIR
W,l . Comment: La Quinta's Draft Environmental Impact Report projects that build out
of the preferred alternative will increase the groundwater overdraft.
Response: Comment noted. The EIR states that buildout of the Plan will increase
groundwater overdraft without mitigation. The EIR goes on to include a
number of mitigation measures to lower the impact, including continued
cooperation with the Coachella Valley Water District in implementing
water conservation measures.
106
Res
TN/City of La Quirlta
Genera] Plan Final EIR
wise to Comments on DEIit
X. B. MANGAN SMITH
(Emphasis throughout added by comrnentor)
X.1. Comment: I am against the EIR Report — it is erroneous in many ways — and vague
in others. Where are equestrian rights mentioned'? "Trails that have been
here for over 56 years — are dismissed with a wave of the hand, Your
agricultural overlay plan is not fully defined.
Response: Comment rioted. Agricultural land uses, including horse ranches, and the
impacts of the Plan on these land uses, are discussed in Section III-13 of
the EIR. Trails included in the Plarx include all currently designated
County and City trails, and the addition of multi -purpose trails in the
planning area, The Plan does not propose to delete any currently
designated trails, but instead connects new proposed trails to the existing
trails system, particularly in the Coral Reef and Santa Rosa Mountains.
The agricultural overlay is defined in the General Plan document, under
the Land Use Element, 'Fable 2.1_ Policy estabiishing the overlay are
included in the Plan. As a policy document, the General Plan is limited
in its ability to implement these policies. The specific implementation
measures will be adopted after adoption of the Cieneral Plan, through
additions to the City's Development Code and Municipal Code. The
hearings held by the City Council and Planning Commission in
September, November arid December introduced the text of the
Development Code additions, The public hearings to be held by the
Planning Commission and City Council for adoption of the Plan will
continue this discussion, larding to adoption of new zoning text.
X.2. Comment: Spraying, burning, fertilizing, harvesting, and yes- even the need to
create dust on occasion is needed by the farmer in order to survive — and
produce food for you,
Response: The agricultural overlay does not preclude the activities mentioned by
the commentor. The overlay specifically states that existing agricultural
land uses can continue in perpetuity, unless the landowner wishes to
develop his or her land. Dust (PM1O) created by agricultural activities is
exempt from SCAQMD standards for dust control, and therefore will not
be impacted by the implementation of the Plan.
X.3. Comment: Roadways that are not 4 lane or 8 lane expressways are needed in
rural/agricultural/equestrian areas — to move equipment from one
farm/ranch to another safely.
Response: Comment noted.
107
TN/City of La Quinta
General Plan Final Ells
Response to Comments on ❑EIR
X.4, Comment: The right to create noise — 2.4 hours a day is necessary for the farmer.
Many crops in order to protect freshness, are harvested all night long.
In our harsh climate — tractors preparing fields will operate at night —
easier on machinery and man.
The same is true of horse workouts — particularly in the summer — early
AM or late evening workouts.
Thcsc items can not be regulated on paper by people who sit in air
conditioned offices with no experience of life in the fields or from the
top of a horse.
Response: Comment noted. The EIR does not preclude the harvesting of crops or
any other nighttime activity due to noise levels, It is not clear that farm
equipment operating during the night would result in an unacceptable
CNEL noise level, since CNEL is a 24 hour average noise measurement.
Should that occur, however, the proposed right to farm provisions of the
new zoning standards which will be required upon annexation of any of
the lands to the east of the City will preclude nuisance complaints.
The noise standards discussed in the EIR apply only to new development
as it occurs, and will not affect existing agricultural activities,
X.5. Comment: It is also inconceivable to many of us aware of the value of the different
horse properties in southern California — that money conceous (sic) La
Quinta has over looked — the potential for a million dollars per acre
future growth.
if you people had done your "homework" properly and used goad
common sense — you would have recognized that fact and create the true
gem of the desert — keeping and developing the wonderful enchanted
village of La Quinta. With it's (sic) special artifacts and also recognizing
Vista Santa Rosa with it's (sic) special needs and requirements, -- 1
draw that would be unbeatable in the future. Man needs space — it will
become a rarity as time goes on. It's (sic) peacefulness (and the
spirituality of this valley) soothe men's souls, Why do vou give it away
so cheaply, cg. — the Embassy Suites — La Quinta deserved better than
that. I only hope it's better looking that it's (sic) art work!
Response: Comment noted. As previously stated, existing land uses of any kind in
the planning arca are allowed to continue until such time as the owner
decides to develop his or her property.
103
TN /City of La Quinta
General Plan final EIR
Response to Comments on DETR
X.6. Comments I am against the plan for if s (sic) one year rule — regarding the use of
land. A farmer should have the right to keep land fallow -- should he
choose to let it rest — without losing the right to farm..And when do you
give the farmer the right to purchase horse acreage and farm it, if he
chooses? Or where is the right for the farmer to sell land for equestrian
use if he wishes to do so? And without time limitations.
Response:
X.7. Comment.
Response:
The commenter is incorrect. The "ont year rule" would apply to a use
which is legally non -conforming. The Plan proposes to make
agricultural and equestrian land uses legally conforming. Nu time
limitations would therefore apply, nor would the Plan preclude the sale
of land or its lying fallow.
You choke us with your restrictions and control of our property rights
it is not Vista Santa Rosa that would take away property rights — it is the
great stumbling giant of La Quinta who rules with an iron fist as to land
use. The same City that creates high walls needing a ;{i% grade of water
wasting grass that is so steep the sprinklers du not water the grass — they
drain into the gutters and roll down the streets.
The cornmentor is incorrect. The proposed Plan includes no restrictions
on property rights. Further, the zoning tcxl presented to the City Council
and Planning Commission during hearings held in September,
November and December directly parallels the existing zoning standards
under which the residents of the planning area are subject under County
jurisdiction.
The City reviews proposals by land owners fir perimeter landscaping as
those landowners request approvals. The projects must meet standards
established for grade, water efficiency and nuisance water.
X.S. Comment; Your lack of concern for our true water situation in this valley is a
dangerous one. WE DO LIVE IN A DESERT AREA — WHERE
PUBLIC LANDSCAPING SHOULD REFLECT THIS FACT. Your
Hydrology Report is way off and full of holes — who did it? Were you
aware that in 1939 — 9 to 12 inches of water came down in one day in
September and that in September 1976 2 to 4 inches of rain fell, causing
flooding — imagine what that amount of rain does to clay soils! Add to
liquafaction (sic) the term "grease" — and the threat of many homes in
peril, Add to this your prediction. (II-6) of earthquakes wii the next 20 to
30 years, Not a pretty picture for builders to build homes for our citizens
— but they do — eg. Shay (sic) Homes and Coral Mt developments. What
ever happened to common sense and what's right and wrong? It has
been tossed away by attention to developer pockets. Those who live out
of the Valley.
lag
TN • C i ly of La Quints
General Flan Final EIR
Response to Comments on D.IR
Response. The cominentor is incorrect. Appendix G of the EIR includes the full
text of the "Seismic, Geologic and Flooding Hazards Sections of the
Technical Background Report for the Safety Element for the City of La
Quirlta," prepared for the General Plari update by Earth Consultants
International. The EIR includes references to both storms mentioned by
the commenter on page III-79.
The EIR includes initigation measures for both ground shaking and
liquefaction. The City currently implements standards for construction
for both seismic and liquefaction zones. The standards represent the
current knowledge of building officials throughout the state of California
relating to these two conditions.
X.9. Comment: You in LQ claim to be sensitive to .nature — what does the lighting of the
mountains do to the night animals that live there? I also have noticed
that those heavy duty lights were never turned off during the energy
crisi.V9 ', Other people had to do w/o for those kilowatts used!
Response: Lighting of the mountains is prohibited under the City's Development
Code, which requires that all lighting be angled down and shielded.
K.10. Comment:
As to Tamarisk in this area — they should be eliminated for the excessive
surface water they consume and the salt they add to the soil — originally
imported from China — they have outlived their use as massive wind
breaks for the open lands. Other wind resistant trees can do the same
purpose with less water use,
Response: Comment noted. The EIR does not encourage or mandate the use of
tamarisk trees as wind breaks.
X.11. Comment:
If as stated on 11-11 the visual resources "most valuable assets are the
mountain views and open desert vistas" why do you erect tall solid walls
on tall berms to shut off — not only air movement but those same
valuable assets — many of us are against this policy — but LQ rolls on
w/o regard to good common sense or what the local people want!
Response: The commenter is incorrect. The General Plan does not include a policy
mandating high walls. 1'he City limits walls to a height of six feet, and
restricts the construction cif residential units of more than one story in
Y
order to preserve scenic resources. The proposed General Plan would
further require that zoning standards be established for the height of
berms, a standard which does not exist under the current General Plan.
1.10
X.13. Comment:
X.12. Comment:
TVCity of La Quinta
General Plan Final FIR
Response to Comments on DEiR
Regarding stir quality — your plan for urban sprawls (sic) — thousands
and thousands more cars starting up and spewing their problems into all
Coachella Valley cities' air. (Yes we do have south winds that sweep up
thru (sic) the rest of the valley). That will clearly put the air quality at
more risk. 2000-2001 has shown the deterioration aunt air quality — the
mountain views have been more blurred and hazy than in previous years
— remember the stark clear outlines in previous years before the
construction boom?
Response: The EIR contains extensive discussion of the Valley's current and
projected air quality (pages III-125 through ill-143). This section also
includes extensive mitigation rneasures to improve air quality.
What do we do with our waste products? We are already running out of
space for waste from those already here. In fact the local waste can not
he acc.omodated (sic) now. Dump areas are too far and too few — so local
roads and vacant areas receive the local trash. Solve local problems —
bef'ore creating a monstrous problem in this area of more trash and waste
accumulation — for this reason I am against your HR.
Response: Solid waste disposal is addressed on pages 111-177 through III-181 of the
EIR. The City's waste is currently disposed of at the Edorn Hill landfill.
Lands in the eastern portion of the Planning Area arc serviced by the
Mecca Landfill, Additional landfills either exist or are planned northeast
of Moreno Valley, or at Eagle Mountain. 'these facilities and others have
sufficient capacity to address buildout of the General Plan. This section
includes mitigation measures to reduce the potential impacts associated
with solid waste with implementation of the (Jeneral Plan.
tIl
TNJCity of La Quanta
General Plan Final FJR
Response to Comments on DEIR
Y. VISTA SANTA ROSA PLANNING COMMITTEE
Ellen Lloyd Troyer
Y.I. Comment: In our view, the most significant local issue pertains to the proposed
"Agricultural Overlay." The EIR makes several references to this
important general plan component; yet, the associated text is not
available in the document for review. This makes it difficult to fully
gauge potential impacts and the effectiveness of the associated
mitigation measures. We believe the Agricultural Overlay is of critical
importance and urge the city not to defer its inclusion in the general plan
text available for public review.
Response: The eommentor is incorrect. The definition of the Agricultural Overlay
is included in Table 1-3, page I-15 of the DEIR. Further discussion of
the land use is included in section [11 of the EIR, page III-10, and pages
III-21 through 1II-29. The General Plan establishes the land use
designation, and defines its usage. The City, after the adoption of the
General Plan, will be required to adopt Development Code standards,
which have already been introduced at public hearings held in
September, November and December of 2001.
Y.2. Comment: Section lll:-A, "Land Use Compatibility" characterizes 7% of the land
area within Annexation No, 12 as "developed" (EIR III-14). The text
also states that approximately 70 0 (3,782 acres) is currently designated
for agriculture and very low density residential. The discussion should
clarify whether land currently in agricultural production or other type of
rural use is included within this classification, Much of the area is
vacant, in agricultural production, or devoted to large parcel ranch and
equestrian uses, In other words, the area is more accurately described as
":rural" than developed. 1'he opportunity to safeguard rural lifestyles as
urbanization advances is a key issue for many in the area. For our
purposes, :`rural lifestyles" includes those uses currently allowed under
the existing zoning and general plan classifications of Riverside County.
Farmers should have the choice to continue with land in agricultural
production, much the same as ranchers should be able to enjoy the use of
their lands for horse ranching or other purposcs currently allowed under
the existing county ordinances,
Response: Comment noted. Table Ill-1 lists the existing General Plan land use
designations, and the number of vacant and developed acres in each land
use classification within the planning area. Any land on which any
development occurs results in its inclusion as developed acreage. The
statistical analysis in the EIR does not characterize land uses, simply
quantifies where development has occurred.
112
TN/City of La Quints
General Plan Final EIR
Response to Comments en DEII
The land uses identified under Riverside County's jurisdiction are
allowed based on its Zoning Ordinance, not its General Plan, As stated
above, the General Plan establishes the definition, and the Development
Code implements this definition. The text proposed for inclusion in the
Development Code was modeled after the Riverside County Zoning
Ordinance, and will therefore allow the uses contemplated by the
cotnmentor.
Y.3. Comment: The city has assigned a pre -dominant (sic) general plan classification of
"LDR" (2-4 d_uJacre) with an "Agricultural Overlay" overlying much of
the same. territory. However, the EIR does not provide a great deal of
explanation with respect to the overlay, The discussion should be
expanded to include more detailed information concerning the
Agricultural Overlay and how it will allow for continued agricultural,
equestrian and other rural lifestyles, as both interim and permanent uses.
Specific concerns exist tbout potential land use conflicts arising as the
urban edge expands outward, and there is an interface with agricultural
uses. More particulars are needed that shed light on how the policies
and standards of an Agricultural Overlay would ameliorate conflicts.
Problems at the interface between agricultural uses and new
developments could result in practical or legal difficulties and could
have quality of life impacts.
Response: Please sec response to comment Y.1. above. The definition of
Agricultural Overlay states: "Any agricultural land use within this
overlay area shall be allowed to continue until such time as the land
owner chooses to develop." This statement makes it clear that existing
farms, ranches and stables can continue to operate indefinitely. As
previously stated, the City Council and Planning Commission have
begun review of the zoning standards to be implemented after adoption
of the General Plan, including permitted uses and "right to farm"
ordinances.
Y.4. Comment: Section III-B, "Agricultural Resources" purports to use an
Agricultural Overlay (as noted above, in order to ".,.preserve
agricultural uses to the extent desired by landowners." The text
continues, "Lands within the Agricultural Overlay will be allowed to
continue cultivation as under the existing General Plan, until such time
as the landowner chooses to develop." While such statements should
offer comfort to those who intend to or are engaged in agricultural
pursuits and/or rural lifestyles, the lack of specifics raises many
questions. Rather than defer the details of the Agricultural Overlay to
the future, the policies and standards should be drafted now. Many of
the mitigation measures suggested by the EIR could be incorporated as
113
TN/C ily of La Quinta
General Plan Final EIR
RssEonse to Comments on DEIR
standards in the Agricultural Overlay. Some of the mitigation measures
appear to address regulatory matters pertaining to agricultural use of
property rather than measures intended to address impacts related to
agricultural resources, i.e. 3. E. & F. Detailed information regarding the
overlay would be useful; including the type of agricultural land uses
coupled with definitive policies and standards. Further, the overlay
should anticipate potential conflicts along the urban edge (as anticipated
by the EIR) and offer solutions that have a tangible relationship to
underlying technical data, For example, buffer design should be a
function of evaluating the contributing factors associated with the
impacts. Some examples are the type of agricultural activity, the
proposed adjacent land use, the prevailing wind directions, noise contour
modeling, pesticide drift, etc, The technical information should be used
to arrive at a scientifically defensible buffer that will adequately mitigate
potential impacts.
Response: Comment noted. Please see responses to comments Y.1., Y,2, and Y.3.,
above. The (ieneral Plan sets policy, while the Zoning Ordinance
implements standards.
Y.3. Comment: Section 11I- , "Traffic/Circulation" contemplates a circulation
network featuring a system cfarterial, secondary and collector roadways
overlying a grid established by section lines. The Vista Santa Rosa
Community Council's "Vision Committee" has developed several
preliminary "Vision Statements" for the area one of which may include
large tracts of land developed as very low -density equestrian oriented
communities, In some instances, the type of circulation network
proposed may be over -designed to service the relatively low volumes of
traffic generated by such enclaves and the cross -sections may be out of
character with the design of such communities, One of the challenges of
creating a cohesive, functional circulation system could be a land use
pattern that juxtaposes the more traditional, higher density urban uses
with rural lifestyle -type communities. Solutions will be needed that
accomplish the disparate purposes of not compromising the design
integrity of such areas while maintaining the integrity of the circulation
system, One suggestion is that a roadway cross-section be added to its
circulation element that is compatible with a rural lifestyle community,
yet achieves the required Levels of Service.
Response: Comment noted. Tha circulation system and associatedroadway cross
sections have been designed to assure that adequate levels of service can
be achieved with buildout of the Recommended Alternative of the
General Plan. Should, over time, less intense land uses be developed in
these areas, and the traffic generated by these land uses be demonstrably
lower than currently predicted, the roadway standards will he amended.
114
TN City eft_.a Quinka
General.Plan Final Elk
Response to Comments on DEIR
Further, the construction of roadway improvements is tied to
development. Therefore, if development in any portion of the planning
area does not occur, roadways will remain in their current
configurations.
Y.6. COMMent: Section 1Ill-D, "Soils & Geology" indicates that much, if not all of the
Vista Santa Rosa area features engineering and geologic properties that
make it susceptible to geologic hazards such as wind erosion, ground
failure, and expansive/collapsible soils, Table I-4, "Land Use Buildout
Statistical Summary" projects a total of 12,225 units at buildout for
Annexation No. 12. Using the average household size of 2.75 persons
per household (as purported by the EIR), this equates to a population of
almost 34,000 persons at buildout, Obviously, this is considerably more
people exposed to the potential risk of geologic hazards than the current
FIR estimated population of 639 residents. Of particular concern are
liquefaction and in particular, subsidence risks. Subsidence risks are
noteworthy because they are associated with pumping of groundwater,
as the E.1R suggests. At the current time, the Coachella Valley Water
District groundwater management plan for the eastern Coachella Valley
is being drafted. The EIR should consider the data and findings being
used by CYWD in its study, and incorporate mitigation measures
consistent with CVWD, if suitable. Also, the CVWD groundwater
management plan envisions a long period of stabilization of the
overdraft and replenishment of the basin to historic levels. It would he
interesting to see a timeline that compares the anticipated absorption of
units within Annexation No. 12 to the implementation of the
groundwater management plan. It seems like there would be a
correlation between the exposure of persons to potential geologic risk
and the tinning/success probability of the CVWD plan.
Response: Comment noted. The draft CVWD Management Plan was included in
the research for the EIR. The EIR includes discussion and mitigation
associated with CVWD, and its implementation of the Plan. The City
will continue to cooperate with the District as it implements the
Management Plan, The preferred alternative in the Plan would result in a
reversal of current overdraft conditions.
As development occurs in any area identified as being susceptible to
either liquefaction or subsidence, engineering techniques have been
developed which shall be implemented. These techniques, includes irk
the City's implementation tools, including the Uniform Building Code,
are implemented on a case -by -case basis, in order to assure that site -
specific considerations are addressed. The City Engineer will continue to
review project on this basis until buildout of the General Plan occurs, As
Its
TN/City of La Quinta
General Plan Final EIR
Ravi -Ise to Comments on DEIR
standards and conditions change, the City's implementation tools will
also be updated.
Y.7. Comment: Section 1II-F, "Water Resources/Quality" comments that
approximately 40% of domestic water consumed is reintroduced into the
groundwater table through percolation. IIowevcr, other sections of the
EIR note that the Thermal area features lacustrine deposits associated
with ancient Labe Cahuilla, which contain relatively significant amounts
of clay, Clay layers can act as barriers to groundwater recharge, or what
the FIR refers to as "aquitards."is evidenced by the extensive tile
drain system in the area, which illustrates how percolation in some
locations is in fact, very poor. 1t should be noted that thc pilot recharge
facility located near Avenue 62 and Madison Street to which the ElE;t
refers lies upstream of what geologists commonly believe was the
shoreline of ancient Lake Cahuilla. "Therefore, the percolation
characteristics of thc surface and subsurface soils may be very different_
The EIR should consider local factors in the area and make an
assessment concerning how much domestic water can actually be
expected to be recaptured in the groundwater basin.
The characteristically slow percolation rates in the area should also
cause the EIR to revisit the premise that detention/retention basins will
play any meaningful role in efforts to filter runoff and stabilize/recharge
the groundwater basin.
A beefed up discussion of the CVWD groundwater management plan,
including its data sources, findings and conclusions, if available, could
be incorporated into the EIR. This would help ensure that there is
synonymous thinking regarding the existing conditions and would be
useful in gauging potential impacts and appropriate initigation measures_
Response: The 40% figure provided by CVWD is based on an average within the
Valley. Differing soils have differing absorption rates, and different uses
of water have a higher or lower recycling potential, These items arc
averaged to result in the 40% estimate. The FIR is a program document,
which addresses the General Plan as a whole, including all areas of the
planning area. Individual conditions vary, based on the soil type
occurring at any given location. The EIR is not intended to preclude
further environmental analysis in the future. On the contrary, as
individual projects occur, the City will have the ability to require
additional environmental analysis under CEQA to review site -specific
issues, including percolation and retention/detention basins. The City
implements the standards of the National Pollution Discharge
Elimination System (NPDES), as a co -permit -tee with Riverside County.
These standards restrict new development's ability to discharge storm
116
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
water, and thereby require the implementation of a retention or detention
system in conjunction with development. The City Engineer requires
that individual projects prepare geologic studies to identify soils on
individual sites, and design storm water systems based on those soils.
This practice will continue throughout the huildout of the General Plan.
Y.S. Comment: Section III-G, "Biological Resources", seems to infer that the city is
planning to opt into the Multiple Species Habitat Conservation Plan now
being prepared by the Coachella Malley Association of Governments and
its members (of which La Quinta is one). However, whether this
decision has been made or not is unclear. The text should clarify
whether if the city does not opt into the MSHCP, the mitigation
measures as proposed are deemed adequate to mitigate any potential
impacts.
Response: The City is currently participating in the preparation of the Multi -
Species Habitat Conservation Plan, as a signatory, to the Memorandum
of Understanding regarding that docuinent. Until such time as the HCP
is complete, and brought by CVAG to the City for adoption; the Cite
cannot determine whether the document will be adopted. That decision
will be made by the City Council at that time. The discussion in the EIR,
however, reviews the species of concern within the planning area,
regardless of their inclusion in the HCP, and proposes mitigation
measures for those species. Should the FICP not be adopted by the City,
those mitigation measures will continue to be implemented and be
adequate to mitigate potential impacts.
Y.9. Comment: Section III -II, "Cultural Resources." The Torres -Martinez tribe,
though not subject to the general plan, is considered to be a part of the
Vista Santa Rosa area. Therefore, we would urge the city to actively
solicit the input of the tribal council concerning cultural resources, and
for that matter, on all issues pertaining to general planning and land use.
Response: Comment noted. Program 1.2.1 of the Cultural Resources Element of the
General Plan states:
"Establish and maintain channels of routine consultation with the
Eastern Information Center at the University of California, Riverside,
the Native American tribes, and the La Quinta Historical Society."
(ennphasis added)
V.10. Comment: Section III -IC, "Visual Impacts." As attempts to define a vision for the
area encompassed by Annexation No. 12 and much of the SOT emerges
(sic), preservation of scenic vistas to the Santa Rosa and San Jacinto
Mountains is considered a very important matter, Other mitigation
117
[T1fCity of La Quinta
General Plan Final FJR
Respornse to Comments on DEAR
measures that could be considered on a project -by -project basis include
appropriate use of landscape materials to allow views, wall heights and
materials, grading, etc.
Response: Comment noted.
Y.11. Comment:
Section 111-1s, "Public Services and Facilities." The provision of
public facilities and services to annexed areas is an area of significant
concern. Reliance is placed upon agencies outside the city, and over
which the city has little or no control. However, some of the mitigation
measures assign the responsibility for mitigation on these same agencies.
Services that the city dues provide will require funding commitments
that once in place, will constitute an annual fiscal drain. Therefore, the
viability of city -provided public services is seen as inexorably linked to
the analysis contained in "Section II1-M, Socio-Econoinie Resources,"
Response. Comment noted_
Y.12. Comment:
The figures for Annexation No. 12 indicate a deficit of about $5.4
million at buildout. This analysis is based on achieving an average
density of 3 units per acre over the annexation area. It is assumed that
the city anticipates offsetting the deficit with general fund surpluses
resulting from the development and/or annexation of other areas
featuring land uses possessing positive fiscal attributes to the city, i.e.
commercial/industrial development and resortlhospitality. The EIR text
should correlate the timing of Annexation No, 12 with annexation in
other areas in order for the reader to better understand the projected cash
flow on an annualised basis, This way, an assessment can be made of
the potential impacts of timing shifts, or the uncierachievcrrient of
projected revenue sources in any particular year. .Also, it would be
interesting to know what the consequences would be of the
deritylintensity yield of Annexation No. 12 being underachieved, e.g. if
the area were to develop at 2 units per acre, rather than 3, with the
corresponding reduction in other non-residential uses as well.
Response: Comment noted. It is not possible for the City to determine the rate of
growth in any arca, and therefore predict the rate of cash flow associated
with development on an annual basis. The estimates provided must
therefore be based on buildout of the planning area. Should the
annexation of any portion of the planning arca proceed, the Local
Agency Formation Commission requires the preparation of fiscal impact
models which include both short-term and long term buildout estimates.
These models will, if prepared in the future, more clearly estimate the
cash flow described by the cornmentor.
118
IN/City cf La Quinta
General Plan Final F1R
Response to Comments on DIiIR
The requested information on lower intensity development is provided
for the entire project area, in the Section V, Table V-14.
Z. IRIS CAPITAL GROUP
Tracey Darrall
TNTCity of La Quinta
Generil Plan Final FIR
Rr.sponse to Comments nn DE R
Z.1. Comment: This Draft FIR is not an objective assessment of the environmental
impacts. It is biased and therefore does not satisfy the requirements of
CEQA,
Response: The commentor's opinions are noted. The EIR addresses the mandated
CEQA topics, provides research and documentation on current
conditions and projected impacts, and mitigation measures. It fully
complies with CEQA.
Z.2. Comment: The above referenced Draft Environmental Impact Report (EIR) for the
Proposed Comprehensive General Plan ("The Plan") does not
adequately address the following issues which should be resolved and
corrected before the EIR is adequate per CEQA and ally General Plan is
updated. Many of these issues were raised before regarding your Notice
of Preparation of an Environmental Impact Report for the City of La
Quinta (-funeral plate up date (sic) notice to the General Plan, but were
ignored. Again, 1 raise them, and refer you again to the letter by Ellen
Trevor (sic) dated May 21,2001.
Per state law you are required to adequately address the issues that have
significant impact and not with a biased view, but vvith an objective view
which does not seem to be occurring.
Response: Comment noted. Please see response 7,.1., above,
Z.3. Comment: The Agricultural Overlay is unclear. The Plan does not define in detail
what types of properties are incorporated into the Agricultural Overlay
yet refers to it constantly throughout the report. In fact there is no
clearly written and defined agricultural overlay per the City of La
Quinta, Therefore, the E1R is invalid until this is clearly defined.
Response: Comment noted. Please see response to comment Y.1, Y.2. and Y.3.,
above.
Z.4. Comment: The Socio-Economic impact of the proposed development on the
equestrian industry and uses with the Annexation Area No. 12 (AA) and
the proposed Sphere of Influence (SOI) have not been addressed even
though this issue has been raised numerous times to the city of La
Quinta in letter and verbal form, in City Council meetings, and in letters
regarding the Proposed Notice of Preparation of the El R. The Draft FIR
still ignores the likely damage to the horse industry that currently brings
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TN/City of La Quints
General Plan Final EIR
Response to Comments on DEIR
in about $70,000,000 annually into the local region, and is projected to
grow to $120,000,000 in the next few years. Development of the
annexation and SOI area with 2-4 houses per acre with no equestrian
overlay and protections, wide roads, and resort, commercial and
industrial development with only 10D foot buffer zones, will ultimately
decimate this burgeoning industry by destroying stabling and training -
facilities, shrink the agricultural pasture lands making livestock and
horses too expensive to keep, and decimate the local alfalfa industry.
The Proposed La Quinta General Plan Alternative, will negatively
impact the equestrian community and severely reduce local employment
and tourism due to the equestrian industry, particularly for the Cities of
Indio and Coachella.
Response: The General Plan does not propose to change any existing land use
within the planning area. The Agricultural Overlay specifically states
that existing land uses can continue in perpetuity, or until such time as
the land owner chooses to develop. Further, the City does not currently
have jurisdiction over the areas referred to by the commentor. Until such
time as these areas are annexed, jurisdiction will continue to fall under
the County of Riverside.
Z.5. Comment: 1,a Quinta has provided no equestrian overlay or provision for equestrian
use as a mitigation measure which would be easy to incorporate into the
Plan, even though a significant portion of the entire area proposed to be
annexed and put into the Sphere of influence (S01) is equestrian
oriented, This must be addressed and thoroughly mitigated through
wider buffer areas, reduced development density, smaller roadways
particularly through the "Vista Santa Rosa" maintaining two lane rural
roads and imposing 35 mph speed limits along with soft curbs and side
of road areas fur safe equestrian passage. The Vista Santa Rosa is
bounded by Avenues 52 and 66, Harrison and Monroe.
Response: Comment noted. Equestrian land uses are currently considered
agricultural land uses in the Riverside County zoning ordinance_ The
City has incorporated the same definition into the overlay. Therefore,
equestrian Land uses are inferred under the overlay designation.
As regards the roadway issue, please see response to comment Y.5,,
above.
Z.6. Comment: Per the County Regional plan, equestrian trails were to be incorporated
throughout the area. They have been virtually left out in certain areas
such as along Avenue 60, changed to golf cart paths or obscured in the
Proposed General Plan and not addressed in the EIR in traffc issues,
cultural resources, or socio-economic impacts, e. The ER does not
121
T ,11City of La Quints
General Plan Final MR
Response to Comments on DE1R
address this issue and the Plan does not accommodate the trails that
should be shown and were provided for in the Specific Plan for PGA
West and in the Regional Plan.
Response: Comment noted. The Riverside County General Plan does not show a
trail on Avenue 60 (Exhibit IV-19). The trails shown in that exhibit have
been incorporated into the City's trail exhibit (Exhibit 3.10, General
Plan). Equestrian trails are described in the General Plan as "Multi -
Purpose" trails, and are included throughout the planning area, including
PGA West.
Z.7. Comment: Wildlife corridors and movement to open space be destroyed. The
trail system would of (sic) allowed wildlife movement throughout the
area. A valid, safe and complete equestrian trail system would allow for
the corridor/movement of wildlife throughout the area and to opci
space. With the lack of an adequate trail system through this area, La
Quinta will have destroyed any ability of the native wildlife to have
survived. The trails should go throughout the area, and roads made
smaller down to two lanes with soft edges instead of curbs to provide
and protect wildlife movement and equestrian usage.
Response:
Z.S. Comment:
Response:
Comment noted, Please see response to comment Z.6,, above. As
regards the viability of equestrian trails as wildlife corridors, it is
generally accepted that the width of an equestrian trail, generally ranging
from 8 to 12 feet, is insufficient to provide adequate space for a wildlife
corridor_
The proposed development density, road system, and traffic load will
destroy the ability to utilize the roadways safely for agricultural or
equestrian 1.13es, The proposed traffic increase to 1,250,000 traffic trips
per day will make unsafe usage of the roads for livestock, horses, or
farm equipment. Per CEQA this roust be thoroughly addressed and
mitigated 1.vhich has not been done.
Comment noted, Please see response to comment Y.5., above.
Livestock, horses or farm equipment will continue to have the ability to
utilize the regional roadway system, within the parameters of State
vehicle codes. The adoption of the General Plan will not impact that
ability. Should the General Plan build out with the land uses proposed on
the Recommended Alternative Land Use Map, the roadways proposed
will be necessary to accommodate the level of service.
Z.9. Comment: Per CEQA, traffic plans must accommodate the movement of
agricultural equipment when the annexation is of agricultural land. This
has not been done. Furthermore, the traffic plan would not
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TN/City of La Quint
General Nan Final E]R
Response to Comments on DE1R
accommodate horse trailers. 1 he roundabout at Jefferson and 52"d right
near the Polo club is impossible for a large trailer to navigate safely,
Response: Comment noted. Please see response to comment Z.S., above. The
roundabout at Jefferson and Avenue 52 has been designed to
accommodate street -legal vehicle of all types.
Z.10. Comment:
The proposed roadway system and traffic plan would destroy the scenic
resources of the area. One of the most beautiful roadways in the entire
area is palm tree -lined Avenue, b{], between Jackson and Van Buren.
Yet it is planned to be major arterial. The impact of the roadway system
destroying scenic resources must be addressed and mitigated. The
roadway system is too large and aggressive throughout the Vista Santa
Rosa area, It should be reduced to two lanes, soft curbs, no lights, and
35 MPH speed limits_
Response: Comment noted. Please see response to comment Z.# ., above. The City's
standards for parkway landscaping will be imposed, should any roadway
in the planning area fall under its jurisdiction in the future. These
standards include setback requirements, berniing and landscaping to
ensure actiteties are maintained.
Z.11. Comment: The claim that "This land use designation of up to two units per acre
provides a transition between agricultural lands and more intense urban
uses and promotes a progression of compatible land uses." (sic) This is
invalid as a transition as the density will provide significant problems for
neighboring agricultural/ranch uses,
Response: Comment noted. The City's implementation of agricultural zoning
standards, right to farm and notification requirements will protect
existing agricultural and equestrian properties in the future.
Z.12. Comment: Mitigation of buffer areas of 100 feet are completely inadequate. It
should be 500 feet and the zoning density decreased significantly -
Response; Comment noted. The provision of buffering is only one component in
the proposed implementation of the Agricultural Overlay. In
combination with development standards, notification requirements,
right to farm standards and other provisions considered by the Planning
Cornmission and City Council, they provide adequate mitigation
between urban and agricultural land uses.
Z.13. Comment:
The No Project Alternative would be a better choice. It would preserve
the current agricultural land use designations and preserve the ability to
.farm and allow the growth of the equestrian industry.
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TIJ C i ty of La Quinta
General Plan Final EIR
Response to Comments on IDEO,
Response: Continent noted,
Z.14. Comment:
The traffic impact at build -out (sic) which would generate approx. (sic)
1,200,150 daily vehicle trips per day in the area, would have a
significant impact. It would not operate within acceptable levels in the
annexation and SQI area, 15 roadway segments would exceed capacity.
This would cause a significant impact on agricultural and equestrian
usage, `1'o state otherwise is biased.
Response: The commenter is incorrect. All of the roadway segments and
intersections in the Annexation area and the Sphere of Influence are
expected to operate at an acceptable level of service at buildout. The
referenced 15 roadway segments arc all located in other parts of the
planning area. The segments are:
Z.15. Comment:
Street Segment
Washington Si.: Avenue 44 to Miles Ave.
Washington St: Miles Ave, to Highway 111
Adams St.: Highway 111 to Avenue 48
Monroe St.: Miles Ave. to Highway 111
Jackson St.: Indio Ave. to Highway 11 1
Auto Center Dr.: Interstate-10 to Indio Ave,
Dillon Rd.: I Iighway 86(S) to 4lighway 111
Avenue 50: Highway 86 S) to Vista Del Sur
Country Club Dr_: Oasis Club Dr. to Washington St.
Fred Waring Dr.: Oasis Club fir. to Washington St.
Highway 1 l l: Washington St. to Adams St.
I [ighway 111: Jefferson St. to Madison St,
Ilighway 86/111: Auto Center Dr. to Dillon Rd.
lIighway 1 1 1: Avenue 52 to Tyler St.
Highway l 11: Airport Blvd, To Filmore St.
WC Ratio
1,20
1,15
1.03
1.03
1.03
1.08
1.01
1.05
1,03
1.02
1.08
1.01
1.17
1.03
1.08
The EIR states that these roadway segments will he impacted, and
provides mitigation measures to reduce the impacts.
Water Resources will be significantly impacted per CVWD. The EIR
does not adequately mitigate or address the depletion of the groundwater
and the depletion of local wells of the residents in annexation and SQI
areas. Again the k 1R is biased. Per The (sic) FIR states that CVWD has
demonstrated that groundwater recharge at this location south of Lake
Cahuilla since 1996 has been feasible. This is riot completely true and
misleading,
124
TN/City of La Quinla
General Plan Final EIR
Response to comments on DEIR
Response: Comment noted, The District's Management Plan, and a number of
other documents published by the District, include the Martinez Canyon
recharge basin project. The District has indeed included this project in
its planning efforts for several years.
Z.16. Comment: The claim that 40°l% of domestic water is re -absorbed into the
groundwater table and not lost is not true in the lower eastern Coachella
basin. Moreover, any recharge water is not as clean as the original
groundwater. The itnpact of this has not been adequately addressed.
There will be a need to build out new treatment plants —who pays for
this and what is the socio-economic impact of this on the area residents?
Who will mitigate the residents for their wells drying up as the overdraft
on the water table is furthered by the proposed development.
Response: As previously stated in response to comment Y.7., the re -absorption rate
discussed in the EIR is an average, .ind actual conditions will vary in
different parts of the planning area. Water which is re -absorbed, if
provided from wells, is treated by the District, and meets all standards
for potable water.
Z.17. Comment:
The District will determine the need for additional facilities through
their planning process, and will have a number of options for financing
facilities, including connection fees, assessment districts and bond
issues.
The purpose of the District's Management flan, and the City's water
conserving ordinances for building and landscaping, is to prevent "wells
drying up." The City will continue to review individual projects for their
conformance with water conserving measures, will continue to cooperate
with the District in the development of water conservation measures, and
will also continue to route projects to the District for comments as they
occur.
The FIR claims La Quinta will protect domestic water supplies. How?
The socio-econornic impact on the residents of switching from septic
and wells to CVWD has not been addressed. Again, who pays for this
and the sewer lines? And what is the impact on the residents. (sic)
Response: The General Plan is a policy document, which will not preclude
individual project reviews in the future. The City's standards, as
established in the Municipal Code, will be applied to all future projects
which are proposed in the City.
The policies in the General Plan requires that new development connect
to water and sewer lines. Existing development is not required to
]25
L.1S. Comment:
`1 1!City of La Quints
General Plan Final EIR
Response to Comments en DEIR
connect. The District has established assessment districts in the past to
constect un-served neighborhoods to sewer system extensions, in order
to protect groundwater, The District offers a number of options to
homeowners under such assessment districts, and generally does not
require connection unless the septic tank on a particular property is
failing, and poses a hazard. These issues will be addressed on an
individual basis as projects are proposed in the future.
There is no real provision for Open Space or biological resource
survival. The EIR states "the general Plan annexation and LOI (sic) land
use designations all propose to maintain a low density development
pattern and preserve sensitive biological areas as undevelopable open
space." Identifying gulf courses as open space is not par government
code. A. golf course is not a valid resource arca for biological survival as
golf courses have a high usage of pesticides and chemical fertilizers.
This must be addressed. Implementation is not expected to have a
significant adverse impact on biological resources," ---This is not true!
No where (sic) in the midst of the area La Quinta claims to be preserving
is there any really useful open space except the edge of some rocky
knolls that are really impossible to utilize except for rock climbers and
bighorn sheep. The lack of wildlife corridors and greenbelts without
walls, that allow access to real open space areas, will significantly
impact the biological resources of the area.
Response: The commenter is incorrect. References to open space in the Biological
Resources section of the EIR do not refer to golf courses. Open space
areas for biological preservation, as described in the EIR, include areas
above the toe of slope, natural open space which may be preserved on
individual properties in the future, and the preserves set aside for
Coachella Valley Fringe -toed Lizard preservation areas. In addition,
future preservation areas, as proposed in the Coachella Valley Multi -
Species Habitat Conservation Plan, if and when adopted, are appropriate
biological resource preservation areas.
The EIR clearly defines the areas of the City and planning area where
sensitive biological resources occur, and provides directive mitigation
measures requiring site -specific studies for those species. The studies,
when completed, will include mitigation which relates to individual
project impacts, potentially including on- or off -site preservation of land.
Because of the issues associated with specific species in specific
locations, the continued review of individual projects is the most
appropriate method to ensure long-term preservation of biological
resources.
126
Z.19. Comment:
TN/City of La Quinla
General Plan Final EIR
Response to Comments on DI~IR
The potential increase in pesticides and chemical fertilizers due to the
increase (sic) golf courses and median and roadway strips has net been
considered on the groundwater and wildlife.
Response: Issues associated with groundwater contamination are addressed under
Section III-F, page 1[1-93, mitigation measure I, page III-95, and
Mitigation Monitoring Program item A. The City shall continue to
review individual project proposals as they occur, and enforce the
required local, regional, state and federal standards associated with
pesticide and chemical use.
Z.20. Comment:
Response:
Z.21. Comment:
Response:
Z.22. Comment:
Response:
The destruction of prime farmlands has not been fully addressed or
mitigated. Over 30% of all the dates in North America are grown in the
Vista Santa Rosa arca of the plan alone. In the entire annexation and
planning area, the number could be virtually 80%. `[his issue has not
been fully addressed cr sufficiently mitigated.
The impacts of the General Plan on farmland is addressed in Section 111-
B, pages 111-21 through II1-29. The potential loss of agricultural lands if
the landowner wishes to stop farming and convert the land to another
use has been identified as being significant, even with mitigation.
The destruction of the scenic resources of the area has not been fully
addressed or mitigated. The views of the Santa Rosa mountains is one
of the most special parts of the area, loved by all who live in the area or
visit. There is nothing in the platy that truly protects that, such as the
elimination of walls and berms, and the plan for view corridors.
Issues associated with aesthetics are addressed in the EIR under Section
III-K, Visual Impacts, pages III-159 through III- 164. Mitigation
measures include provisions for the protection of viewsheds throughout
the planning area, including mitigation measures F., J., L., M. and N.
Air pollution increase in the basin is falsely represented as it will be
significant due to the increased motor trips.
"I'hc air quality impacts associated with buildout of the General Plan
have been calculated using the current methodology required by the
South Coast Air Quality Management District. The calculations are
shown in section III -I, on pages III-132 through I11-140. This data
accurately represents the potential air pollution emissions for buildout of
the General Plan.
327
TN!City of La Quinta
General F'kn Final EIR
Response to Comments on DEIR
Z.23. Comment: More open space is defined as golf courses. Golf courses may or may
not be public or visible so it is not real "open space". And is a misuse
(sic) and misleading term_-1-22.
Response: Comment noted. The General Plan identifies Open Space lands in four
categories: Park Facilities, Open Space, Golf Course and Watercourse,
These lands in the aggregate represent a total of 14,120 acres under the
Recommended alternative. The lands assigned the Golf Course
designation total 4,694 acres, or 33% of the total Open Space lands_ 66%
of Open Space lands are public lands.
Z.24. Comment: II-3 Agricultural Resources: Never mentions equestrian uses, pasture
and alfalfa, which is inadequate,
Response: Comment noted. The description of the arca as "agrarian" provides a
general description of the. existing. No specific usage was intended,
Z.25, Comment: The planned additional 66,81 l residential units at 75% build -cut (sic), is
outrageous for the area, and lAii11 have a more than significant impact on
all aspects of the area. That is a virtual another Los Angeles. This will
destroy the local economy as the reason people come from LA is to get
away from the density_ The negative impact to the local economy of the
proposed development must be considered.
Response: The EIR analysis represents a conservative (worst -case) analysis of the
development potential of all lands in the planning. arca. Socio-econornie
impacts are addressed on pages Ili-191 through 111-209 of the EIR.
Z.26. Comment: On page 11I-10, the EIR states "the proposed land use densities and
assignment do not appear to pose any significant land use
incompatibilities with existing or planned land uses in adjacent
jurisdictions." This is completely untrue and biased. A11 the true and
cumulative impacts must be addressed.
Response: The General Plan does not propose land uses which are incompatible
with the land uses in adjoining jurisdictions. The land development
pattern in Indio, Coachella and the unincorporated portions of Riverside
County adjacent to the current City limits include projects, both
approved and constructed, which range in density from 2 to 8 units per
acre. The land use map of the General Plan proposes similar densities,
and therefore demonstrates a consistent development pattern.
Z.27. Continent: Open space Land uses---III-12 No real open space is actually being
planned. Golf courses are not Open Space. The park area actually
planned in the annexation and sphere of influence area is only 20 acres,
128
TN/City of La Quinta
Ocncral Plan Final EIR
Response to Comments on DEIR
in an area comprising over 12,000 acres. This is completely inadequate
for the public and potential residents.
Response: Please sec response to comment Z.23, above. The General Plan
identifies a need for 3 acres of parkland for each 1,000 residents (Policy
2, Parks and Recreation Element), and clearly shoves that future parkland
will be required. The specific locations for parks, unless currently owned
by the City, have not yet been identified.
Z.28. Comment:
The Summary of Impacts is invalid and biased. On page III-13, the EIR
states that "impacts within the City of La Quinta and on surrounding
lands resulting from adopting implementation of the proposed General
Plan are not expected to be significant" This is completely false. How
can an additional 1,250,000 daily traffic trips and 66,000 new homes
immediately adjacent not be significant? This is a biased EIR. The
impact on agricultural atone will change the financial dynamics of Indio
and Coachella and Riverside County, The ultimate elimination of
equestrian ranches will impact the horse industry and dynamics of that
vital industry in the desert to say nothing of the removal of year round
activities being changed to resort and second homes thus diminishing
year round activity for many business.
Response: Comment noted. The FIR addresses the mandated CEQA tc:pics,
provides research and documentation on current conditions and
projected impacts. and mitigation measures. Areas where impacts may
he significant are clearly identified. The EIR fully complies with CEQA,
Z.29. Comment:
The EIR states that the approval ofthe SGI amendment would not result
in any significant adverse environmental impacts to lands within the SOI
or its vicinity, per their EIR, This not true, and again biased. It would
diminish the local residents self -destiny and would encourage more
development, as La Quinta is pro -development. It will diminish the
equestrian interest in the area and thus reduce the value of the local
properties, as the plan does not accommodate equestrian interests.
Response: The commentor is incorrect, The City currently has nc jurisdiction over
lands outside its City limits. Should any of the planning area lands
eventually be annexed, the General Plan clearly states that all lands
currently in agricultural land use may continue in such use until such
time as the land owner wishes to develop another land use, The
equestrian interests in the area will be diminished only if the land
owners choose to sell or convert their ranches.
129
AA. CITY OF IND1O
TN/City of La Quinta
[general Plan Final EIR
Response to Comments on DEIR
AA.1. Comment: Our conclusion — the DE,ll fails to meet the minimum legal
requirements for both procedural and substantive aspects necessary to
carry out a complete, thorough and objective analysis in accordance with
CEQA. In particular, the DEIR is flawed and deficient in the areas of:
Proper notice to affected and adjoining governmental jurisdictions.
Response: Comment noted. The City of Indio was sent the Notice of Preparation
and the Draft EIR, The Notice of Availability was published in the
City's adjudicated newspaper. The City has complied with CEQA in
providing public notice to all responsible parties.
AA.2. Comment: General Plan, zoning and land use descriptions of Indio Rancho Country
Estates and Polo Resorts properties immediately adjacent to your area of
Interest and north or Avenue 50 and 52 in the City of Indio are not
identified or are inadequately described. These are areas of particular
concern to the City of Indio, its residents and investors and must be
addressed in the DEIR.
Response: Surrounding land uses for all adjacent _jurisdictions are described in
sections II-R and III -A of the EIR. Lands within the City of Indio are
described in particular on page 111-7 of the FIR, and provide sufficient
description to characterize land use patterns hi the area.
AA.3. Comment: Traffic impacts upon the City of Indio including impacts upon such
major north/south roads as Jefferson, Madison, Monroe, Jackson,
Calhoun and Van Buren which provide the most direct access to both
Highway 111 and the I-10 freeway and all of the inter -related
intersections thereto resulting from the potential of 80,000 new dwelling
units rather than 66,000 dwelling units identified in the DELI .
Response: Comment noted, Traffic impacts, including regional traffic impacts, are
described on pages 111-38 through 1I1-48, as well as in Appendix F of the
EIR. The methodology used to quantify potential dwelling units is
clearly described on page III-3 of the EIR. The accurate number of
potential units is 66,000, not the 80,000 estimated by the cammentor.
Also see response to comment AA.11., below.
AA.4. Comment: Traffic impacts upon the City of Indio including impacts upon such
major easUANeSt roads as Avenue 52, Avenue 50, Avenue 49, Avenue 48,
Highway 111, Miles Avenue, Fred Waring Drive and all of the inter-
130
TN. City of La Quinta
Gencral Plan Final EIR
Response to Comments on I]EIR
related intersections thereto resulting from the potential of 80,000 new
dwelling units rather than 66.000 dwelling units identified in the DEIR.
Response: Comment noted_ See res xinse to cornmcnt AA.3., above.
AA.5. Comment: Cumulative impacts upon all areas of sensitivity to thresholds including
mitigation measures, public improvements and other financial offsets for
enhanced infrastructure of affected public agencies necessary to properly
mitigate the significant impacts.
Response: Cumulative impacts are addressed in Section VIII of the 1✓IR.
AA.b. Comment: Consideration of reasonable municipal service agency alternatives to the
project including leaving the area within the City of Coachella Sphere of
Influence, placing the area into the City of Indio's Sphere of influence,
creation of a Vista Santa Rosa Municipal Advisory Council under the
jurisdiction of the County of Riverside or the incorporation of a city of
Vista Santa Rosa.
Response: Comment noted. Ci1QA does not require the "consideration of
reasonable municipal service agency alternatives." Such consideration is
the responsibility of the Local Agency Formation Commission.
AA.7. Comm cut: In other instances, the DEIR contains summary and conclusionary
statements that arc not supported by any information, documentation or
analytical data.
In determining the proper scope of an EIR, it is necessary to consult with
the appropriate agencies, municipalities, and public who will be
impacted by the proposed actions. Because a portion of the area being
considered for annexation and a sphere -of -influence amendment
currently lies in the city of Coachella's sphere -of -influence and the fact
that both cities of Indio and Coachella would bear impacts from buildout
of the proposed General Plan, the absence of a "Notice of Intent to
Prepare an EIR" to the City of Indio has resulted in a void of
information relative to impacts upon the City of Indio. "Traffic, noise,
land use, and water resource impacts upon the City of Indio were not
fully analyzed or disclosed in the DEIR. It should be noted that the City
of Indio was not sent a Notice of Preparation (NOP) for the DEIR. It is
unclear to us whether such notice was overlooked with the City of
Coachella — and if it was, there may be additional shortcomings in the
DEIR.
Response: The commenter is incorrect_ The Notice of Preparation (NOP) was sent
to the City of Indio on 4/17/01, UPS tracking #.IZ84E 022 03 1003 270
131
41\17City of La Quints
General Plan Final EIR
Respnne to Comments an DE1R
3. It was delivered 4/18/01, 12.09 p.m., and signed Ramsey_ The City of
Indio did not respond to the NOP_
All regional issues, including traffic, have been fully analysed in the
DF.IR. As a Program EIR, the document does 110 analyse individual
project impacts, not does it preclude such analysis under CEQA in the
future.
AA.8. Comment: Although the document contains a substantial amount of information,
the DEIR is inadequate since it fails to fully analyze the Cieneral Plan's
impact on several environmental categories including mineral resources,
hazards and hazardous materials, and parks and recreation. These
categories were identified in the Initial Study as less than significant and
potentially significant. This is very questionable since the bui]dout will
add about 66,811 new dwelling units (sec comment below regarding the
potential maximum huildout). All of the environmental categories
identified above that have been excluded in the DEIR are required to be
analyzed in EIRs for general plans.
Response: The cornntentnr is incorrect_ The potential impacts associated with
mineral resources and hazardous materials are both identified as less
than significant in the initial study (see Appendix A, DEIR). The
General Plan clearly states that mineral resources do riot occur within the
planning arca (General Plan, page 52). T}i issues associated with land
use compatibility and hazardous materials are addressed in Section III -A
of the EIR, Finally, parks and recreation are addressed in the General
Plan Parks and Recreation Element, pages 45 through 48. Since the
General Plan and associated Master Environmental Assessment identify
a need for 3 acres of park land for every 1000 residents, and policy in
the General Plan establishes that standard, no mitigation is needed.
AA.9. Comment: The DEIR fails to include an accurate project description. In particular,
the DEIR ignores the fact the arca being considered for annexation and
sphere -of influence amendment is currently in the City of Coachella's
sphere -of -influence _ This oversight is significant for all parties involved
(citizens and property owners in surrounding areas, investors/developers,
affected public agencies) in the decision making process regarding this
very important land resource opportunity. Ali members of the public are
owed a reasonable description and comparison analysis of all options in
analyzing your proposal. In fact, one of the actions necessary to achieve
the project's end result is a L FCD Sphere of Influence Amendment by
the City of Coachella deleting a portion of their SDI.
Response: The City is aware that approximately 3,200 acres of the planning area is
located in the Sphere of Influence of the City of Coachella, A Sphere of
132
TN City of La Quinta
General Plan Final E1R
Response to Comments on DEIR
Influence, however, is advisory only, and can be amended by action of
LAFCO. The project description is located on pages 1-4 through 1-2.9. In
order to clarify the issue for the cornmentor, the second paragraph of
page 1-9 is amended as follows:
"The General Plan planning area consists of 53,498 acres, including
20,254± acres in the City limits, and 33,244± acres in the sphere -of -
influence and lands outside the sphere and within the planning area.
Approximately 3,200 acres of the planning area, generally located north
of Airport Boulevard and East of Monroe Street, are located within the
City of Coachella's Sphere of Influence,.,,"
The EIR addresses only the CEQA analysis for any potential change in
boundary to the City of La Quinta or the City of Coachella. The LAFCG
process will include additional analysis and a number of public hearings,
should an application be filed by the City of La Quinta. 'The inclusion of
3,400 acres of the planning area in the City of Coachella's Sphere of
Influence does not represent a potentially significant impact under any
mandated CEQA analysis category,
AA.10. Comment: The DEIR fails to provide any thresholds of significance as a baseline
fur determining whether the impact for each of the issue areas is
significant.
Response: Where appropriate and available, thresholds of significance have been
identified in the EIR, including bat nil limited to air pollution emission
standards, traffic levels of service, noise standards, public facility
capacity standards, and impacts to cultural and biological resources.
These standards are discussed itt the appropriate section of section III of
the Ell.
AA.11. Comment: The analysis in the DEIR underestimates the impacts of buildout of the
proposed Genera] Plan and the proposed annexation and sphere -of -
influence amendment areas on the adjacent cities of Indio and Coachella.
This is especially apparent in the impact analysis for public services and
utilities. The DEIR uses 2.75 persons per household to determine the
impacts. This number is considerably lower than the household size
figures used by the California Department of Finance (3.263 persons per
household), and the Southern California Association of Governments
(3.24 persons per household — 2005 and 3.14 persons per household -
2020). The DEIR's low household size figure is used throughout the
analysis, significantly underestimating the impacts of the buildout of the
General Plan on all public services and utilities by 20 percent — that is as
much as 13,362 additional household and dwelling units.
133
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Genera] Plan Final FIR
ResEnse to Comments an DE1R
Response: As cited in the EIR, the data regarding the persons per household was
provided by Claritas, Inc., a well respected market data provider, based
on actual households in the planning area, not on populations in any of
the surrounding cities. The ClariLas estimate represents a more accurate
per household population count for the planning area, and was therefore
utilized in the EIR. Estimates of impacts are riot under -estimated,
AA.12. Comment: Alternative analysis in the DEIR is inadequate because it does not
comply with CEQA's requirement to provide alternatives that
substantially lessen or avoid environmental damage. Instead, the HEIR
presents a "more intense development scenario" which does not lessen
or a -void environmental damage and has impacts greater than General
Plan buildout.
Response: The comrnentor is incorrect. The alternatives selected include both a less
intense and more intense alternative. The less intense alternative clearly
demonstrates how impacts would be lowered if densities were to be
reduced. The more intense alternative does .meet the requirements of
CEQA, insofar as it identifies potential impacts associated with the
project if principles associated with the elimination of urban sprawl were
implemented. These principles include intensified land use densities for
residential development, permitting a larger population in a smaller area,
and locating commercial opportunities to serve these areas within short
distances. The intent of this alternative was to examine whether it could
achieve less signit[eant impacts if implemented. Although some of the
impacts associated with this alternative may be greater than the
recommended alternative, its analysis was still appropriate as part of
Section V of the EIR.
AA.13, Comment: Besides containing substantial errors in forecasting impacts, the I]EIR
also lacks consistent application of the cumulative impact analysis,
especially as it pertains to the proposed annexation and sphere -of -
influence amendment. Time and time again, the cumulative impact
analysis of an environmental category consists of a brief, superficial
discussion that is factually lacking.
Response: Please see response to comment AA. I l., above. Section 15130(b) of the
CEQA Guidelines states:
"The discussion of cumulative impacts shall reflect the severity of the
impacts and their likelihood of occurrence, but the discussion need not
provide as great detail as is provided for the effects attributable to the
project alone."
134
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General Plan Final LIR
Response to Comments an DEUR
The discussion contained in Section VIII of the EIR accomplishes this
goal, and references other portions of the document where regional
issues have been identified. The document adequately addresses
cumulative impacts.
AA.14. Comment; In sum, the DEIR discounts or entirely ignores many signifeant, adverse
environmental impacts associated with buildout of the General Plan and
the proposed annexation and sphere -of -influence amendment areas. An
EIR must be prepared with a sufficient degree of analysis to provide
decision makers with information which enables them to take necessary
and appropriate actions. The DEIR's analysis of the project's impacts
fails this test, being seriously misleading and inaccurate.
Response: Comment noted. The EIR provides sufficient information, whether in the
text itself or in the attached and referenced Appendices to meet or
exceed the requirements of CFQA_
AA.15. Comment: The following is a list of some of the deficiencies in the. DEIR. We
conclude that the DEIR is inadequate in its present form and that the
DEIR requires additional information arid analysis of such substantial
nature that it cannot be completely corrected by simply responding to the
comments which follow_ The additional information_ needed for the
Riverside County LAFCO to make an informed and intelligent decision
in accordance with CEQA guideline, is so extensive as to justify
additional peer review by recirculating the EIR as a draft for public
review. Prior to recirculating the EIR, the issues raised in these
comments need to be fully addressed. Without the benefit of peer
review, the information presented to I,AFCO will contain many of the
flaws identified below.
Response: Comment noted. See response to comment AA. 14., above.
AA.16. Comment: Page 1-4 Project Description
The project description does not disclose that a substantial portion of the
area being considered for the proposed annexation and sphere -of -
influence amendment is currently in the city of Coachella. Rather, the
DEIR addresses the City, its 50I and land outside the SOI. While the
existing City area encompasses 31 square miles; existing SOI area
include another 2.7 square miles; the area outside the SOI encompasses
an additional 49 square miles. Clearly the preponderance of the area
reported in the DEIR is located outside the City of I,a Quinta Sphere of
Influence and yet the level of information provided for this area is
described at best, as being "broad." Perhaps a better term might be to
135
'1 4/City of La Qninta
General Plan Final EIR
Response to Comments on DEIR
describe the DEIR's description and analysis of this area outside the SOI
i5 "vague."
Response: Sec response to comment AA.9., above. The project description includes
acreage calculations for each of the areas addressed, descriptions of the
proposed land uses under the rccornmended alternative, and descriptions
of the land uses under the current County of Riverside General Plari. The
project description also includes summaries of all environmental
affected areas, and provides an extensive discussion of the issues to be
addressed in the document. It is more than adequate to meek the
requirements of CEQA.
AA.17. Comment: Page 1-9 Existing Land Uses
There is a discrepancy between the number of acres and dwelling units
disclosed in the second and third paragraphs, and those shown on Tables
I-1 and 1-2. Normally, this would be a simple mathematical error that
could be easily corrected. However, it may be indicative of a common
and critical error in this document, i.e. making incorrect mathematical
forecasts for critical issues.
Response: The commcntur is incorrect. The data provided in the discussion on page
1-9 is clearly labeled "Existing Land Uses." "Tables 1-1 and 1-2 are
clearly labeled "General Plan Recommended Alternative," under the
General Plan Land Use Summary discussion. The text and tables
referenced by the commentor, therefore, do not correlate.
Should the comrnentor wish to compare the text on page 1-9 to the
tabular summaries provided in the EIR, he should reference Table III-1,
labeled "Current General Plan."
AA.1.$. Comment: Page I-10
The second paragraph refers to the properties within the jurisdiction of
the City of Indio. It is a general description that offers an inaccurate
depiction of what exists and planned for areas critically close and
adjacent to the proposed Sphere of Influence amendment area. In
particular, existing land uses located in the two square mile area
bounded by Avenue 52 on the south, Madison and Jackson Streets on the
west and east, and Avenue 50 on the north arc oriented around major
equestrian facilities including the empire Polo Ground, the El Dorado
Polo Grounds and the Horses in the Sun (I IITS) equestrian facilities.
These land use activities are core equestrian facilities that have resulted
in the establishment of very significant equestrian investments for the
area, including new estate sized lots and housing with equestrian
136
TN/City of Lit Quinla
General Plan Final EIR
Response to Comments on DEIR
permitted accessory uses. In addition, the area immediately north of
Avenue 50 is also zoned and used for equestrian oriented single family
residential properties.
The Indio Cicricral Plan and zoning for these areas (Country Estates
Indio Ranchos zoning and Indio Ranchos Polo Estates Specific Plan)
recognize existing land uses and projects future land use policy to be an
equestrian nature_ To ignore their presence in and around this portion of
the Vista Santa Rosa community would be a disservice to both existing
and future landowners of the area; not to mention the land use
ramifications of non -equestrian properties locating nearby equestrian
oriented activities such as these. It would seem "good planning" to build
upon the equestrian orientation that is being pursued by both the City of
Indic and the Vista Santa Rose (sic) community_
Response: Comment rioted. The second paragraph on the referenced page, after
identifying lands under the City of Indio's jurisdiction, lists a number of
land trio designations, taken directly from the Indio General PIan. The
first laud use designation listed is "country estate residential," The
paragraph goes on to list a number of other land uses which occur in
Indio's jurisdiction. The paragraph provides an overview of Indio's land
use designations.
The Genera Plan places an Agricultural Overlay on the lands rcfcrenccd
by the commenlor. The overlay clearly states that existing land uses arc
permitted to continue in perpetuity, and can be developed at a density of
up to 4 units per acre if the landowner so chooses. The General Plan
does not eliminate the existing development pattern in the area, and in
fact preserves the existing lifestyle. Furthermore, lands within the
County of Riverside at the southeast corner of Avenue 50 and Jackson
are currently designated for 2 to 5 units per acre, as are lands on the
south side of Avenue 52, east of Madison Street within the existing City
limits.
A mix of densities, and the options available to land owners tc maintain
equestrian or agricultural facilities for the long term, has been identified
and addressed in the EIR.
AA.19. Comment: Page 1-12
On Table I-1, two columns of information are reported: "City of La
Quintal' and "Sphere/Planning Area." '1'hc latter column groups together
the land area currently in the City of La Quinta's Sphere of Influence
and the land area currently in the City efCoachella sphere of influence.
The table needs to he enlarged to accommodate a split of the latter
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General Plan Final EIR
Response to Comments on DEIR
category into two distinct categories for analysis to better enable the
reader the opportunity of comprehending and assessing the issue of
deleting the 19,619 acres from the Coachella SOI and placing that area
or a portion thereof into the La Quinta SDI.
Response: The comrnentar is incorrect. The area currently within the City of
Coachella Sphere of Influence represents approximately 3,200 acres, not
19,619 acres. The Table differentiates between lands within the City's
jurisdiction, and lands outside its jurisdiction. Further breakdowns are
not necessary to adequately address issues in the EIR.
AA.20. Comment: Page I-13
On Table 1-2, what is the land use buildout for the City of La Quints, the
proposed annexation arca, the sphere -of -influence amendment area, and
the remaining planning area? In the Office category as well as the
Commercial and Industrial subtotals, there are many typographical
errors which makes (sic) it difficult to distinguish the correct buildout
numbers for Office, Commercial and Industrial land uses_ What is the
correct buildout for Office? \Vhat are the correct Commercial subtotal
(sic)? What arc the correct Industrial land uses? This could be an easily
corrected simple error, However, it is indicative of a pattern of errors in
this document that includes providing incorrect information for critical
issues.
Response: There is one typographical error in Table 1-2, involving an untabbed
number in the first column on the left, under the Office category. The
numbers elsewhere in the table are correct. The conirnentor may also
review the individual categories in 'Fables 1II-3 and 111-4.
AA.21. Comment: Page I-19 and 1-20
On Tables I-d and 1-5, what are the existing land uses (not the existing
General Plan designations) for the proposed annexation area, sphere -of -
influences amendment area, and the remaining planning area? How
many acres of the proposed annexation, sphere -of -influence, and
reraining planning area are currently being used for agricultural (sic)?
Classifying their existing land uses as either "very low density or low
density" is misleading and incorrect.
Response: The discussion of surrounding land uses is contained in Section 1I-B and
Section 1 ll-A. Table III-1 on page 111-5 shows that 15,152 acres
designated Agriculture under the County General Plan are currently
developed.
138
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General Plan Final EIR
Response to Comments on DER
AA.22. Comment: Pages 1-20 and I-21
The discussion regarding residential land uses is also misleading and
incorrect. What are the existing residential land uses? Ilow many
dwelling units and residential acres are currently in the city of La
Quinta, the proposed annexation area, the sphere -of -influence
amendment area, and the remaining planning area? What information
and methodology have been used to derive the assumption of "75
percent of the maximum densities permitted"? How many acres of
"residential development" are currently being farmed or used for
agricultural (sic)?
Response: Regarding existing land uses, please see response to comment AA.21.,
above. Existing dwelling units are listed in Table 1I1-1. As regards the
residential calculations, it was assumed that 2.5% of an acre would not be
available for the construction of housing units. The assumption is made
that 25% of an acre, on average, is developed for streets, parkways and
similar facilities. The assumption was hascd on the writer's experience
with development in the Valley as a whole, and a comparison of
development trends in the City of La Quinta in particular. Regarding
land in agriculture, please see response to comment AA.21., above.
AA.23. Comment: Page 1-22 and 23
There is no mention that a portion of the area within the proposed
annexation and sphere -of -influence amendment is currently within the
sphere -of -influence for the city of Coachella, Ilow many acres of the
proposed annexation and the sphere -of -influence amendment areas are
in Coachella's existing sphere -of -influence? How many acres of
Coachella's existing sphere -of -influence are currently used for
agricultural? What is the average household size for the proposed
annexation and the sphere -of -influence amendment areas according to
the 2000 Census? What information and methodology have been used
to derive the household size of 2.75 persons per household? This is
lower than the figure used by the California Department of Finance and
SCAB_
Response: Please see responses to cornments AA.9., AA. l 1. and AA.19., above.
AA.24. Comment: Page I-25
Information provided in the first and second paragraphs regarding the
number of acres designated for Very Low Density Residential (7,089 vs.
6,280) and Low Density Residential (22,705 vs. 11,335) is not consistent
with the numbers shown on 'fable T-1. Why is there an (sic)
139
TNiCity of La Quinta
General Plan Final ER
Re$TK)nse to Comments on DEFR
discrepancy? How many acres are going be (sic) designated as Very
Low Density and Low Density Residential?
Response! `I he commentor is incorrect, The discussion on page 1-25 relates to lands
in either the Very Low Density or Low Density categories which also
have the Agricultural Overlay, The Bala provided in Table 1-1 includes
all lands in each of the two categories.
AA.25. Comment: Page I-27
Impacts on water resources are one of the many critical components in
the DEIR where impacts have been vastly underestimated, If the
population is underestimated, then water usage is underestimated. ITow
was the low household size of 2.75 persons per household derived when
the California Department of Finance and SCAG have projected
household size to be 3.2 and above? What are the assumptions and
methodologies used to curve up 2.75 household figure? How is it
determined that only 75 percent of the residential lands would have
maximum densities permitted? Ilow was the population figure of
207,970 derived? According to Table I-2, at buildout, the General Plan
will result in 78,952 dwelling units. Using the low household size of
2.75 persons per household, the population generated is 217,118
persons, not 207,970 persons as disclosed in the I]E1R. Normally, this
would be a simple mathematical error that could be easily corrected.
Ilowever, it may be indicative of a common, and critical error in this
document, that includes making incorrect mathematical forecasts for key
issues.
Response: See responses to comments AA.11., A.22., above. The paragraph
referred to by the commentor clearly describes how (he buildout
population was derived: The number of new dwelling units is multiplied
by 2.75, for a subtotal of 183,730, 183,730 is added to the existing
population of 24,240, resulting in a total population of 207,970, It would
be inappropriate to multiply the total number of units at buildout by the
2.75 household size, since the existing population is known.
AA.26. Comment: Page 11-1
What are the existing land uses (not the existing General Plan
designations) for the City of La Quinta, the proposed annexation area,
sphere -of -influence amendment area, and planning area? flow many
dwelling units and what type of dwelling units (single family vs. multi
fancily, seasonal, low income housing) in La Quinta, the proposed
annexation area, sphere -of -influence amendment area and remaining
portion of the planning area? How many square feet of commercial and
140
THt ' ty of La Quints
General Han Final EIR
Response to Comments on DER
industrial uses are in La Quinta, the proposed annexation area, sphere -
of -influence amendment area, and remainder of the planning area? How
many acres of parks and open space exist? How many acres and square
feet of public/quasi-public facilities currently exist? How are (sic) many
acres are currently in agricultural production? Why was there no
mention of the fact that a substantial portion of the area of the proposed
annexation and sphcrc-of-influence areas arc currently in the city of
Coachella's sphere -of -influence?
Response: Sec responses to comments AA,9,, AA,21. Existing and projected units
and square footage are contained in table III-1 on page 1II-5, as well as
Tables III-2,111-3, 11I-5, 111-6, III-7 and I1I-8.
AA.27. Comment: Page II-2 .E?xisting Land [.Ices
Why is there such a large discrepancy between the information provided
in the discussion of the existing land uses and the information provided
on Table I-1?
Response: The commentor is incorrect. The discussion on page II-2 refers to
existing land use and General Plan designations, while 'fable I-1 refers
to the Recommended Alternative land use plan. The discussion and
Table are therefore not directly related.
AA.28. Comment: Page I1-2 Surrounding Land I.Ises
The information provided in the DEIR is inadequate regarding
surrounding land uses in Indio and Coachella. Where are Indio and
Coachella's residential, commercial, and industrial areas in relationship
to the proposed General Plan, annexation area, and sphere -of -influence
amendment area? Where are the potential land use conflicts?
Response: See response to comment AA.1 8. Surrounding land uses are described
on pages II1-6 and III-7 for the entire planning area. Lands within and
adjacent to the annexation area are described on page 111-14-17. Lands
within and adjacent to the sphcrc of influence amendment area are
described on pages III-18-20.
AA.29. Comment: Page II-3
The DEIR downplays the fact that approximately 40 percent of the
existing area (19,938 acres) in the General Plan which is currently used
for agricultural purposes will be converted to urban development. What
are the potential land use conflicts between proposed residential
developments and existing agricultural operations? What about
141
TN/City of La Quinta
General Plan Final EIR
Ike onst� to Comments on DER
potential conflicts with surrounding equestrian properties to the north in
the City of Indio'? The close proximity to the Polo Grounds and the
Desert HITS facilities?
Response: The discussion of impacts to agricultural resources is contained in
Section III ("Existing Environmental Conditions, Project Impacts, and
Mitigation Measures" [emphasis added)), subsection B., Agricultural
Resources, pages III-2I through III-29_ This section includes discussion
of the urbanization of the area as a whole, not the impacts to specific
projects. This section clearly states that the urbanization of this area will
have a significant impact on the character of the area in the long term,
although this impact is highly dependent on the rate at which
development occurs,
Lands in the City of Indio are currently developed as polo facilities, but
are designated "Country Estates," a designation which allows up to 3.5
units per acre. Furthermore, since these polo Facilities are in RPD
overlays in the Indio General Plan, densities of 6 to 10 units to the acre
are allowed. Since the densities proposed in both the annexation area
and the sphere of influence amendment in the La Quinta General Plan
are Low Density Residential, Up to 4 units per acre, the land use
designations and ultimate huildout are Iikely to be similar.
AA.30. Comment: Page II-6
The majority of the planning area is located in a high liquefaction hazard
area. This needs to be identified in the existing setting as well as
identified as an issue of future analysis and mitigation.
Response: Paragraph 3, page 11-6 states
"Issues associated with these geotechnical conditions include ground
shaking, liquefaction, rack falls and landslides.,," (emphasis added)."
The impacts and mitigation measures associated with geological hazards
are contained on pages III-61 through III-78.
AA.31. Comment: Page II-13
Domestic Water
No mention is made of the serious groundwater overdraft situation in the
Coachella Valley or that the amount of water which is being pumped in
the Colorado River to recharge the areas is being reduced. There is also
no discussion of the subsidence caused by the groundwater overdraft
situation. There is no information provided regarding how much growth
142
TN/City of La Q iinta
General Plan Final EIR
Response to Comments on DEIR
the Coachella Valley can support in the future and whether the
development being proposed by the General Plan can be facilitated and
by what means or costs to ether existing development policies.
Response: The aommerttor is incorrect. The last sentence of the paragraph referred
to by the commentor states;
"Currently, the groundwater resource is in an overdraft condition."
Section II of the EIR provides a brief environmental setting discussion.
The complete discussion of water resources, including discussions of
recharge, growth rates and subsidence, are contained in Section 1 I [,
subsection F., pages III-87 through [II-95.
AA.32, Comment: Wastewater Treatment
No information is given as to the current capacity of wastewater
treatment facilities that will be serving the planning area and whether
they can support the additional development from the proposed General
Plan at buildout; or a phasing plan implementation.
Response: Section Ii of the FIR provides a brief environmental setting discussion.
The complete discussion of wastewater treatment is contained in Section
III, subsections F. and L, and includes description of existing and
planned facilities acid planned capacity enhancements which will double
the capacity of the Madison and Avenue 38 plant, and increase the
capacity of the Mid -Valley Reclamation Plan by 20 percent in the next
year.
AA.33. Comment: Solid Waste
No information is provided as to the capacity of the landfills that will be
servicing the planning area and whether the landfills can accommodate
projected development.
Response: Section [1 of the EIR provides a brief environmental setting discussion,
The complete discussion of solid waste is contained in Section III, pages
I11-177-1 80.
AA.34. Comment: Page III-2
The DEIR does not provide any information regarding existing land uses
within the proposed General Plan area. How many dwelling units and
type of dwelling units (single family vs. multi family, seasonal, low-
income housing, equestrian oriented) in the City of La Quinta, the
proposed annexation area, sphere -of -influence amendment area, the
143
AA.35.
Response:
Comment:
Response:
AA.36. Comment:
TN/City of La Quinta
General Plan Final E1R
Response to Comments an I)EIR
adjoining areas in the City of Indio and the remaining portion of the
planning area? What is the comparative assessment between existing
residential, current Ind use policy and what is being proposed? How
many square feet of commercial and industrial uses are in La Quinta, the
proposed annexation area, sphere-of-intluencc amendment area, and the
remainder of the planning area? What is the difference between existing
commcrciallindustrial land uses and what is proposed? How many acres
exist or are proposed for public parks and recreation areas? IIow will
General Plan buildout impact public parks and recreation areas? How
many acres and square feet of public/quasi-public facilities now exist,
and how many are proposed? How many agricultural acres will be lost
to urban development as proposed by the General Plan?
See response to comment AA.21 and AA.26., above.
Page 11I-3
How was it established that only 75 percent of the residential lands
would have maximum densities permitted? What are the methodology
and information used to substantiate the 75 percent assumption? How
did the analyst derive a 22 percent lot coverage assumption for buildout
of commercial use? What are the methodology and infonnation used to
substantiate conuncrcial lands? flow did the analyst derive. a 34 percent
lot coverage assumption for buiIdout of industrial uses? What are the
methodology and information used to substantiate the industrial lands
assumption? How do these assumptions differ from what is currently
happening in the Coachella Valley?
As regards the residential land use assumptions, see response to
continent AA.22., above. The assumptions for commercial and industrial
square footage are based on floor area ratios, the need for parking and
landscaping areas, and typical development in and around the City of La
Quinta, which results in the referenced lot coverages.
Page 111-4
Exhibit III-1 does (sic) not distinguish between Agricultural and Very
Lew Density residential land uses. According to the DEIR, 19,938 acres
currently are designated Agricultural. "There is a significant difference
between the two land uses, and this difference needs to he shown. Also,
there is no indication that the proposed annexation and sphere -of -
influence amendment areas currently are in the city of Coachella's
sphere -of -influence. In addition, there is no indication of what the
existing land uscs are for the adjacent jurisdictions affected by the
proposed General Plan. Exhibit 111-1 needs to be corrected to show the
144
TN/City of La Quinta
Gcncrai Plan Final FIR
Response to Comments on DFIR
difference between the Agricultural and Very Low Residential land uses,
Coachella's existing sphere -cif -influence, and existing land uses for
adjacent jurisdictions (cities of Indio and Coachella),
Response: Comment noted, The breakdown between Agricultural and Very Low
Density Residential requested by the comrnentor is displayed on the
following page, in Table III-1. band uses in adjacent jurisdictions are
described in Section II and Section 1I1-A. As regards the Sphere of
Influence, and has been previously stated, 3,200 acres located between
Monroe and Van Buren, Airport Boulevard and Avenue 52 are currently
in the City of Coachella Sphere of Influence.
AA.37. Comment: Page III-5
Why are there inconsistencies between Table III-1 (Current General Plan
— Land use Iiuildout Statistical Summary) and Table 1-1 and I-2? 'fable
III-1 states that there are 19,938 acres of Agriculture (1duf I ()acres), out
of which 16,132 acres are designated for urban development. Why are
there no existing dwelling units listed for these urban areas? Also, there
lacks mention in either fables I-1 or 1-2 of agricultural land, when 'fable
III clearly states that 16,132 agricultural acres are set aside for urban
development_ Thus, the sub -totals for each of the categories on Table
111-I are in conflict with those in Tables 1-1 rind 1-2.
Response: The corttmentor has misinterpreted the data. Table II1-1 represents the
land use designations under the existing general plans for the City and
surrounding jurisdictions, The Developed Acres column represents land
on which development occurs, regardless of -whether that development is
urban or agricultural_ 'Tables I-1 and I-2 represent the Recommended
Alternative statistical summary. Existing dwelling units are grouped
together for all single family and multi -family units, since the
Department of Finance does not assign units by land use designation.
The asterisks in all three referenced tables cite that item specifically.
Tables I-1 and I-2 reference the proposed land uses, and therefore do not
include the agricultural land use designation. There is no conflict
between the referenced Tables.
AA.38. Comment: Page 1 [I-10, fourth paragraph
The DEIR does not address land use impacts on adjacent jurisdictions,
which contain rural residential agricultural, and private recreational
areas. The higher residential densities and assignments proposed by the
General Plan would be incompatible with adjacent jurisdictions' land
uses and could create significant impacts.
745
Response:
AA.39. Comment:
Response:
AA.40. Comment:
Response:
AA.4I. Comment:
Response:
AA.42. Comment:
TNicity of La Quinta
General Plan Final LIR
Response to Comments on DER
Sec response to comment AA.18., above. High density residential is not
proposed adjacent to other jurisdictions anywhere in the planning area.
Page III-13
What methodology and approach have been utilized to assess land use
impacts resulting from huildout of the proposed General Plan? What
threshold of significance was used to evaluate land use impacts?
Land use impacts were reviewed based on density comparisons, built
versus vacant land, and development patterns in an area. The criteria
include quantitative analysis of existing development, surrounding land
use designations, and the location ofland on major roadways, adjacent
to public facilities or open space, etc. .Also see response to comment
AA.10., above.
Surnmary of Impact.s
No information or analysis is provided regarding land use impacts on
adjacent jurisdictions. The majority of the proposed annexation and
sphere -of -influence amendment areas currently are in agricultural use.
The proposed General Plan would designate these areas for residential
development with no transitional land to buffer the existing agricultural
operations. '[his would cause significant land use impact.
Land use impacts were not identified for adjacent jurisdictions, since the
land use pattern proposed in the General Plan is similar to that in
adjacent jurisdictions, and since the Agricultural Overlay allows the
continuation of agricultural and equestrian activities in perpetuity. Issues
associated with buffering and the interface between agricultural and non-
agricultural uses are addressed in Section 111-B, page I11-28.
Page 111-14
How many acres within the proposed annexation area currently are used
and designated as either Agricultural or Very Low Density Residential?
As stated on the referenced page, 3,782 acres are designated for
Agriculture or Very Low Density Residential currently.
Page III-15
The city of Coachella's current sphere -of -influence should be designed
on Exhibit 11I-3.
146
'IN/City of La Quintal
General Plan Final EIR
Response to Comments on DEZR
Response:
AA.43. Comment:
Response:
AA.44. Comment:
Response:
AA.45. Comment;
Response:
Comment noted.
Page 111-17
No information is provided in the DEIR identifying land uses in
jurisdictions adjacent to the proposed annexation area. The majority of
the adjacent land uses are agricultural. The proposed General Plan
would designate areas currently used for agriculture to urban
development. This could result in significant land use incompatibilities.
See response to comment AAA 8_, above.
Page III-1 R
In the proposed sphere -of -influence amendment area, the I717IR fails to
specify the number of acres currently used for agricultural, nor does it
identify land uses in _jurisdictions adjacent to the proposed amendment
area. How many acres in the proposed sphere -of -influence area support
agriculture? The proposed General Plan would change /and currently
designated for agriculture to urban use. This would result in significant
land use in incompatibilities with existing and adjacent land. Again, the
DEIR fails to mention that the proposed sphere -of -influence amendment
area currently is in the city ofCoachella's sphere -of -influence.
The corrncntor is incorrect_ Page 111-27 of the EIR states:
"Approximately 5,651 acres of the proposed SDI. area are designated for
Agriculture/Very Low Density Residential development under the
existing Riverside County General Plan.,,
See responses to comments AAA 8_, and AA.4O., above.
Page III-20
The majority of the proposed sphere -of -influence area and adjacent land
uses currently support agricultural operations. The proposed General
Plan would designate an area currently used for agriculture to urban
development. This would create significant land use incompatibilities
with existing adjacent and uses.
Comment noted. Agricultural Resources are addressed in Section III-B,
pages HT-21 through 111-24. This section discusses the direct and indirect
impacts associated with urbanization of the area. It also includes
mitigation measures, including buffer areas between these land uses. At
the hearings held by the Planning Commission and City Council in
147
TN/City of La Quints
General Plan Final .E1R
Response to comments on DEIR
September, November and December, 2001, additional zoning
standards, including right to farm provisions and notification of land
buyers was also presented, and will he incorporated into the Municipal
Code amendments which will be processed by the City after adoption of
the General Plan. In addition, the City's Transfer of Development Rights
provisions (Section 9.190) shall be considered for inclusion in the
Agricultural Overlay district, thereby providing an incentive for the
long-term preservation of agricultural parcels in the planning area.
AA.46. Comment: Page 11I-22
The DEIR states that the County Agricultural Resource Map shows a
combined total of 28,657 acres of Prime Farmland or Farmland of
Statewide Importance exist within the planning arca. This conflicts with
the 19,938 total agricultural acres presented on Table II1-3. Why is there
a discrepancy between Table II1-3 and the discussion Section of the
DE1R? llow many acres of productive agricultural land currently are in
the planning area?
Response: As stated on the referenced page, the County General Plan map
represents an over -statement of lands available t'or agriculture, since it
was prepared in 1993, and the County has since approved projects such
as the Village at the Palms, Coral 1 launtaiu Specific Plan, the Kohl
Ranch Specific Plan, and scattered residential development. in the area.
Also as stated or the referenced page, the Desert Resorts Airport is
designated prime and statewide important farmland. The County map
offers a guideline, but is inconsistent with the County land use plan.
AA.47. Comment: Page 11I-23
Williamson Act Contracts
The DE1R fails to identify parcels currently under Williamson Act
contracts. What are the proposed land uses according to th.c General
Plan?
Response: The last sentence on the referenced page states;
"There are currently a total of 5,41 1.99 acres of land under Williamson
Act contracts within the planning area." As a Program FIR, it is not
necessary to identify individual parcels. Finally, in order to receive
Williamson Act benefits, the land roust be in agriculture. The land uses
proposed under the Recommended Alternative would be Low or Very
Low Density Residential, with an Agricultural Overlay.
148
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
AA.48. Comment: Page II[-24
What were the methodology and approach taken to assess agricultural
impacts resulting from buildout of the proposed General Plan? What
was the threshold of significance for evaluating the impacts on
agricultural lands? The DEIR should utilize the LESA methodology
recommended by State Department of Resources (sic).
Response: Comment noted, Section 111-13 identifies agricultural lands both in use
and designated, The methodology used to determine the potential
impacts included analysis of Williamson Act contracts, and the ultimate
buildout of the General Plan under the Recommended Alternative. The
EIR determined that the potential impacts to agricultural resources
would be significant, even with mitigation. The LESA methodology
would be appropriate for project specific reviews, should land currently
designated Agriculture be annexed into the City.
AA.49. Comment: Agricultural Land 11sc Impacts
In Table 111-9, the DEIR stales that a total of 19,938 acres are in
agricultural production and recommends 17.615 acres be designated as
low -density residential with an agricultural overlay. What will the
remaining 2,323 acres of agricultural lands be designated:? How many
acres of State Prime Farmland or Farmland of Statewide Important
would be designated for residential land uses`? How many agricultural
acres under the Williamson Act contracts would be designated for non-
agricultural uses?
Response: The EIR states:
"The remaining 2,323 acres, which are currently designated for
Agricultural uses in the County General Plan, are not included in the
proposed Agricultural Overlay. These lands generally occur immediately
adjacent to existing City limits, and in the Coral Mountain and Kohl
Ranch Specific Plans..."
'fhc Recommended Alternative land use designations do not include an
agricultural land use designation. Therefore, all lands currently affected
by Williamson Act contracts would be assigned non-agricultural land
use designations. Lands developed in agriculture or equestrian uses in
the Agricultural Overlay will be allowed to continue as conforming uses
in perpetuity, should they be annexed,
149
TNiCity of La Quints
General. Plan Final EIR
Response to Comments on DEIR
AA.50. Comment: The DEIR fails to acknowledge that buildout of the proposed General
Plan would convert prime Farmland and Farmland of Statewide
Importance to non-agricultural uses; therefore a significant impact will
result.
Response: Page Ill-28 states:
"Even with implementation of mitigation measures, the impacts
associated with long term loss of prime agricultural lands will be
significant."
AA.5L Comment. Page III-35
What are the existing average daily traffic (ADT) volumes for the
proposed annexation, sphere -of -influence. and the remaining planning
area? No information is provided in the DE1R. Also, no information is
provided as to the existing Level of Service (LOS) and ADT for the
areas that will he affected in the adjacent jurisdictions (cities of Indio
arid Coachella). Since the adjacent jurisdictions will be affected by
General Plan traffic, existing traffic information is needed.
Response: The commcntor is incorrect. Existing volumes to capacity ratios
throughout the planning area are depicted in Exhibit III-4_ This exhibit
also includes roadways in adjacent jurisdictions. Levels of Service can
be derived from this exhibit by using the data in Table I11-10.
AA.52. Comment: Page III- w6
Where are the routes for public transit services? What is the existing
rider ship for public transit service? How many trains provide passenger
service? Where is the train station in Coachella Valley, and how far is it
from the proposed planning area?
Response; Public transit routes and the availability of a train platform in Indio are
described on page III-36. Ridership of routes operated by SunLine vary
from Line to Line. SunLine adds buses to lines which are heavily
traveled. In addition, another train platform is located in Palm Springs.
The vast majority of trains passing through the Valley carry freight.
AA.33. Comment: Page I11-37
Are there bicycle and pedestrian facilities in La Quinta and the proposed
General Plan area? If so, where are they located? Are there any plans
for bicycle and pedestrian facilities? Are provisions made for electric
golf carts?
15D
TN/City of La Quints
General Plan Final ElR
Response to Commerns on DELR
Response: Bicycle and pedestrian facilities are described on page III-37. Trails of
all types, both existing and proposed, are depicted in Exhibit 111-!0 of
the General Plan. .An extensive discussion of the City's proposed golf
cart plan is included in the EIR, on pages 11I-44 through III-48,
AA.54. Comment: Page 1ll-38
What methodology and approach have been utilized to assess traffic and
circulation impacts resulting from General Plan buildout? What are the
thresholds of significance for determining whether traffic impacts are
significant?
Response: The methodology used is summarized in the EIR, page 111-38, under the
heading "La Quinta General Plan Transportation Model." A complete
description of the model is included in Appendix F of the EIR. Levels of
Service and volume to capacity ratios, and the City's policies regarding
acceptable LOS, are used to determine significance,
AA.55. Comment: Page III-39
Level -of -Service on Roadway Segments
How many segments have a volume -to -capacity (WC) ratio between
0.91 and 0.99? Where are those segments located? Are there any
segments with a V/C ratio between 0.91 and 0.99 located in the adjacent
jurisdictions?
Response: As stated on the referenced page, volume to capacity ratios are
illustrated an Exhibit 111-7. Monroe Street, north of Mile Avenue, is
depicted as having a VIC ratio of (.92. Harrison Street, north of Avenue
54, is depicted to have a We ratio of 0.91.
AA.56. Comment; Page III-40
What assumptions have been used for the traffic model? What
assumptions were made regarding access to network roadways and
actual impacts to capacity?
Responses Assumptions are summarized in the EIR, and included in their entirety
in Appendix F of the EIR.
151
TN/City of La Quinta
General Plan Final EIR
Res ore to Comments on DEIR
AA.57. Comment: Page I1I-43
Intersection Analysis
Which intersections located in adjacent jurisdictions will be impacted by
traffic associated with General Plan builduut? Which intersections in
Table III-14 are located in adjacent jurisdictions? The most direct lines
of access from the proposed Sphere of Influence Amendment area and
the 1-113 freeway or Highway 111 are via Jefferson, Madison (along an
uncompleted segment to the north), Monroe, Jackson, Calhoun .ind Van
Buren. It is the City of Indio's contention that the addition of upwards
of 80,000 new dwelling utnits will have significant impacts upon these
and connecting roadwayslintersections and will require mitigation if
better alternatives are not pursued,
Response: tvfitigation measures, including the recommended roadway
classifications and cross -sections, are included in the EIR, pages III-48
through 111-62. Since the CVATS model was used as the basis for the
model, and the City of Indio participates in CVATS, the data provided
by Indio to the Coachella Valley Association of Governments regarding
roadway classifications within its jurisdiction are included in the model,
and therefore reflected iri the E1R and Appendix F.
AA.58. Comment: Summary of Roadway Impacts
What are the ADT volumes projected to result from buildout of the
Recommended land Use alternative, and how will volumes affect
circulation systems in adjacent jurisdictions? Your traffic analysis must
identify the roadway segments in the adjacent jurisdictions that will
likely operate with volumes exceeding their design capacities? And
mitigation of such impacts is required.
Response: Roadway segments expected to exceed capacity arc shown in Table 111-
13, page III-40, Post-2020 volumes throughout the region are illustrated
on Exhibit I1I-7, page 111-42. Levels of service at major intersections are
listed in "table III-14, page ill-43. Mitigation measures are listed on
pages 1II-48 through 1I1-6D.,
AA.59. Comment: It oadwav Classifications
What are the existing roadway classifications and do they differ from
those proposed? How do the proposed roadway classifications
correspond to existing roadway classifications of adjacent jurisdictions?
152
Response:
AA.60. Comment:
Response:
AA.61. Comment:
Response:
AA.62. Comment:
Response:
AA.63. Comment:
Response:
TNIC ity of La Quinsy
General Plan Final FIR
Respnnsc to Comments on DF.UR
Roadway classifications are depictcd in Exhibit 1II-11, and illustrated in
Exhibit III-12. There are no significant changes to the roadway
classifications in the 1992 General Plan.
Page III-58
Which mitigation measures address traffic impacts on adjacent
jurisdictions?
The mitigation measures involving outside agencies name those
agencies when necessary. These include mitigation measure 13,, and
mitigation monitoring program C.
Page 111-72
Pro'ect Impacts
What methodology and approach were used to assess soils and
geological impacts resulting from the proposed General Plan? What
thresholds of significance were used to determine whether impact (sic)
on soils and geological (sic) are significant?
As cited on page 1I1-61, the Soils and Geology section of the EIR is
based on the Technical Background Report contained in Appendix (i of
the FAR. 1'he standards utilized in the analysis are summarized in the
FIR and described in their entirety in Appendix [l.
Page III-74
What are the wind erosion and blowsand impacts resulting from the
construction activities associated with General Plan implementation?
Wind erosion impacts are discussed on page 11I-72, third and fourth
paragraphs.
Page III-75
What assumptions have been used to determine that no substantial
amount of development will occur within the proposed annexation and
sphere -of -influence areas in the near future?
Both the Annexation arca and the SOI include a majority of lands which
are developed (77% in the Annexation area, and 84% in the SGI). Since
General Plan policies provide for the preservation of existing
agricultural and equestrian facilities, and since those land owners have
153
IN/City of La Quinta
General Plan Final EIR
Rcspons❑ to Comments on DE1R
vociferously expressed their wish to maintain their properties in their
current condition at numerous public hearings on the General Plan, it is
reasonable to assume that substantial development is unlikely.
AA.64, Comment: Page III-84
What methodology and approach were used to assess impacts on storm
water run-off and flooding? What thresholds of significance were used
to determine whether the proposed project would have significant
impacts on hydrology? What are the storm water and flooding impacts
resulting from the buildout of the proposed General Plan en adjacent
jurisdictions (the cities of Indio and Coachella)? What mitigation
measures will be taken to reduce Storm water and flooding impacts on
the adjacent jurisdictions?
.Response: The Technical Background Report contained in Appendix G provides
methodology for the development of the Hydrology section of the EIR.
The City currently requires that projects retain 100 year storms on -site.
Further, the City maintains a master plan of drainage, to which all
projects must conform. These standards, combined with the mitigation
measures contained in the EIR, are designed to reduce potential impacts
within the City and on adjacent properties which may occur in another
jurisdiction.
AA.65. Comment: Page 111-91
What methodology and approach were used to assess impacts on
groundwater resource in the Coachella Valley? What are the thresholds
of significance used to determine whether the proposed project would
have a significant impact on groundwater resources? What is the basis
for the assumption of a 23 percent increase in commercial lands and a 43
percent increases for industrial lands stated in the DEIR.
Response: The sources of data in the Water Resources section of the EIR are cited
in the document, and rely on documentation prepared by the Coachella
Valley Water District. The methodology used to calculate the impact of
General Plan buildout on water resources is described and detailed on
page III-92, The increase in commercial and industrial development is
cited in the document as "compared to the current General Plan," and is
primarily due to the increased planning area being studied in the
Recommended Alternative.
AA.66. Comment: The DFIR assumes a low household size which undcrestimatcs water
consumption impacts. This is especially apparent in the impact analysis
for public services and utilities. The DEIR uses 2.75 persons per
]54
Response.
AA.67. Comment.
Response:
AA.68. Comment:
Response:
TN/City of La (uinta
General Plan Final EIR
Response to Comments on DEIR
household to determine impact. This number is considerably lower than
the household size figures used by the California Department of Finance
(3.263 persons per household) and the Southern California Association
of Governments (3.24 persons per household in 2005 and 3.14 persons
per household in 2020). The DEIR should be revised to reflect these
updated household size assumptions to analyze water consumption and
impact on groundwater resources resulting from the buildout of the
proposed General Plan.
See response to comment AA.] l ., above. Since the household Nice used
is reflective of current conditions in the planning area, rather than
statistical assumptions made by SCAGr for other jurisdictions, it is an
appropriate figure to usc. There is no need to revise the calculations in
the OR_
There is no impact analysis for the increase in water consumption of
commercial and industrial land uses resulting from buildout.
The comrncntor is incorrect_ Paragraph three of page III-92 states:
-The Coachella Valley Water District estimates that domestic water
demand in its urban service area is approximately 550 gallons per day
(gpd) per capita. This is an aggregate figure that accounts for all water
uses in the community, including residential, commercial, industrial,
golf course, irrigation and other uses, and is not intended iu represent a
specific land use such as residential uses. This factor is used in the
following analysis because it best reflects local water consumption
conditions,"
Page III-11 l
What methodology and approach were used to assess impact on
biological resources resulting from the buildout of the proposed General
Plan? What thresholds of significance establish criteria to determine
whether the proposed project would have significant impacts on
biological resources? Would the urban development proposed by the
General Plan affect biological resources in adjacent jurisdictions?
The Biological Resource section of the EIR is based on the assessment
prepared by Dr. L. I.aPre, which is summarized in the EIR and included
in its entirety in Appendix C oFthe document_ The methodology follows
the requirements and standards established in the Endangered Species
Act and the California Endangered Species Act, the most broadly
accepted standards for biological resources.
r5s
1'N!C4 of La Quirna
Genera] Plan Final MR
Response to Comments on DE,1R
The General Plan includes policies and programs which address
individual species of concern which occur in the planning area, and
provide for additional study as development occurs, In addition, the
General Plan provides the Ilillside Overlay for all properties above the
toe of slope, which significantly limits the potential for development in
the Santa Rosa and Coral Reef mountains.
AA.69. Comment: Page III-120
Where (sic) historic resources exist within the planning area' Which
historic sites area on the State and National Registers? Are there any
local historic resources?
Response: Historic resources arc generally mapped on Exhibit 9.1 of the General
Plan. A description of historic resources is included on page III-120 of
the EIR. Sites of state, federal or local significance are listed can page
III-120_ Sites of local significance are also listed Oil this page.
AA.70. Comment: Page III-121
What methodology and approach were employed to assess impact on
historic resources resulting from (general Plan buildout? What arc the
thresholds of significance used to determine whether the proposed
project would have significant impacts on historic resources? Which
historic resource would he affected:
Response: `1 he Cultural Resources section of the EIR is based on the cultural
resource study prepared by CRlvi Tech for the General Plan update, and
included in its entirety in Appendix B of the PAR. Impacts were assessed
based on CEQA section 15 64.5, which directly addresses impacts to
cultural resources.
AA.7L. Comment; Page III-132
What methodology and approach were used to assess air quality impacts
resulting from the buildout? What thresholds of significance have been
used to determine whether the proposed project would have significant
air quality impacts?
Response: As stated in the EIR, all calculations relating to air quality are based on
models developed by the South Coast Air Quality Management District
(SCAQMD), which has jurisdiction over the Coachella Valley. All
SCAQMD thresholds are included in the tables.
156
TN/City of La Ouinta
General Plan F[nal E1R
Response to Comments an DEIR
AA.72. Comment: Page III-138
What assumptions and information were used to determine the average
trip length?
Response: The average trip length of 3 miles is based on buildout of the
community, and assumptions made regarding typical distances in the
area to work, shopping, school and recreation.
AA.73. Comment: Page ] II-139
What are the air quality impacts on adjacent jurisdictions? Are there any
sensitive land uses within the adjacent jurisdictions which will be
affected by carbon monoxide hot spots?
Response: Air quality is by definition regional. The significance of the impacts is
defined by regionally established criteria The air quality impacts
associated with buildout of the General Plan are likely to be similar to
those associated with buildout of adjacent jurisdictions, since the land
uses proposed do not vary significantly from the development pattern
currently occurring in the area. Whether a specific sensitive receptor in
another jurisdiction will be affected by buildout of the cities of Indio and
Coachella is dependent on the trip generation on any given street. The
traffic and circulation states that no intersection will operate at a level of
service below D. This represents an acceptable level, and limits the
potential for carbon monoxide hot spats. Individual projects will
continue to be reviewed for air duality impacts through buildout of the
General Plan, and their impacts will be assessed as they occur.
AA.74. Comment: Page IIi-14]
What air quality impacts on adjacent jurisdictions will result from
buildout within the proposed annexation and sphere -of -influence
amendments areas?
Response: See response to comment AA.73,, above.
AA.75. Comment: Page III-149
Which computerized noise model was used and what were the
assumptions? What arc the thresholds of significance used to determine
whether the buildout would have a significant noise impact? where are
the sensitive receptors? Are there any noise -sensitive land uses in the
adjacent jurisdictions which will be affected by development?
157
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
Respunse: The description of the noise modeling for the proposed General Plan
Update is provided in Appendix E of the EIR, including locations of
modeled sensitive receptors. Residential units constructed on lands
adjacent to major roadways in the City or planning arca will be impacted
by noise, as stated in the EIR. The EIR, however, also provides a
number of mitigation measures which effectively lower the potential
impacts of noise. Individual noise analysis for projects in the future will
be required whether in the City or in an adjoining jurisdiction, if that
jurisdiction as a lead agency, determines that noise analysis is
necessary.
AA.76. Comment: Page III-151
What was the basis for the assumptions regarding train trips and aircraft
operations? What impact will the future train trips and aircraft
operations havc on proposed urban development? What assumptions
were made regarding noise impacts generated from commercial and
industrial development? How were noise impacts assessed? Where are
sensitive receptors in relationship to planned commercial and industrial
development?
Response: Assumptions regarding trains trips ,aircraft operations and commercial
and industrial development are contained in Appendix E of the EIR.
Impacts of those activities are summarized on pages Ill-51 through III-
54, and contained in their entirety in the Appendix. The assumptions are
based on growth projections provided by the rail and airport operators,
respectively. Also see response to comment AA.75., above.
AA.77. Comment: Page III-1 a5
What are the nuise impacts on sensitive uses in adjacent jurisdictions
resulting from buildout within the proposed annexation and sphere -of -
influence areas?
Response: Noise impacts in the annexation and SOI areas are described on pages
ill-155 and III-156 of the EIR. Detailed modeling information is
contained in Appendix E of the LIR.
AA.78. Comment: Page III-160
What methodology and approach were utilized to assess visual impacts?
What thresholds of significance were used to determine whether the
General Plan would have significant impacts on visual resources? Are
there any view corridors that will be affected by proposed development?
[58
TN/City of La Quint
General Plan Final E.1R
Response to Comments on DI;IR
Will scenic views from surrounding areas be affected by the proposed
urban development?
Response: The visually valuable resources in the City and planning arca are
described on pages 1II-159 and III-160, The potential for view blockage
of the mountains is the primary issue associated with huiIdout of the
General Plan. There are no designated scenic corridors in the City.
Impacts to resources are described on pages 1I1-I60 through III-162,
4A.79. Comment: Page III-162
"1'he urban development proposed within the annexation and sphere -of -
influence areas are not consistent with the rural, agricultural and open
space land uses of the existing General Plan designations. The DEIR
needs to be revised to reflect this.
Also, the proposed urban development designations in the annexation
and sphere -of -influence areas will be in direct contrast with the adjacent
scenic rural open spaces and will impact visual resources and view
corridors.
Response: The land uses proposed in the General Plan are described in Section III -
A of the EIR. The impacts expected due to buildout of these land uses
are also described in section III -A. Regarding impacts to surrounding
areas, see response to comment A1,78,, above.
AA.fiO. Comment: Page Ili- 166
According to Table I-2, the number of dwelling units resulting from
buildout is 78.952 units, not the 66,811 units reported here. The school
enrollment analysis should he revised. The breakdown between single
family and multi -family is different than the one used in the air quality
analysis (Table 111-24). What is the proposed capacity of the Mountain
Vista Elementary School and how will it ease the elementary student
overcrowding which will result from the buildout of the proposed
{ieneral Plan? "fife average persons per household size is increasing.
How will this affect the methodology and approach (student generation
rates) taken to assess school enrollment impacts resulting from the
buildout? What thresholds of significance are used to determine
whether buildout would have significant impacts on school facilities?
What are the specific student enrollment impacts on the Desert Sands
Unified School District? On the Coachella Valley Unified School
District?
Response: The comtrtenlor is incorrect. The EIR states:
159
TN/City of La Quir to
General Plan Final EIR
Response to Comments on DER
"Buildout of the proposed General Plan is expected to result in the
construction of approximately 66,811 dwelling units..." (emphasis
added).
The existing dwelling units in the City and planning area already have
their children enrolled in schools in the area. Those numbers are
reflected in Tables 1[I-32 and III-33, Table 111-34 represents the total
school enrollment potential, including existing units, As regards Table
111-24, there is no discrepancy. The numbers used in '['able II1-24 are
identical to those used in Table III.34.
Mountain -View Elementary School has opened since the release and
distribution of the EIR. Its capacity is 700 students. It has a current
enrollment of 508 students. The school therefore provides an additional
700 students with school space.
Average household size is actually decreasing in most statistical models,
as the population in the area gets older. As stated by the comrnentor in
comment AA.11, SCAG projects a decrease in household size by 2020.
All calculations in this section of the FIR use thresholds adopted by the
school districts themselves, as cited in the document.
Enrollment impacts to the two districts will vary based can development
patterns in the planning area. Since a large portion of the planning area
occurs cast of Jefferson (the boundary between the two districts), the
majority of enrollment is expected to occur within the Coachella Valley
Unified School District. Impacts to schools have been mitigated by the
payment of Ices by developers for all types of development. This state-
wide program is expected to stay in effect, and to continue to provide
mitigation for the impacts associated with General Plan buildout.
AA.81. Comment: Page III-170
The DE1R uses a low household size figure and therefore underestimates
impact can library facilities, The DEIR uses 2,75 persons per household
to determine the impacts. This number is considerably lower than the
household size figures used by the California Department of Finance
(3.263 persons per household) and the Southern California Association
of Governments (3.24 persons per household in 2005 and 3.14 persons
per household in 2020). The DEIR should be revised to reflect a current
household size figure in analyzing public services. Also, what
methodology and approach were used to evaluate impact on library
services and facilities? What are the thresholds of significance used to
160
TI JCtty of La Quinta
General. Plan Final FIR
Rospcnse to Comments on DEIR
determine whether the project would have significant impacts on
libraries?
Response: As regards household size, please see response to comment AA.11.,
above. The estimates are representative of the anticipated need. The
methodology and assumptions made to calculate impacts to libraries are
described on page III-170.
AA,82. Comment: Page 111-172
The DEIR should be revised to reflect a current household size figure to
analyze impact on police protection services. Also, what methodology
and approach are used to assess impacts on police protection services
resulting from the buiidout of the proposed General Plan'? What arc the
thresholds of significance used to determine whether there would be
significant impact on police protection services?
Response: As regards household size, please see response to comment AA,I1.,
above. The estimates are representative of the anticipated need. The
methodulugy and assumptions made to calculate impacts to police
services are described on page I11-172.
AA.83. Comment: Page III-174
What methodology and approach were used to assess impact on fire
protection services? What are the thresholds of significance used to
determine whether there were significant impacts? Which fire agency
currently serves the amendment and sphere -of -influence areas? Are fire
stations planned for the proposed General Plan area? If so, where?
Response: The assumptions made to determine impacts to firc services are
described on page I11-174. As stated on page 111-173 "fire protection is
provided to the City of La Quinta and its planning area by the Riverside
County Fire Department." The General Plan also establishes a guideline
of one firefighter per 1000 population. This standard is used as the
criteria by which impacts are judged.
A fire station has been planned since the publication of the EIR. It will
be located at Mile 11vetre and Adams Street, within existing City limits,
The City is currently acquiring the land, and public hearings on the
project are scheduled for March before the City Council.
1.61
1NiCity of La Quints
General Plan Final EIR
Response to Comments on DF.TR
AA.S4. Comment: Pagc II1-175
What methodology and approach were used to assess impacts on health
care facilities and services? What thresholds of significance were used
to determine whether there would be significant impacts? Are any public
health facilities planned to meet the increased population?
Response: The assumptions made to determine impacts to health care services are
described on page 1II-176. I -Health care, as stated in the document, is
operated by private companies, who will address the need for additional
services as market forces make that necessary.
AA.85. Comment: Page 111-177
Where are existing solid waste facilities in relation to the proposed
annexation and sphere -of -influence amendment areas, and what are the
landfill capacities and closure dates? How much solid waste is currently
generated'? How much solid waste will be generated in the future?
What methodology and approach were used to assess solid waste
impacts? What thresholds of significance were used to determine
whether there would be significant impacts? It is unrealistic to assume
that the buildout pursuant to the proposed General Plan (19,137.651
square feet of commercial and 28,835,849 square feet of industrial) will
not result in any hazardous waste generation.
Response: The locations, capacities, daily tonnage and closure dates of existing
landfills is described on page I11-177. The methodology used in the Ell
is cited in footnote #71.
The cornmentor has misread the document. The EIR does not state that
buildout will not result in any hazardous waste generation. As stated in
the General Plan, the City currently is home to small-scale generators of
hazardous waste, such as gasoline service stations, dry cleaners and
medical facilities. The General Plan also states that this pattern is
expected to continue. The General Plan specifically calls for the
development of Light Industrial land uses, and does not allow heavy
industry, which would be a more likely source for hazardous waste
generation.
AA.86. Comment: Page III-181
What is the service area for the existing sewage treatment plant? How
ranch wastewater will be generated within the project area? What
methodology and approach were used to assess wastewater impacts?
162
MUCity of La Quint
General Plan _Final EIR
Respor1se to Comments cm DEER
What thresholds of significance were used to determine whether
significant impacts wou]d result?
Response: The service areas and assumptions for the sewage treatment plants are
described on page III-181 and III-182. The usage rates developed by
G'WI, and the data provided by that agency were used to determine
the level of impacts associated with buildout of the General PIan.
E1A.87. Comment: Page III-183
The DE1R uses a low household size to estimate water usage and
therefore underestimates the impacts on domestic water service. (Sec
prior discussion), The DEIR should be revised to reflect an updated
average household size to analyze impacts on domestic water services.
What methodology and approach were used to assess domestic water
service impacts? What thresholds of significance were used to determine
whether significant impacts result? What impacts occur due to
development in the proposed annexation and sphere -of -influence
amendment areas?
Response: See responses to comments AA.11. and AA.25_, above. The usage rates
developed by CVWD, and the data provided by that agency were used to
determine the level of impacts associated with buildout of the General
Plan,
AA,S8. Comment: Page ill-] 86
What methodology and approach were utilized to assess electrical
service impacts? What thresholds of significance were used to determine
whether significant impacts will result?
Response: The assumptions are described on page 111-186. The usage rates
developed by Southern California Edison are included in this section,
and are used to determine the potential impacts associated with buildout
ofthe General Plan.
AA.89. Comment: What methodology and approach are taken to assess natural gas service
impacts resulting from the buildout ofthe proposed General Plan? What
are the thresholds of significance used to determine whether there were
significant impacts resulting from the buildout of the Proposed General
Plan on natural gas services? What are the impacts from the proposed
annexation and sphere -of -influence amendment? What impact will this
have on the adjacent jurisdictions?
163
TNfCity of La Quin#a
General Plan Final EIR
Response to Comments on DEIR
Response: The methodology is described on page [ [1-189. Impacts from the
Annexation area and SO1 are described on page III-189. The usage rates
developed by The Gas Company are included in this section, and are
used to determine the potential impacts associated with buildout of the
General Plan,
AA.90, Comment: Page 111-190
What methodology and approach were used to assess cable service
impacts? What thresholds of significance were used to determine
whether significant impacts will result?
Response: The methodology is described on page III- L 90. The ability of the cable
company to expand services as development occurs was used asthe
determining factor in assessing impacts associated with buildout of the
General Plan,
AA,91. Comment: Page III-198
The DE-IR uses a low household size assumption to assess public service
impacts (see previous discussion) and therefore underestimates impact.
The DEIR should be revised to reflect an updated household size
assumption to analyze impacts on public services.
Response: See response to comment AA.11., above.
AA.92. Comment: Page IV-1
Is the loss 426,312 acres of Prime Farmland considered an unavoidable
significant impact?
Response: Section III of the EIR states that the buildout of the General Plan will
result in unmitigated impacts on Agricultural Resources. The discussion
was omitted in error in Section IV. The following text is hereby added to
page 1V-1:
Agricultural Resources
As described above, the existing General Plan designates a total of
19,938 acres for Agricultural development. 1t is difficult to anticipate
whether and to what extent these lands would actually be converted to
residential uses in the future, as the decision to do so will be left to
individual landowners. Due to the application of the Agricultural
Overlay, implementation of the Recommended General Plan will not
directly result in the conversion of prime .farmland or farmland of
statewide importance to residential uses, but it will provide an
16
TN,'City of La Quii.ta
General Plan Final EIR
Response to Comments an DEIR
AA.93. Comment:
Response:
AA,94. Comment:
Response:
AA.95. Comment:
opportunity for this conversion to take place without requiring a 3icneral
Plan or zoning arnendment or other administrative approval. Similarly,
for lands covered by the Agricultural Overlay, the Recommended
General Plan will not directly cause the cancellation of any contract
made pursuant to the Williamson Act, but it could provide the ability for
landowners to cancel their contracts if they choose to develop,
Implementation of the Recommended Land Use Plan and Annexation
No, 12 could result in the conversion of prune farmland and farmland of
statewide importance to urban land uses, and could result in the
decisions by property owners to not renew Williamson Act contracts on
lands in the easterly portion of the planning area. Even with
implementation of mitigation measures, the impacts associated with long
term loss of prime agricultural lands will be significant.
Page V-1
The "More Intense" Alternative should not he considered in the DEIR
since alternative does not comply with CEQA regulations by reducing or
eliminating environmental impacts, With the "More Intense"
Alternative eliminated from consideration. the DEIR does not present an
adequate range of reasonable alternative to meet CEQA requirements,
See response to comment AA.12,, above.
Page V-13
What impacts to existing agricultural resources result from a "No
Project" Alternative? What are the impacts of the "No Project"
Alternative en land uses within the adjacent Jurisdictions?
Impacts to agricultural resources under the No Project alternative are
described on page V-3. Under the County jurisdiction currently in effect,
the land owners who have agricultural land uses on their properties have
the ability to change that land use al any time through a General Plan
Amendment and Change of Zone. As previously staled, the land uses in
adjacent jurisdictions arc similar to those proposed in the General Plan.
impacts to surrounding jurisdictions' land uses will not vary
significantly for any of the alternatives.
Page V-14
Under CEQA regulations, Alternative I: More Intense Development
should not be considered as an alternative in the DEIR because it does
riot reduce or eliminate any significant environmental impacts. lender
k5
Response:
AA.96 Comment:
Response:
&A.97. Comment:
Response:
AA.9I. Comment:
TN/City of La Quints
General Plan Final ElR
Response to Comments on DEIR
alternative II: Less Intensive Development Scenario, what are the
impacts to existing agricultural resources? How many acres of Prime
Farmland would be converted to urban land uses? How does the Less
Intense Alternative impact land use in adjacent jurisdictions? How
would the land use impacts associated with the project differ from No
Project and Less Intense Development Alternatives? Ilow would land
use impacts on adjacent jurisdictions differ between the No Project and
Less Intense Development alternatives?
Scc response to comment AA.12. and AA.94., above.
Table V-3 illustrates that 5594 acres would he converted to Very Low
Density residential, up to 2 units per acre. That acreage is currently
farmland. Comparisons of each alternative is provided categorically for
each issue area on pages V-13 through V-36.
Page V-16
What traffic impacts in adjacent jurisdictions (circulation and
intersections) result from the No ProjectAlternative?
Impacts from the No Project Alternative are illustrated in Table V-4 on
page V-17.
Page V-17
tinder Alternative II: Less intensive Development Scenario (Table V-4),
the traffic impacts are greater than the proposed project. Flow does the
Less Intense Alternative impact circulation and intersections in adjacent
jurisdictions? How would traffic impacts differ from No Project and
Less Intense Development Alternatives? How would traffic and
circulation impacts on adjacent jurisdictions differ among the
alternatives?
The differences between alternatives is sumrnarized on page V-17. The
complete analysis is included in Appendix F.
Page V-] S
The DEIR does not provide adequate information to compare the
relative impacts with respect to soils and geology. How would project
differ from the No Project and Less Intense Development Alternatives?
166
`1 N.{City of La Quinta
General Plan Final EIR
Response to Comments on DEMR
Response: "'he comparison is provided on page V-18. The analysis clearly shows
that all alternatives result in similar impacts, and that all alternatives will
require individual project analyses in the future.
AA.99.. Comment: Page V-19
The DEM. does not provide adequate information to compare the
relative impacts on hydrological systems among the alternatives. How
do the No Project and Less Intense Development Alternatives affect
flooding in adjacent jurisdictions?
Response: The comparison is provided on page V-19. The analysis clearly shows
that all alternatives result in similar impacts, and that all alternatives will
require individual project analyses in the future.
AA.100, Comment; Page V-20
The 1)EIR does not provide the quantitative information necessary to
analyze potential water quality and resources impacts for the
alternatives. What assumptions were used for the population
projections? Will groundwater overdraft or water quality impacts result
from the No Project and Less Intense Development Alternatives both
within the project area and regionally?
Response: The comparison is provided on page V-20. The assumptions are listed
on that page also. Groundwater overdraft will have a lesser impact under
both the No Project and Less Intense alternatives, insofar as both these
alternatives result in lower water usage. However, since overdraft
currently occurs and will continue to occur with additional development,
overdraft conditions will occur in all alternatives. Water quality impacts
under all alternatives are discussed on page V-21.
AA.101. Comment: Page V-22
The DEIR does not provide sufficient information to enable comparison
of the potential biological resource impacts among the alternatives.
Weld (sic) the No Project and Less Intense Development Alternatives
impact biological resources in adjacent jurisdictions'? How do impacts
associated with the project compare to the No Project and Less Intense
Development alternatives both locally and regionally?
Response: The comparison is provided on page V-22.
1
TN/City of La Quints
General Plan Final Ell/
Response to Comments on D.EM
AA.102. Comment:
Response:
AA.103. Comment:
Response:
AA.194. Comment:
Response:
AA.105. Comrncnt:
Response:
AA.106.Comment;
Page V-22
The DEW provides no information to enable comparison of potential
cultural resources impacts among the alternatives. Will the No Project
and Less Intense Development Alternatives impact cultural resources in
adjacent jurisdictions? How do air quality (sic) impacts compare to
impact (sic) from No Project and Lcss Intense Development alternatives
both locally and regionally?
The comparison is provided on page V-23.
Page V-23
How might the No Project and Less Intense Development Alternatives
affect air quality in the adjacent jurisdictions? How do project air
quality compare to impacts from the No Project and Lcss intense
Development Alternatives booth locally and regionally?
'the comparison is provided on pages V-23 through V-25.
Page V-25
How might traffic noise associated with the No Project and Lcss Intense
Development Alternatives impact adjacent jurisdictions? How do noise
impacts compare between the alternatives?
The comparison is summarized on page V-26. The full analysis is
included in Appendix E.
Page V-27
What arc the regional visual resource impacts associated with the No
Project and Lcss Intense Development Alternatives? How do visual
impacts compare between the alternatives?
The comparison is provided on pages V-28 and V-29
Page V-29
Thu DEIR underestimates the public services and utilities impacts
because the analysis utilizes a low average household size of 2.75
persons per household. As discussed above, the California Department
of Finance and SCAG project a larger avenge household size, at least
3.2 and above. TIIie public services impacts of the alternatives should be
re -analyzed using this updated household size. flow would the public
168
Response:
AA.107. Comment:
.Response:
AA.10S. Comment:
Response;
AA.109. Comment:
Response:
AA.110. Comment:
TN/City of La Quinta
General Plan Final EIR
Response to Comments on MEIR
s rvicc impacts differ from the No Project and Less Intense
Development Alternatives both locally and regionally?
See comment AA.12., above_ The comparisons are provided
categorically throughout this section, on pages V-28 through V-36.
Page VII-1
Prime farmland is considered a non-renewable environmental resource.
The DF,IR should state that Prime Farmland will be permanently lost due
to implementation of the proposed General Plan.
Comment noted. Agricultural resources is hereby added to paragraph 2
on page VII-1, as follows:
"The loss of prime farmland to development will represent a permanent
significant loss of a non-renewable resource."
Page VIII-1
}low do the growth -inducing impacts of the proposed General Plan
impact adjacent jurisdictions' agricultural resources?
That description is provided on page VIII-1 and VIIE-2.
Page VIII-2
The DEIR underestimates the cumulative impacts by using a figure of
2.75 persons per household (see discussion above). The DEIR lacks
consistent application of the cumulative impact analysis, especially as it
pertains to the proposed annexation and sphere -of -influence amendment.
Buildout of the proposed General Plan, together with development
within the proposed annexation and sphere -of -influence areas, would
have a significant cumulative impact on the adjacent jurisdictions.
Comment noted. See response to comment AA_ 12., above.
In conclusion, the environmental analysis contained in the DEIR
exhibits significant flaws. The analysis substantially underestimates the
type and severity of significant impacts associated with the buildout of
the proposed General Plan and within the annexation, and sphere -of -
influence amendment areas, Because of inconsistencies in the document
and the underestimation of impacts, the DEIR requires substantial
reworking to comply with CEQA and also requires recirculation. In
particular, a thorough analysis of impacts on the cities of Indio and
169
TMICity of La Quints
General Flan Final E1R
Response to Comments on DEIR
Coachella associated with the proposed annexation and the sphere -of -
influence amendment are critical.
Response: The City cf La Quinta's responses to City of lndio's comments is set
forth above in response to comments AA.1—AA.109.
170
TN/City of La Quinta
General Plan Final EIR
Response to Comments on DEIR
SECTION II
COMMENT LETTERS
ON THE
DRAFT ENVIRONMENTAL IMPACT REPORT
The following comment letters were received on the Draft EIR transmitted to various public
agencies and interested parties. Comments restated in Section 1 are bracketed in this section and
correspond to the continent numbers in Section I.
LSIAaLISHEW IN 19111. AS A PUBLIC AGENCY
COACHELLA VALLEY WATER DISTRICT
POST OFFICE EIDX 105d • COACHELLA, CAL]FQRNIA 92236 ■TELFPHONE (760; 39E1-2851
CIRECTDRS
J01'.N w, McrACDEN. PRESIDENT
FL1 SEI L F,TAtiARA, v10E pR:510EN1
TE'LL]S COCE1;i45
PATH•CIR A. LARSON
PETER NELSON
Fred Baker
Principle Planner
City of La Quinta
78-495 Calk Tampico
La Quinta, California 92253
Dear Mr, Baker:
August 1, 200]
OFFICERS
TFIO.Lr.S E. LEVY, GENERAL MJINAGEP-GRIEF ENGINEER
3ERNARDIN; SUTTON, SECRETARY
SIEVEN D. ROBE'NS. AESISTAfiT TO GENERAL hIRNADEI]
AEDAINE AND SHeRRILL. AITORNE'+'S
File: 1150.14
Subject' Draft Environmental Impact Report for the
La Quinta General Plan, Annexation No. 12
and St:ihere of Influence Amer,dmenl
This is in response to your transmittal and request for comments for the above -referenced
document dated July 13. We appreciate the opportunity to respond to this document. The
proposed ?nmcxation and sphere of influence amendments are within our service area. Future
development ).vithirl the subject area will most likely affect all five types of facilities:
domestic water, sanitation, stormwater, irrigation supply and agricultural drainage.
We encourage the city's continuing cooperation in the Coachella Valley Water Ivianagernent
Plan as a means of securing adequate water supplies for the future. Our comments can be
found in attachment A, enclosed.
If you have any questions, please contact Joe Cook, planning engineer, extension 2 2.
Enclosure/1/as
Yours very truly.
Tom Levy
General Manager -Chief Engineer
TRUE CONSERVATION
!SE WATER WIFELY
Attachment A
1. Page 1-27, Water Resources, second paragraph, fourth sentence, please revise to reflect
the following:
The district estimates that 40 percent of the domestic water used in the upper valley is
reintroduced into the groundwater table through percolation.
In the lower valley (areas south and east of Point Happy) this number ranges between 50
percent and 25 percent depending on the suhterrancan soil characteristics in the vicinity of a
project.
i
2. Page 11-7, Water Quality/Resources, under the subheading of Vw'hitewater River
Subbasin, third paragraph:
This sentence is incorrect. The increased water levels after 1951 was the result of decreased
use of groundwater after Colorado River water became available for farm irrigation. After
Colorado River water became the primary source of -agriculture water and groundwater levels
began to rise until the ] 970's when well water was used for drip irrigation.
A -2
k 3
3. Page I11-75, Soils and (ieulogy, under the sUbhead;ng Mitigation Measures, Item A:
This section is incorrect in suggesting that Lake Cahuilla may fall under the jurisdiction of
the California Division of Safety of Dams. As a federally owned facility, Lake Cahuilla is
not wader the jurisdiction of the State Division of Dams, Lake Cahuilla is operated and
maintained by CVWD and it is the district's responsibility to maintain the strucrural safety of
the lake.
3, Page III-81, Flood Hazard Areas should address the following:
Much of the area within the proposed annexation and the proposed sphere of influence is
currently identified as a zone D on the Federal Flood insurance Rate Maps that are in effect
at this time. A zone D represents areas that have undetermined flood risks. As the city
annexes these areas, it becomes the local NFIP community with jurisdictional
responsibilities. The city should participate with CVWD in funding flood nsk studies for the
subject area so that the proper flood risks may be mapped.
4. Page liI-8G, Hydrology, under the subheading Mitigation Measures, item C:
A-4
A-5
This paragraph refers to the seismic safety of CVWD's above ground reservoirs. The water
tanks currently meet seismic requirerncnts and are not in need of seismic retrofitting. District A- 6
reservoirs are fitted with seismic couplings to absorb seismic forces. The reservoirs are also
fitted with automatically actuated seismic valves that will shut offwithin 45 seconds of
seismic activity.
5. Page ]]I-$7, Water Resources/Quality:
This section should refer to the Coachella Valley Draft Water Management Plan, prepared by A-7
CWl, which discusses existing conditions and mitigation goals for the general plan
planning area. The mitigation measures beginning on page I]]-94, should indicate the city's
support for implementing the goals of the water management plan including source
substitution , conservation and groundwater recharge.
6. Page I1I-89, Domestic Water Services third sentence)
This sentence identifies 'he Myoma Dunes Mutual Water Company as the domestic water
purveyor for a]1 of Bermuda Dunes area. This is not correct in that the district has several
domestic water customers in Bermuda Dunes. Some of C WD's customers are located east
of Adams Street also on the north and south side of Darby Road and areas along and adjacent
to t17e east side of Washington Street. The jurisdictional boundaries between different water
agencies will be confirmed during the city's planning review process for new developments.
7_ Page III-183, Domestic Water Service under the subheading Coachella Valley Water
District we recommend the following revisions.
First paragraph, second sentence we recommend the word limited be deleted. The district
serves many square miles of ]and south of Avenue 58.
First paragraph, third sentence we recommend that the part "A new well is proposed..," be
changed to "A new well has been constructed".
First paragraph, fourth sentence we recommend that the part "The existing wells have been
drilled to depth ranging from 700 to 8500 feet..." be changed to "The existing wells have been
drilled to a depth ranging from 700 to l 000 feet,.."
First paragraph, sixth sentence .ve recommend to be deleted completely.
Second paragraph, third sentence should be revised to affirm that Reservoir No, 6725 has
been constructed with a capacity of 10 million gallons.
Second paragraph, fourth sentence should be revised to state the district's plans to construct
an additional 5- to- 10-million gallon reservoir near the southeastern edge of the La Quints
cove.
8. Page V-20, Water Resources first paragraph, second sentence refers to the current
overdraft condition of about 0.24 percent per year. We recoirimend the report stay consistent
with section 1I1-88 and use 0.32 percent for the year 1999.
EC:md wrik..sw1a u g%bak Ge
A- 8
A- 9
A-10
RIVERSIDE COUNTY
LARRY D. SMITH. SHERIFF
July 25, 2001
Mr. Fred Baker
Principal Planner
City of La Quints
78495 Calie Tampico
La Quinta, Ca 92253
Sheriff__
mimw
U-695 ill{, f=AP.RLO *f BLVD. • Ii D1C'i. C~ 9 (76
U)i y 899[}
FIEC±Tiv.T
c
JUL 2 7 al
En `yf
Re: La Quinta General Plan, Annexation No. /2 & Sphere of Influence Amendment
Dear Mr. Baker
The Sheriff's Department has the following comments to make regarding this plan,
+ Page I7-15 (Police Protection) - The city currently contracts for 82 .hours of patrol tame
per day. They also cont.-act fcr a three-rnan special enforcement unit, a school resource
officer, two community service officers, a motor officer, arsd a dedicated city sergeant.
Staffing levels and the law enforcement contract are reviewed annually.
i
• Page III-172 (Police Protection/Existing Conditions) - same as above
. \ w��
The Sheriff's Department appreciates the opportunity to comment on this plan from a late
enforcement point of view.
Thank you,
Sincerely,
Larry Dr Smith, Sheriff
� � a
Dart gamer, Captain
lrtidi Cation Commander
D-1
ID2
ArMEM&ERS
Lcserf h'DP 55nrtps r{vncnc Mmpge lido
.�;� FDfn'1SArir,C° Fi.7fr�iDeSerf C-Iversid&
Cofnearc� Cih' J 1{7�i(},1S' L.verr5 s7ve?rSiQB Coon fy
y Jf1fq
S { _ r , s ? fi 11 // # A Pr.niPe Agarocy
Mr_ Fred Baker
Principal Planner
City of La Quints
76-495 Calle Tampico
La Ouinta, CA. 92253
RE Comments on the Draft EIR for the La Cuinta General Plan
Dear Mr, Baker:
SunLine Transit Agency has reviewed the above referenced document and
would like to at this time inform you of some changes to our fixed route service
that occurred July 1, 2001 which affects text within this document.
Referencing section III page 36 under Public Transportation, changes to our
service in July 2001 included the combination of routes 36 and 91 into one route
which will be called the Line 91, The combination of these two routes will allow
for better frequency for residents of the east end of the valley_
The Line 91 will operate eight round trips seven days a week.
Also, there were some additions to the Line 111. The Line 111 now operates 38
round trips on consistent 25 minute headways Monday through Friday and 23
round trips on weekends at 44 minute headways.
The Line 70 which operates within La Quinta is scheduled for service additions
next July 2002. Our Planning and Operations Departments are currently working
on this project.
If you should have any questions regarding these changes. Please feel free to
give me a call at (760) 343-3456 ext. 119.
eslle Gros
Sr Transportation Analyst
Cc: Nicole S auv iat C ri ste
C-x
32-505 Hcrrw ()by =i c.lifc]friro 92 ,76 Phorle 760 543-3456 Fc 7. i0 .34,3 i G
S6n-ID-2001 09-09
•
From-COACHELLA VLY 1.l',JCp
-181`,1 842 8110 T-5.0 F p;7zIO a F-36i
.ier drlrust=
President
PAUL FLOWERS,
Indian wells
Vice Pre51dt nt
KARL $AKLR
Dser< Hot springs
SecretatyJTrcasurer
ART n+icK4Y
Palm Desert
r]EN LAFLIN
County at Large
NICK NIG05IAN, JR.
Caurrty Fit Large
PAMJt MARCHANL?
C;rawdrbi City
LUPE DGM!NGUU
Cinchona
RONAW WALKER, CAM
Indio
RON PERKINS
Ln Qurrro
LESLIE PRICER
Palm Sprino
JOHN FUSCHEfTI
Rrrficha Mirage
❑ONALD L. 00114.51
General Nianacar
Coachella Valley Mosquito and Vector Control District
43-42a Trader Place * India, CA 02201 * ',rib} 342-5287 • Fax (7 501 342-S 110
E-mail: CVmcsqurtodiearihlink.n-t - Wehsite: www.CVmcsquito.org,
Sepieniber 7, 2001
Fred Baker
Principal Planner
City of La Quinta
78.495 Calle Tampico
La Quinta, CA 92253
Subject: Draft Environmental Impact Report (S CI -I number 200OU97 023) for the
]1a Quinta General Plan, 1'Lnnexaticm No. 12 and Sphere Influence
Ainendineut
Dear Mr. Baker:
Thank you for the opporn nity to express ow opinion regarding the environmental
impact report tor the Draft Environmental tai Impact Report (SCIT / umbc_
2000091023).
in regard to the proposed project, one of the District's concerns is in the
possibility of creating breeding sources rut mosquitoes and aquatic midges by
constructing flooding retention basins and drainage systems. The newly
established drainage systems, although generally limited in size a]'d location by
the plan, could support breeding sources for vector species of mosquitoes, if not
properly designed and constructed. It is a fact :hat one of the indigenous
mosquito species, Cul x quinrlu aselatus; -is a major vector for St. Louis
encephalitis and west= equine encephh1l0myelitis in the Coachella Valley.
The Distract. would like to take this opportunity to bring to your attention the
necessity of incorporating our District in the process cf evaluating proposed
architectural plans of drainage facilities and retention basins in order to insure that
the public is protected from vectors and nuisance species that can be created by
the proposed project_
you have further questions, please feel free to contact roe_
Donald E. Gornsi
Gcnera1 Manager
B
B-1
$-2
99-1G-GI
01.' 95
REC.IVE]] FROM:-7ED3a29s1]d P.02
ri
The
Gas
COrnpanya
risj5erripra Frwrgv company
July 23. 2001
City c` La Quinta
78-495 Calle Tampico
La Cuinta, CA 92253
Attention: Fred Baker
Southern California
Gas Company
1997 w_ Lugonla Avenue
Petl lantl s, CA 92374-9 i 20
Mziling AQdrpsS=
Pu Box 3003. SCPA..31
PeUIanas. CA 92373-0aub
Gas Co. Ref. No. 01-346 OG
4,7
QT
Re: Draft EIR — Cty of La Quinta Comprehensive Generai Flan, SCH No.
2000091023.
Thank you for the opportunity to respond to the above -referenced project. Please note
that Southern California Gas Company has facilities in the area where the above named
project is proposed. Gas service to the project could by provided without any .s gnificar,t
impact on the environment• The service would be in accordance with the Company's
policies and extension rules or: file with the California IPurrlic Utilities Commissiontt the
time contractual arrangements are made.
You should be aware that this letter is not to be interpreted as a contractual
commment to sorvo the proposed project, but only as on informational service. The
availability of natural gas service, as set forth in this letter, is based upon present
conditions of gas supply and regulatory porcies. Asa public utility, The Southern
California Gas Company is under the jurisdiction of the California Public Jtilities
Commission. We can also be affected by actions of federal recutatory agencies.
Should these agencies take any action, whicn affects gas supply, or the conditions
under which service is available, gas service will be provided in accordance with revised
conditions.
Typical demand use for:
E-i
1E2
a, Residential (System Area Ave'acgo'Use Per Meter Yearly
inele Farrlily 799 thermsiyear dwelling unit
l•iulti-Family 4 or less units 482 thermsryear dwelling unit
Multi -Family 5 or more units 483 therms/year dwelling unit
These averages are based an total gas consumotion in residential units served by
Southern California Gas Company, and it should not be implied that any particular
home, apartment or tract of homes will use these amounts of energy.
E-3
Commercial
Due to the fact that construction varies su widely (a Glass building vs, a heavily
insulated building) and there is such a wide variation in types of materials and
equipment used, a typical demand figure is not available for this type of
construction. Calculations would reed to be made after the building has been
designed.
We have Demand S:cie Management programs available to commercialfndustrial
customers to provide assistance in selecting the most effective applications of enercv
conservation techniques fora particular r ct. jlf yau7c. irc further information on any
of our energy conservation programs, please contact our CommerciallEndustriai Support
Center- at 1-8i =SAS-20OU.
Sincerely,
John DeWitt
Technical Supervisor
SDUHFFf=RI./ CAL/FORMA
ASSOCIATION of
GOVERNMENTS
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August 16. 2001
Mr. Fred Baker
Principal Planner
G;ty of La Quints
7D-495 Calle Tampico
La Quinta, CA g2253
Rai Comments an the Draft Environmental Impact Report for the City of La
Quinta Comprehensive General Plan Update.-SCAG No. 120010402
Dear Mr Baker:
Thank you for submitting the Draft Environmental Impact Report for the City of La
Quinta Comprehensive General Plan Update to SCAG for review and comment- As
areawide clearinghouse for regionally significant projects, SCAG reviews the
consistency of local plans, projects, and programs with regional plans_
Thisactivity is based on SCAG•S responsibilities as a regional planning organization
pursuant to state and federal laws and regulations- Guidance pravidad by these
reviews is intended to assist local agencies and project sponsors to take actions that
contribute to the attainment of regional goals and poiiuies, If you have any questions
regarding the attached comments, please Contact me at (213) 23F-1857- Thank you.
Sin cere!y
E` r' 66/3 1ITH, AICP
Senior Planer
Intergovernmental Review
1'ellLra Canasta Tean,yar,,nco CeJNniuinn:
tiII 7iws. Slen. 'filler
tti Mr." cn Race -led NF<• 50411,114
August 16.2001
Mr. Fred Baker
Page 2
COMMENTS ON THE
DRAFT ENVIRONMENTAL IMPACT REPORT
FOR THE
CITY OF LA QU)NTA
COMPREHENSIVE GENERAL PLAN UPDATE
SCAG NO. 1 200/0402
PROJECT DESCRIPTION
The proposed Project consists of a Comprehensive General Plan Update for the City of
La Quinta, in Riverside County. The proposed Project involves the planning of 53,498
acres of incorporated lands and sphere of influence areas.
INTRODUCTION TO SCAG REVIEW PROCESS
The document that provides the primary reference for SCAG's project review activity is
the Regional Comprehensive Plan and Guide {RCPG). The RCPG chapters fall into
three categories: core, ancillary, and bridge. The Growth Management (adopted June
1994), Regional Transportation Plan (adopted April 2001), Air Quality (adopted October
1995), Hazardous Waste Management (adapted November 1994), and Water Quality
(adopted January 1995) chapters constitute the core chapters. These core chapters
respond directly to federal and state planning requirements. The core chapters constitute
the base on which local governments ensure consistency of their plans with applicable
regional plans under CEQA. The Air Quality and Growth Management chapters contain
both care and ancillary policies, which are differentiated in the comment portion of this
letter. The Regional Transportation Plan (RTP) constitutes the region's Transportation
Plan, The RTP policies are incorporated into the RCPG.
Ancillary chapters are these on he Economy, Housing, Human Resources and Services,
Finance, Open Space and Conservation, Water Resources, Energy, and Integrated Solid
Waste Management. These chapters address important issues facing the region and may
reflect other regional plans. Ancillary chapters, however, do not contain actions or
policies required of local government. Hence, they are entirely advisory and establish no
new mandates or policies for the region.
Bridge chapters include the Strategy and Implementation chapters, functioning as limits
between the Core and Ancillary chapters of the RCPG.
Each of the applicable policies related to the proposed project are identified by number
and reproduced below in italics followed by SCAG staff comments regarding the
consistency of the Project with those policies,
August 1e, 2001
Mr. Fred Baker
Page 3
SUMMARY OF SCAG STAFF COMMENTS
1. The Draft EIR does not addresses the relationship of the proposed project to
applicable regional plans as required by Section 15125 [di of Guidelines for
Implementation of the California Environmental Quality Act.
2. The Final EIR should address the relationships (consistency with core policies and
support of ancillary policies) to SCAG's Regional Comprehensive Plan and Guide,
utilizing commentary from the following detailed SCAG staff comments. The response
should also discuss any inconsistencies between the proposed project and applicable
regional plans_ We suggest that you identify the specific policies, by policy number,
with a discussion of consistency or support with each policy.
CONSISTENCY WITH REGIONAL COMPREHENSIVE PLAN AND GUIDE POLICIES
The Growth Management Chapter (GN1C) of the Regional Comprehensive Plan and
Guide contains a number of policies that are particularly applicable to the City of La
Quinta Comprehensive General Plan Update.
Core Growth linanagernent Policies
3.01 The population, housing, and jobs forecasts, which are adopted by SCAG's
Regional Council and that reflect local plans and policies, shall be used by SCAG
in all phases of implementation and review.
SCAG staff comments, The Draft EIR references the adopted RTP 1998 SCAG's
Population, Household and Employment forecasts for the City of La Quinta. The
Draft EIR should use growth forecasts from the adopted 2001 RTP, which were
included in SCAG's May 23, 2001 letter on the Corrected NOP for the proposed
Project. The estimates in the Draft EIR are slightly above the adopted RTP growth
forecasts. The Project is partially consistent with this core RCPG policy.
3.03 The timing, financing, and location of public facilities, utility systems, and
transportation systems shall be used by SCAG to implement the region's growth
policies.
SCAG staff comments. The Draft E1R does not present a discussion on Project F-3
phasing and timing. It would be helpful if the Final EIR would provide a discussion
and address the manner in which the Project is supportive or detracts from the
achievement of this policy_ Based on the information provided in the Draft EIR, we
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August 15, 2001
Mr. Fred Baker
Page 4
are unable to determine if the Project is consistent with this core RCP! policy.
Regional Transportation Plan
The Regional Transportation Plan (RTP) also has goals, objectives, policies and actions
pertinent to this proposed project. This RTP links the goal of sustaining mobility with the
goals of fostering economic development, enhancing the environment, reducing energy
consumption, promoting transportation -friendly development patterns, and encouraging
fair and equitable access to residents affected by socio-economic, geographic and
commercial limitations. Among the relevant goals, objectives, policies and actions of the
RTP are the following:
Core Regional Transportation Plan Policies
4.01 Transportation investments shall be based on CA 's adopted Regional
performance Indicators.
SCAG staff comments. The Draft ER does not provide a discussion on
Transportation investments based on the following SCAG adopted Regional
Performance Indicators:
Mobility - Transportation Systems should meet the public need for improved
access, and for safe, comfortable, convenient, fester and economical movements
of people and goods.
• Average Work Trip Travel Time in Minutes — 25 minutes (Auto)
• Pm Peak Freeway Travel Speed— 45 minutes (Transit)
• PM Peak Non -Freeway Travel Speed
• Percent of PM Peak Travel in Delay (Fwy)
• Percent of PM Peak Travel in Delay (Non-Fwy)
Accessibility - Transportation system should ensure the ease with which
opportunities are reached_ Transportation and land LISP measures should be
employed to ensure minimal time and cost.
• Work Opportunities within 45 Minutes door to door travel time (Mode Neutral)
▪ Average transit access tiara
Environment - Transportation system should sustain development and
preservation of the existing system and the environment. (Alf Trips)
• CO, ROG, NDx, PMi O, PM2.5 — Meet the applicable SIP Emission Budget and
the Transportation Conformity requirements
4
August 16, 2001
Mr, Fred Baker
Page 5
Reliability- Transportation system should have reasonable and dependable levels
of service by mode. (All Trips)
. Transit - 03
• highway - 7E%
Safety - Transportation systems should provide minimal accident, death and injwy.
(Ali Trips)
, Fatalities Per Million Passenger Miles - 0
, Injury Accidents - 0
Equity/Environmental Justice - The benefits of transportation investments should
be equitably distributed among all ethnic, age and income groups. (All trips)
▪ By Income Groups Share of Net Benefits - Equitable Distribution of Benefits
among ail Income Quintiles
Cost -Effectiveness - Maximize return on transpodation investment (All Trips). Air
Quality, Mobility, Accessibility end Safety
. Return on Total investment- Optimize return on Transportation Investments
The Final E3R should address the manner in which the Project is supportive of or
detracts from the achievement of the eight core RTP objectives. Based on the
information provided, we are unable to determine whether the Project is consistent
with this core RCPG policy.
4.02 Transportation investments shall mitigate environmental impacts to an acceptable
level.
SCAG staff comments, The Draft EIR in Section 3-C (Traffic/Circulation) identities
transportation and circulation impacts, and details the measures to mitigate these
impacts on page ll I-58. The Project is consistent with this core RCPG policy,
4.04 Transportation Control Measures shall be a priority.
SCAG staff comments. The Draft EIR, on page III-58, includes a discussion on the
City's development and Implementation of Transportation Demand Management
strategies, to extend or preserve capacity roadways, In addition, mitigation
measures support the implementation of Transportation Canto! Measures. The
Project is consistent with this core RCPG policy.
5
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F-5
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August le, 2001
Mr. Fred Baker
Rage 6
4.16 Maintaimng and operating the existing transportation system will be a priority over
expanding capacity
SCAG staff comments. The Draft E]R. in Section 3-C (Traffic/Circulation) includes F-7
a discussion on the existing circulation system, and recommends measures to
upgrade the existing circulation system. This should maintain and operate the
existing transportation system. The Project is consistent with this core RTP policy,
GMC POLICIES RELATED TO THE RCPG GOAL TO IMPROVE REGIONAL
STANDARD OF LIVING
The GrowIn tvlanagernent goals to develop urban forms that enable individuals to spend
Tess income on housing cost, that minimize public and private development costs, and
that enable firms to be competitive, strengthen the regional strategic goal to stimulate the
regional economy, The evaluation of the proposed project in relation to the following
policies would be intended to guide efforts toward achievement of such goads and does
not infer regional interference with local land use powers
3.05 Encourage patterns of urban development and land use, which reduce costs on
infrastructure construction and make better use of existing facilities.
SCAG staff comments. The Draft EIR in Sections 3-C (Traffic/Circulation) and 3-L
(Public Services and Facilities) acknowledges that the Project will maximize the
use of existing infrastructure and improve infrastructure defciencies to meet the
needs of the proposed Project. In addition, increases in demand for services will
occur gradually as additional development takes place. Mitigation measures
recommended in each section would address identified impacts. The Project is
supportive of this ancillary RCPG policy.
3.09 Support focal jurisdictions' efforts to minimize the cost of infrastructure and public
service delivery, and efforts to seek new sources of funding for development and
the provision of services,
SCAG staff comments. See SCAG comments on policy 3.05. The Project :s
supportive of this ancillary RCPG policy.
3.10 Support focal jurisdictions' actions to minimize red tape and expedite the permitting
process to maintain economic vitality and competitiveness.
SCAG staff comments. The Draft EiR only addresses subjects that may have
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August 16, 2C01
Mr. Fred Baker
Page 7
adverse environmental irnpacts. It is written in a concise manner, where all
possible adverse impacts are mitigated this will help minimize red tape, and help
maintain the economic vitality and competitiveness of the City of La Quinta, In F-10
addition, the Draft E1R, on page 1-30, includes a number of General Plan goals and
policies, which will also help to minimize red tape, and help maintain the economic
vitality and competitiveness of the City of La Quinta. The Project is supportive of
this ancillary RCPG policy.
GMC POLICIES RELATED TO THE RCPG GOAL TO IMPROVE THE REGIONAL
QUALITY OF LIFE
The Growth Management goals to attain mobility and clean air goals and to develop
urban forms that enhance quality of life, that accommodate a diversity of life styles, that
preserve open space and natural resources, and that are aesthetically pleasing and
preserve the character of communities, enhance the regional strategic goal of maintaining
the regional quality of life. The evaluation of the proposed project in relation to the
following policies would be intended to provide direction for plan implementation, and
does not allude to regional mandates.
3.12 Encourage existing or proposed local jurisdictions' programs aimed at designing
land uses which encourage the use of transit and thus reduce the need for
roadway expansion, reduce the number of auto trips and vehicle miles traveled,
and create opportunities for residents to walk and bike.
SCAG staff comments. The Draft EIR does not include a discussion on land uses
that encourages the coordination and implementation of transit and transit
facilities, and bikeways, pedestrian and/or equestrian trails. It would be helpful if
the Final EIR would provide a discussion and address the manner in which the
Project is supportive or detracts from the achievement of this policy. Based on the
information provided in the Draft EIR, we are unable to determine if the Project is
supportive of this ancillary RCPG policy.
3.13 Encourage local jurisdictions' plans that maximize the use of existing urbanized
areas accessible to transit through hill/ and redevelopment.
SCAG staff comments. The Draft EIR does not address the subject of transit
service to serve and provide access to new development and redeveloped areas.
It would be helpful if the Final EIR would provide a discussion and address the
manner in w Lich the Project is supportive or detracts from the achievement of this
policy, Based on the information provided in the Draft ER, we are unable to
determine if the Project is supportive of this ancillary RCPG policy.
F-X 1
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August 18, 2001
Mr. Fred Baker
Page 8
3.17 Support and encourage settlement patterns, which contain a range of urban
densities.
SCAG staff comments. The Draft EIR in Section 3-A (Land Use Compatibility)
identifies ranges of urban densities. The Project is supportive of this ancillary
RCPG policy,
3.13 Encourage planned development in locations least likely to cause adverse
environmental impact.
SCAG staff comments. The Project is proposed in a manner, which will minimize
adverse environmental impacts, Mitigation measures included in the Draft EIR
have been developed to address identified impacts. The City of La Quints should
carefully consider the adequacy of these measures. The Project is supportive of
this ancillary RCPG policy.
3.20 Support the protection of vital resources such as wetlands, groundwater recharge
areas, woodlands, production lands, and land containing unique and endangered
plants and animals.
SCAG staff comments. The Draft EtR in Section 3-G (Biological Resources)
discusses the Projects' impact on biological resources, The Draft EIR
recommends a number of mitigation measures to address impacts to plants,
invertebrates and reptiles, birds and mammals. The Project is supportive of this
ancillary RCPG policy.
3,21 Encourage the implementation of measures airned at the preservation and
protection of recorded and unrecorded cultural resources and archaeological sites,
SCAG staff comments. The Draft EIR in Section 3-H (Cultural Resources)
identifies potential impacts related to archaeological and historic resources. A
number of mitigation measures are recommended to address impacts to
archaeologic and historic resources. The Project is supportive of this ancillary
RCPG policy.
3.22 Discourage development, or encourage the use of special design requirements, in
areas with steep slopes, high fire, flood, and seismic hazards.
SCAG staff comments. The Draft EIS in Section 3-D (Soils and Geology) identifies
potential impacts related to sons, siesmicity, induced slope instability, induced
inundation and liquefaction. Mitigation measures recommended include the
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F-17
8
August 16, 2001
Mr, Fred Baker
Page D.
implementation of building codes, specific requirements and/or project design.
The Project is supportive of this ancillary RCPG policy.
3.23 Encourage mitigation measures that reduce noise in certain locations, measures
aimed et preservation of biological and ecological resources, measures that would
reduce exposure to seismic hazards, minimize earthquake damage, and to
develop emergency response and recovery plans
SCAG staff comments. The Draft EIR in Section J-N {Noise) acknowledges
potential noise impacts related to aviation, traffic, stationary noise sources and
construction activities. Mitigation measures recommended in this Section have
been developed to address identified impacts. The Project is supportive of this
ancillary RCPG policy.
GMC POLICIES RELATED TO THE RCPG GOAL TO PROVIDE SOCIAL, POLITICAL,
AND CULTURAL EQUITY
The Growth Management Goal to develop urban forms that avoid economic and social
polarization promotes the regional strategic goal of minimizing social and geographic
disparities and of reaching equity among all segments of society. The evaluation of the
proposed project in relation to the policy stated below is intended guide direction for the
accomplishment of this goal, and does not infer regional mandates and interference with
local land use powers.
3.24 Encourage efforts of focal jurisdictions in the implementation of programs that
increase the supply and quality of housing and provide affordable housing as
evaluated ire the Regional Housing Needs Assessment.
SCAG staff comments. The Draft EIR, in Section 3-A (Land Use Compatibility)
provides a discussion on residential land uses. The discussion suggests that there
is the potential for 78,952 units at buildout, or an increase of 66,811 units over the
long term. The Draft EIR, however, does not provide a discussion on programs
that could increase the supply and quality of housing and the provision of
affordable housing. It would be helpful if the Final EIR would provide a discussion
and address the manner in which the Project is supportive or detracts from the
achievement of this policy. Based on the information provided in the Draft EIR, the
Project is partially supportive of this ancillary RCP policy.
F-17
F48
F-19
9
August 16, 2001
Mr. Fred Baker
Page 10
3.27 Support local jurisdictions and other service providers in their efforts to develop
sustainable communities and provide, equally to all members of society,
accessible and effective services such as: public education, horsing, health care,
social services, recreational facilities, law enforcement, and fire protection.
SCAG staff comments. The Draft ERR, in Section 3-1_ (Publi❑ Services and
Facilities) acknowledges that the potential build out of the General Plan would
have impacts on schools, libraries, police and fire protection, health care facilities
and services. Mitigation measures are recommended to address impacts to
services. The Project is supportive of this ancillary RCPG policy.
AIR QUALITY CHAPTER CORE ACTIONS
1
The Air Quality Chapter (AQC) core actions that are generally applicable to the Project
are as follows:
5.07 Determine specific programs and associated actions needed (e.g., indirect source
rules, enhanced use of telecommunicatiions, provision of community based shuttle
services, provision of demand management based programs, or vehicle-miles-
traveled/emission fees) so that options to command and control regulations can be
assessed.
SCAG staff c❑mments. See SCAG staff comments for policy 4.02, The Draft EIR,
in Section 34 (Air Quality), includes a number of mitigation measures that
encourages the implementation of measures that focuses on trip reduction,
improving traffic flow, pedestrian movement, biking, public transit and utilizing
alternative meth❑ds of transportation. The Project is consistent with this core
RCPG policy.
5.11 Through the environmental document review process, ensure that plans at all
levels of government (regional, air basin, county, subregional and local) consider
air quality, land use, transportation and economic relationships to ensure
consistency and minimize conflicts.
CAG staff comments, The Draft EIR, in Section 3-I (Air Quality) discusses the
consistency of the proposed Project with regional and local air quality policies and
inctudes mitigation measures for impacts to air quality. The Project is consistent
with this core RCPG policy,
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F-21
F-22
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August 16, 2001
Mr. Fred Baker
Page 11
WATER QUALITY CHAPTER RECOMMENDATIONS AND POLICY OPTIONS
The Water Quality Chapter core recommendations and policy options relate to the two
water quality goals: to restore and maintain the chemical, physical and biological integrity
of the nation's water; and, to achieve and maintain water quality objectives that are
necessary to protect all beneficial uses of all waters.
11.07 Encourage water reclamation throughout the region where it is cost-effective,
feasible, and appropriate to reduce reliance on imported water and wastewater
discharges. Current administrative impediments to increased use of wastewater
should be addressed.
SCAG staff comments. The Draft EIR does not provide a discussion on reclaimed
water. It would be helpful if the Final EIR would provide a discussion and address
the mariner in which the Project is supportive or detracts from the achievement of
this policy, Based on the information provided in the Draft EIR, we are unable to
determine if the Project is consistent with this core RCPG policy.
OPEN SPACE CHAPTER ANCILLARY GOALS
Outdoor Recreation
9.01 Provide adequate fend resources to meet the outdoor recreation needs of the
present and future residents in the region and to promote tourism in the region.
SCAG staff comments, The proposed Project provides for approximately 14,120-
acres of open space for park facilities, golf courses, open space and watercourse.
The Project is supportive of this ancillary RCPG goat
9.02 increase the accessibility to open space (ands for outdoor recreation.
SCAG staff comments. See SCAG staff comments for goal 9_01. The Project is
supportive of this ancillary RCPG goal.
9_03 Promote self-sustaining regional recreation resources and facilities.
SCAG staff comments. The Draft EIR does not discuss the subject of self
sustaining regional resources and facilities. It would be helpful if the Final EIR
would provide a discussion and address the manner in which the Project is
supportive or detracts from the achievement of this policy. Based on information
F-23
F-24
F-25
F-26
11
August 16, 2001
Mr. Fred Baker
Page 12
provided in the Draft EIR, we are unable to determine if the Project is supportive of F-26
this ancillary RCPG goal.
Public Health and Safety
9,04 Maintain open space for adequate protection of lives and properties against
natural and man-made hazards.
SCAG staff comments. The Draft EIR does not discuss the subject of open space
for the protection of lives against natural and man-made hazards. It would be F-27
helpful if the Final EIR would provide a discussion and address the manner in
which the Project is supportive or detracts from the achievement of this policy.
Based on information provided in the Draft EIR, we are unable to determine if the
Project is supportive of this ancillary RCPG goal,
9.05 Minimize potentially hazardous developments in hillsides, canyons, areas
susceptible to flooding, earthquakes, wildfire and other known hazards, and
areas with limited access for emergency equipment.
SCAG staff comments. See SCAG staff comments on policies 3.22 and 9.04.
The Project is partially supportive of this ancillary RCPG goal,
Resource Protection
9.08 Develop well -managed viable ecosystems or known habitats of rare, threatened
and endangered species, including wetlands.
SCAG staff comments, See SCAG staff comments on policy 3.20. The Project is
consistent with this core RCPG goal,
CONCLUSIONS
1. As noted in the staff comments, the Draft Environmental impact Report for the City of
La Quinta Comprehensive General Plan Update is consistent with or supports many
of the core and ancillary policies in the Regional Comprehensive Plan and Guide,
Based on the information in the Draft Environmental Impact Report, we are unable to
determine whether the Project is consistent with core policies 3.03, 4,01 and 11.07.
The Project is also partially consistent with core policy 3.01. Based on the information
in the Draft Environmental Impact Report, we are unable to determine whether the
Project is supportive of ancillary policies 3.12, 3,13, 9.03 and 9.04. In addition, the
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August 15, 2001
Mr. Fred Baker
Page 13
Project is partially supportive of ancillary policies 3,24 and 9_05.
2. As noted in the Summary of SCAG Staff Comments, the Final EIR should address the
relationships (consistency with core policies and support of anciiiary policies) to
SCAG's Regional Comprehensive Plan and Guide and discuss any inconsistencies
between the proposed project and applicable regional plans.
3. All feasible measures needed to mitigate any pctentialfy negative regional impacts
associated with the proposed project should be implemented and monitored, as F-31
required by CEDA,
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1s4:'1!1/U3 09:4q FAX 5OM1 25T%U K1NK0' S S.F. DMI% 1'34N 1+anl
THE VISTA SANTA ROSA ASSOCIATION
E LL,EN TiCVER. PRESIDENT
PHILIP nURNETT, VICE PRESIMENT
!BETTY MORG1H, 5ECRETAR"
ELIZA19ETH L- 7ALLLY, IREASUR%t
HETI'V MANGAN SMYTI1, DIRECTOR
EDWARD GRANADdS, Du rC..TOR
82-836 BEcto..1AN DRIv
THERMkL, GA 92274
September 9, ^001
Mr- Prod Baker
Principal Planner
City of LL�� ()hilt.
7R-495 Cal] Tampico
La Quinta, CA 92253
Sent via FAX to Nicole Sauviat Cristo at 761) 322-2760
Original to be sent via TES Mail
RE: Colnrntnts on Draf~ Environmental 1rnpact Report (S E-H Number 00009 ] 023) for the 1.a
Quint' General Plan, Atmexaticn N€i. 12 a11d Sphere of Influence
Deal' Mr. Bakci.-..
en behalf of the Vita Santa Rosa Association, a non-profit organization devoted to dissemination
ot',rsYtet infonnadon and the soca,a: el fare of the area. known as Visxo. Santa Rosa, we are submitting
coniments, under separate crArcr, c11] the Draft Environmental Plan from two cxpe.rts ..a�tlk5eu
'Medlin and Gary Mitchell & Associates_ Additionally, l would like to make the attache.Li c omrnctxls
that covet` some of the areas of concern of our resideTa.>s-
We are concerned. trot only about lilt impact of the General Plan on the areas cast oft:re current City
limns of L.:T Quinta; gut also the cumnlativc impact of the Plan on the region, including the current
incn;porated city.
Since] eiy yours,
-Ben Lloyd Trovcr, Prrsiderlt
WWW.viSt3S3ntarosa.CDQI
etrover@ix,net.coln.tom
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Comments on Draft Environmental Impact Report (SCH Number 20001)91023) for the La
[ uima General Plan, Annexation No. ]? and Sphere ofiufluertce; submitted on behalf of tlhc
`,'isttt Santa Rosa Association
Asa general observation. it is our opinion that there is insubstantial evidence presented and
inadequate analyses of Proj LAlternatives. \Vital respect to the"Preferred Plan:,,
Section Ill A&a: I_attd Use and Agricultural Resources: It is our opinion that the Low Density
and Very Low Density designations col the land cast of Ehc cif limits would cncornaw,
spraw' is specifically discouraged by State Stattttel Furthermore, the absence of any
spccif`e v urding of the "Agricultural Overlay" makes it impossible to deterlr ii e and analyze [lie
impact on existing land uses. it is our belief that the wording of Agricultural Overla y tnay
nikicuntly ]linit tilt current agricultural uses, especially for annual k,usbandrlFurdir car
appears that horde {tccupaticy business uses under the city plan would. hemore restrictive than
the current rc utatior s under Riverside County zoning regulations, and the resulting impact is
not lddressed in the Drafl EIR.
An a€iriitiona] issue of concem is that the "Kohl Ranch" development is not included in the
Agricultural Overlay which means that if the City should annex that area also_ it could not be
continue to be cultivated pending development,
The ern ire premise of the General Plan and Draft EIR seems to be that the areas cast of the city
]itr,iis be developed at an average of 3 units per acre at a fairly steady pace; however, as tite
economy of the region would be drastically altered by the conversion of agricultural land to
"country dirt." or standard subdivisions, the impact on the region is not adequately addressed.
Additionally, the repo -it states t'.iat "Ftnzters and rnncheis gray he exposes to increased noise
as$ociatcd with household mechanical equipment and traf `tc generated by :leuw residences.
Residents of low -density developments may be exposed to operational noise generated by farm
equipment, odors front furno animals and organic or chemical crop applications, and airborne
sand oodles dust generated by plowing and harvesting activities." The mitigation measurer's on
these issues are inadequate to address the problems.
On bate 111-140, the draft EIR states: "Land u e incompatibilities may arise where urban and
agricultural lands are adjacent to oar another. Fugitive dust generated by disking, plowing, and
other agricultural operations could create a nuisance for neighboring deve,lopment, arrd fugitive
dust generated during the grading and construction phases of new development could adversely
impact neighboring farmlands." A WO foot buffer would be inadequate to -,revert these
incompatibilities as {anyone. who has heen in the Coachella Valley on a breezy, not averi windy
day, can attest.
At the -very least, the City should adopt a "Right to Farm" ordinance_
Section HI CC Traffic/Circulation:
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it is our opinion that [lie Plan is iiiadec11141e as it indicates that "most" cline roadway se,2,ti1etus
will operate as Levels of Service "D" on buildout of the proposed Gcuera] Pltin. Adclitioiially,
the need to nmove tractors and other r' gricultural equipment is not adequately analyzed., nor are Clic
provisions for regional horse trails, and their impact on circulation taken into consideration.
Certainly one of the glaring problems with traffic plans in the City is the recent installation of the
trafficc, circle; at Ave, 52 and Jefferson Streets which has potential Gala. trophic consequences for
anyone atten'Spting trr transport horses, other ltvestoc1., or heavy equipment via trailer through the.
intersection.
Section D. Soils & Gcology:
The General Plan's twntticip itecI buildout at an average of 3 houses to the acre is excessive and
irresponsible until, and unless, the df.12ers cal -collapsible soils aid ground subsidence are
demonstratively solved. Although CVWD has operated a pilot recharge facility, it is still in the
experiretttal stage and even if sueuessitil, a fall -scale facility is years in the future. lucked.
CVWD has _dust received a grant from the State for further study.
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The issue of wind erosion and damage from blowing sand are grossly tinder -rased. Reduction of - - 11
the flood potential. of. the Whitewater River not solve tit: existing conditions.
While. improved building cc dcs have reduced the potential for collapse of buildings and deaths as
a result of seismic activity, significant damage to structures, city Infrastructure, and r:ri 1rmintiy
social life are inescapable in the event of major vernal-. The Draft E.IR anticipates "a 22%
probability of the Sail Andreas Fault gerieratine a magnitude 7,0 earthquake before t:ic year
2024' and "the slip gate of the San Jacinto fault is c;tirnated at Tletve.eeu 7 Lind 17 aim/years and is G - 12
capab;e of generating magnitude 6,5 to 7_5 earthquakes." Added to the initial impact Of the
tremor are liquefaction, se:ilement., slope instability, and inundation. All of these issues are
inadequately {.rxalyzed and initiated, not to rnent;un their eullur]at.i.,1e impacts. To encourazo
urbanization cf nn area subject to these factors is tnsu.zlort.able.
Section E & F.=lyd';o]a y & Water Resources/Quality:
As shown above, the Dtaft.IR fails to view the hydrology issues in the context of cumulative
inipacts. At the present time, residen.ia] development will place an additional burden on the
over dialled valet table, as residential uses (including pota�lc welter) asre served by water'
ptirs-iped from the aquifer.
The engineerii]g firun for the Coral ]viountaw. Project alialyaed the water supply demands of that
project, which is a coimiry club/residential development of the type that can be auitieipatc[l to be
built throughout the annexation and planning area. They calculated that development thine
would contribute an Additional average demand of 1.8 acre feet per acre per year on the
g1 Lmnc wateJ. That project is only the "tip of the iceberg."
The residents of the Vista Santa Rosa have repotted that the water Leek in their wells
have, been dropping for years, with a significant acceleration of the. rate since PGA West was
approved. The draft Coachella Valley Water Management Plan slates that groundwater derrand
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lower yal.•ey currently exeteds recharge by 4l,7 O acre feet per year and that groundwater
levels have decreased 60 feet or more in some parts of t]ie lower valley; our residents Gan verify
those findings from empirical experience.
-Elie draft Water Management Plan .5tairs "it is clear that the continued {Ieclit',e of
groondwater- levels is unaeceptabie" and that "the continued overdraft will have Serious
consequence; for the Coachella Valley". Shcrt term impacts include increased
groundwatei pcnnpii]g souls, and the cost of deepening yells Ent] installing larger pumps_
"Continued decline of grou.sidwatei- ]evens could result in a substantial and possibly irreversible
degra{t{uior, of water quality ril the groundwater basins."
Areas of the lower Coachella Valley are already experiencing subsidence caused by excessive
groundwater overdraft.. As the water in the aquifer is depleted, the space between soil particles
is lost, w.iich leads to compaction, which CVWD reprtstritatives could peniitirterltly
reduce the capacity of the aquifer. If capacity is diminished, even if a way to recharge the c]r�ifer
is `1mitd, its ability to receive the water will be signific:anily reduced or lost. As stated above,
CVWD has not proven the physical ability to adequately recharge the aquifer, 1lr~,deed, the
CVWD ]]raft eater Management Plan states "the nlaxinttun amount of potential] recharge i!r1 the
lower valley is not known at this time,"
Additionally, this V'ater I ianr.genient Plan is itself only a draft, the EIR ]ioi (u be issued until
late i]1 2001. then it must u]:dcrgo comment, Public Tearing, and rnt±st be adopted by more ',lean
one agency; it also teems fated for c]iallerige in court. There is no guaranta.e that the plan w,11 be
adopted as currently written, when it will be implemented, that it will be s•ecessfu1, o_. )f it does
stop the overdraft that will do so in time to prevent signi-ficant subsicltnce.
The draft Waster h4 iu genhent Plan notes that the Coachella Valley does not currently have water
rights to irnponod -eater sufficielit tc satisfy its cur: ent and fit[urc demands. The issue cif
:nlported water is especially complex as seven staicti s] asrc the Colorado which, like all rivets, is
subject to reduced water capacity due CO climatic conditions, While t.VWlD Ims made an
outstanding attempt to acquire additional sources, those efforts have not yet leached fruition.
Major urban areas like. Los Angles and Phoenix may not have the "federal water priority" of khe
Coachella Valley water project, but ii is a political reality that such concentrations of population
and industry vital to the economic health and defense capability of the nation will have their
basic needs plaited in higher priority for delivery, although probably not price.
TheState is tinder directive from the Secretary of Interior to reduce its use of Colorado River
Water by Yearly 1,DDD,000 acre feet annually. ]f this area dots not significantly increase its
conservation of water, even without growth, we may have ouT current allotment redUCCd. While
an argument is made that an acre of agriculture, rises the same amount of water as an acre. of golf
course, Or an ;acre of residential use, that does not mean: that each of these uses depends on water
from the same sources; that it could or would be recycled the same way; that the drainage impact
on the Salton Sea, a federal concern, would be the .nine; that the development of currently non -
farmed hind would not in:Tease the demand on the water supply; that the impact on the i itiorx's
food supply woti]d b o' the same, etc. The effects oft1rbathi2ation of die planned area are fear, ;ai-
more complex than what is addressed in the draft EIR and any plan based upon this report is
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fatally flawed_
Sec.iein 111 G. Biological Resources:
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While extcr•eive coverage has been given to the biological resnurceYs and concerns. This is a
regional issue, and development of a plan for expansion of the city is pre]naturc until CVA[a
carnlileics it; stlfdy. Many forms of animal life can and do co -exist with existing agiiculltrri] use
a the land which cannot exist with urhani ation. 13ersolna] obsery;ition has acquainted me with
the objections of resfde]tts of one local country club to the use of their swimming' pools, etc_ by
bit clti protected by the federal migratory wildlife laws_ These sorna birds cause no problems
when they use aztioultural t'eser ibirs_
Scctio]i ER E. Cultural Resources_
As stated in the EIR, La Quinta contains "carte of the most dense concentrations cf archaeo]ogical
itcs in California." Additionally, since 19E1, "over 120 historic buildings and sites have. been
recorded in the General Plan planning area." Farm inR may "tuna" the ]and, but does not
pulverize artifacts as (levelupmeut would, as a result t:ie area is cii ttu-ally extrc.-ricly sensitive,
Additional s�neltcS ws]ulcl he necess ry to dctermire to what extent urbanization would destroy
sites that future generations could inure adequately preserve and/or c]«cumerit. Additionally, the
Torres-Maninef• and August:nei t:51,es should be onsuttod regarding pian1ied -urbanization. L]fllil
t nd unless ]potential impact sttfdics and adequate mitigatiou measures sue developed, the area of
potential development should not be expanced.
Section 1, Air Quality:
AS staled in the draft B1k. "winds suspend 2nd tritispri'I ]'i-ge c'l[antilfes elf sand aI]d dii t, which
can reduce visibility, damage pT pe-ty and constitute a sigr]iiicant health threat." Acleiitional}y,
the `'C'claclieilti Valley is also susceptible to air inversions. in which a layer of stagnant ant- is
lrilf]pecl neat the ground where it is ftu'tber loaded with pollutants. When combined with
chemical ac-oso].3 need other pollutants emitted by automobiles, iiuzna::es and odhcr svurcbs, this
process cr]n result in substantial lialciness and a deterioration in ambient air quality_„ The,
mitigation intaSlt]res :7' i inadequate in addressing these cot}dition5.
Section 3. Noise:
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Ivtercly looking at the chart on page l.I.1-] 5 }: leads one to know that the impacts of the Genet -a!
Plan are staggering. Anyone who has visited a Iarge urbian arcs know= that it wottlti lie
impossible to maintain, acceptable noise levels when increasing the size of city from
approximately 24,000 to 207,00f
Section K. Visvt'tl 1]n]3acts'
The impact of the planning is difficult is access when viewed in light of the recent decisions of
the City Cnur]cil to allow a significant variance for the new hales from its "Cave" height
restrictions, and to allow abernl of up to 19' tall on Avenue 54, a street that was to be designated
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an agrarian corridor. The mitigation measures indicate lite "City shall establish and implement
urbane design standards which protect scenicviewslieds and enhance community cohesion."
Absent pu ise woor[]ing on these standards and gtiarantccs that the standards will lxe followed. it
is impossible to analyze the impact of the new General Plan.
Section L. Public Sci vices and Facilities'
This entire sectiorx is bases upon conjecture about Future development of a huge hand area.
Significant developer fees or new community facilities districts would be necessary io : dequaiel}' - 23
p: uvide for the increase student population.
The city library is currently significantly under -served by County standards, which evert with the
new hiiilding plans, would be e.xaccrbate by the bui Worn and the plan is vague on its correcting`G —24
these problems.
Policing_ fire protection and healthcare projections are woefully inadequate and likely Io remain G - 25
so with the fiscal shortfalls projected in the draft EIR.
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one again, the plan covers too large an area to adegnately project and plan for waste wafer fT —2f
disposal.
Basicall--, the planning area is siip]y too large for adequate planning ofinfra sirncture for a city
ofthe size of L.a Quinta. Fax too many projections ate based on "developer fees" and not on
sustainable revenue sources. Maintenance of services must he an extreme consideration when
the 1ouildnui of Annexation No. 12 would result in an annual revenue shortfall of a]7roximolely
$5, 8.7,9!}i, and buildout of the SOI amendment 7,..ould result in a negative annual shortfall or
$1,998,74E.
The draft EAR fails for adequately address the current problem: inherent in the iniras 1Tcturc. cif
the City much less the problems that will develop if additional area is annexed with the resulting
shortfalls; at the very least, a new EIR should be required for any annexations or changes of
Sphere of influence as the current craft does not only fail to fully analyze alternative plans, it
also fails to analyze the impact of changed land use on the regional economy, The fatal flaw of
Ehe Genera] Phan and draft EIR. is the proposed development and enlargement of 9 city that
already has significant problems, including the fact that approximately 49%, of the ]arid within
the city limits has not been developed despite a State policy to diwr:orit tgr uroam1 xp r iwl.
For all of these reasons, and those submitted by Mr. \\ {ir dlin and Mr. Mitchell, it is our opinion
that the rat Ent is significantly inadequate to serge as an environmental ;inpact report for {i' y
additional annexations or expansion of the City's Splie c of Influence to the cast of the current
city limiest
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COACHELL ,. CA c2223r Cn, C:•.. 1 ... .... . 39s.S34
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September 1C. 2001
Mr. Fred Baker
Principal Planner
City of La Quints
7 -495 Calle Tampicr+
L.a Qulnta, CA 92253
L+�e Er- ........
Einnsm h.-flr.e:c �;. ,39(1•'�11
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Subject. Comments on thu Dealt EF vir;arirnenial Impact, Report , CH Number
2000Dg1C23'a for the La Quinra General Plan, Annexation No. 1.2 and
Sphere of Influence Amendment.
Mr, Balser,
The City of Cna&ella is pleased to 'lave received a copy of the above rGfero."Lcod
document for review and comment Staff has conducted an initial review GI he DER and
forwards Co.'nments tor your consideration_ Staff had requested an elrension to October 3,
2001, to allow time for the City Council of the City 01 Coachella tc review staff comments
prior to submission to you, Since that request was not granted, the staff comments are
being forwarded io you by y:Jur September 1 r deadline. Additional comments may be
submitted El your hearing, Rev 1ew'oythe Cily Counci of the Cityof Goa ch'eIla V011 rRo= ur
until their meeting of September 26, 2001 • at which time comments will be torwarded to you.
H-1
The proposed General Plan Planning Area, including proposed Annexation Area No. 12 is
ar a-nbitious one, that cod potentially result in significant impacts to the City of Coechel'a H - 2
in several areas of concern.
Agriculture
The preservation of the agi-arian and equestrian lifestyle and resources within the south-
cent'al and;;outheastern portion of the Planning Area is of major con�.emn. Resulting tiDss
of agricrAuraI lands and resources throug�, conversion of existing agricultural lands to
resiclential land uses could pose a signilicEnt threat, to -he traditionally strong economy of
the Coachella Valley. Preservation of these areas is vital to the economic well-being of the
agricultural community of the Coachella Valley. From a preservation standpoint, the
proposed Agricultural Overlay (as depicted in the Recommended Alternative and
.Alternative 11) is extremely lrnoorlant to include in th•e general plan. It is understood that the
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Sep 10 01 03 : 24p C f t; ef- Loacme 1 L a
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proposed Agricultural Dverlay will allow current agricultural land uses to continue unW the
property owner chooses to develop the land_ However, is is not clear whether vacant H - 3
agricultural lands will be allowed to begin agricultural activities at t'le property owners'
discretion.
The proposed 100-foot minimum buffer between agricultural land uses and proposed
residential areas and other land uses seems too little to realistically mitigate the typical
aoriculturai DCiivities (pesticides, fertilizers, dust, nois£, odors, etc.) upon residentia, areas.
Some crops require activities and techniques done at nigrt•tirne and early morning hours, H - 4
using b^th manual labor and machinery that can be quite noisy at IOD-feet away_ Rather,
it is suggested that a minimum 300 to 500 toot butter might be considered a rror4 adequate
mitigation measure. -
Preservation of -hs equestrian lifestyle in the Planning Area should be a priority to retain
existing equestrian properties and to provide tor the development of new properties as II -5
desired by property owners.
Jr3ftic and Circulation
With a 113% increase in dwelling units (at 75°%4 maximum densities at build -out) there will
be signitrcant impacts to the local roadway system and to airport trattic, with increased daily
trips and airport service expansion, The projected increase in residential, commercial and
industrial vehicular traffic, will, potentially overburden roadways, bridges, and intersections
adjacent to and within the City ❑t Coachella. Specific mitigations such as improvements to
the streets, interchanges, bridges, and grade -separations are not identi`ied in the Draft EIR
making it impossible to identify ttie level of significance of the Impacts after mitigation. This
needs is be corrected prior to the adoption of the ERR_ Furthermore, Level of Service D is
riot acceptable as the standard LOS tor most areas within the City of Co' as is
currently proposed in the DE.IR.
UV_ ati
Consider'.ng the high number of dwellings proposed by the Recommended Alternative, the
consumption gf water and inter availability is of major concern an a valley -wide scale,
given the current overdraft cordition_ 'This begs the question of whether there is enough
water tar the projected Growth in the Planning Area. The 55% reduction in water
consumption at build-au1 as described roc Alternatives I and II are preferable to that
described for the Recommended Alternative,
There is also concern for water quality, as each alternative discussed in the document
results in additional urban development and polenCaliy new pollutants try the groundwater
supply, It is agreed that conversion from private septic systems to a sewer system could
redo :e the threat of groundwater contamination. Additional discussion of potential impacts 1 H — 8
to water supply and systems adjacent to the Planning Area should be ir cludeor especiOy
as .t impacts the City at Coachella.
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Air Quality
It i5 clear that there could be significant adverse impacts to the local aif quality from the
build -out of the proposed Planning Area under all project alternatives_ Traffic emissions.
site disturbance, grading and construction activity, and increase in utility consumption will
lead to an increase in air pollution for the valley.
5oilseoiooy,
Projected development within the P1anninci Area under any o`. the project alternatives wily
resort in a sigr'ificant increase in populat un which will be subject to nater'.tlal seisrrlC and H - 10
geological hazards.
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Hydrolo
Projected development of the Planning Area under any of the pro eut zIternativ5.s will result
in the need tor additional flood prutuction facilities and improvements.
Biology
ire acted development ot any ot the project alternative s coulr► result potential adverse
impacts 10 wildlife and native plants. Exotic plant species will ❑e introcuced into the areas
as development aeours that could dominate plant cnmrnr.nities. Domestic pets cou',d intrude
into remaining natural habitat areas and adversely impact wildlife.
Nolte
There will be an .,nrrease in variaus noise generators in the proposed Planning Area that
couid adversely impact the Planning Area as well as adjacent communities. Veh oulaftraffic
will be the dominate source ❑f the noise i rrrpacs. There could be Incompatibilities and i H - 13
conflicts between agricultural la:n l uses and proposed residential lard uses if a larger
buffer area is not required.
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Land We
The proposed Recommended Alternative will result in a 113° increase in dwelling units at
build -out (al 75%rnaximurn densities) which is a significant increase in dwelling units and
population for this area. Alternative II will result in 41,605 ewe dwelling unils ihan the H— 14
Recommended Alternative anti correspondingly result in fewer adverse impacts between
land uses within the proposed Planning Area and adjacent communities.
Cultural Resources
The City of La Quinta has a INealth of prehistor o and Historic resources that should be
given the highest level of consideration before they are adversely impacted by the
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proposed development strategy. Avoidance should be the preferred alternative for H - 15
preserving these resources wherever possible.
Visual
There is a potential for significant adverse impacts to vistas and views cf the Santa Rosa 1
Mountains, from the City of Coachella, if stringent controls are not placed upon projected
developmentwilhin the proposed Planning Area. The uridero ound ng :,f util;ties should be
a priority within the proposed Planning Area_ Wireless communication towers end
monopoles. utility towers and poles, signs, and multi -story buildings, should be sub.? ct to
strict development standards that will ensure minima+ impacts to viewsheds. The city 01
Coachella requests building heights be limited to protect view condors of the local
mountains from properties within the La Duinta.
Public Services/Facilities
The City of La Quinta is currently uriderserved in fire, police, and library, services. With
such a large proposed Planning Area, it will be critical that adequate services are provided
as development occurs so that them will not be adverse impacts upon adjacent
communities and their service resources,
Sacio-economics
Adverse impacts to the agricultural and equestrian lifestyles is [Doter tialysigrrifi;arit u+�less
the proposed Agricultural Overby in adopted as indicated in the Recommended Alternative
and A!ter^ative II, There has been a lengthy tradition of these lifestyles in the Scutt central
and southeastern areas of the Planning Area.
Additional Information
Environmental Summary Matrix:
The Environmental Summary Matrix does not include a column fos the discussion of
significance after rnOigation lor each Issue area. Without this information, how can over-
riding findings be made?
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here is no discs. Sion about impacts and mitigation measures under TrnfficiCircj:ationfor 1I - 20
the Desert Resorts Airport.
Significance ievefs are not clearly stated for several of the areas of concern_ These s'iouJd
be added to the document and to the Pro}ect impacts column of the matrix.
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Discussion needs to be added to the DE!R that identifies specific impacts to the Cities of
fndio and Coachella, and quantifiable mitigation measures. H - 22
jep lu VL v7 4oaCnel le
rua
The energy crises needs to be discussed in the DEEIR, including both electrical supp}y and H - 23
rtiaturai gas resources.
Additional comments may be forthcoming as slat' continues our review cl the DEIR. Should
you have any questions regarding `has setter, please do not hesitate to contact Leslie
Hudson, Associate Ftanner, who can be reached at (76O) 398-3102 x 242
Very truly yours,
426'4
Susan E./rilliams
Director of Community Development
cc: Byron b. Woosiey, City Manager
Sep ]D f]I C3:27p City of Coachella
?GO 390-542] p.
Attachment:
Page I-13; 12ble 1-2, Land Use column, 0 Office34, Is this a typo`?
Exhibit 111-1: City of La Quinta, Existing General Plan- This exhibit coiltusinc with the
County desidnatians included, V
Page III-16 is printed twice.
Page 111.21- paragraph 1, line 1, "at" should be z.
H 24
H 25
II-26
H-27
Pages 111-26: lndirerk Environmental Impacts section, should inc:ude discuss:on on specific p - 28
impacts tc the Cities of Indic and Caacnella.
Pages 111-91 and 92: !s there a conflict with the number of dwelling units indicated on Page
91. paragraph 5, line 2 , "78,9.52 dwelling units-..", and Page 92. paragraph 5, line2,
"___66,81 t new dweII.rkg units" 7
Page 111-12{ paragraph 4, consider stating that the City was actually certified as a CLG H _ 30
in April of 1995; Aso, the reference to Appendix K is obsolete.
Page 111-143 Subsection Q, should include the requirement that truck loads lie covered- 11 31
Page 1I1-1 e : paragraph 1, this discussion should be updated as the MW :retain Vista Schook
opened September at 2000 and is in full operation. II - 32
Page IlI-t7O: Existing Concfitions, Since The existing library in La Quinta is currentky
undeserved, and the proposed new library will not meet the alarming standard, will there ' H - 33
rat be an irrkpac, upon other adjacent libraries?
Page III-185: paragraph 1, 11ne 2, GTE is now Verizon H - 34
Pages 111-185-166: Electricity: Consider adding a discussion under Cxisting Conditions
on 117E current paver Cnset and the proposed power plants in the vailev.
H-29
H-35
Pageslll-188-189: Natural Gas: Consider addin,o a discussion regarding the current suppler H _ 36
of natural gas in light of the power crises under Existing Conditions.
Page ill-195: Table 11I-41: Why are employers outside of the City of La Quints included :rti H - 37
this table when the title indicates thal they are inside the City boundary?
Page V-9: Tab le V-2• The Commercial Subtotals ors this table and Tatrie `tr-3 are different.
Is them a reason? H - 38
• r7 r c I T, o f
'IIA WELLS
Gt111' 0 k 11
August 9, 2C01
Fred Baker, Principal Planner
CITY OF LA QUINTA
7$-495 Calle Tampico
La Cuinta, Galitcrnia 92253
E 1 I V F
AUG I 321101
CITY OF LAMINTA
PLANNING DEPARTMENT
RE: DAFT ENVIRONMENTAL IMPACT REPORT (SCH NO. 2000091023) FOR THE LA QUINTA
GENERAL PLAN, ANNEXATION NO. 12 AND SPHERE OF INFLUENCE AMENDMENT.
Dear Mr. Baker;
The City of incl:an VVells has reviewed the above referenced DEIR relative to possible impacts on the
City or surrounding adjacent areas. We offer the following comments for your consideration:
1. The descriptions of the adcp;ed land uses in the City cf Indian Wells on Page No. 1.10 and
I11-7 are inaccurate. The area west of Fred WarirrC Drive adjacent to the Garden of
Champions, is currently zoned for Resort C❑MMercial uses and not Community Commercial.
Please see attacried exhibit.
2. The existing hillside woos (between Indian Wells and La Quinta) are not appropriate for the
proposed Comrrunity Commercial and High Density residential Lard Use designations as
depicted in the Recommend Land Use Plan illustrated in Exhibit 1`I-2, Any development
within this area, as proposed, would severeiy impact the adjacent residential areas within the
City of Indian Wells. A Hillside Overlay designation should be placed on tl,.ese areas to
protect the resources.
3. As tie' di cusscrns, stiff has observed Feiiiii uiar Big 1-kri' Sheer. on ;ilc I1�aij
area adjacent to Point Happy Ranch. This information should be included in Exhibit III-22,
See attached color photos dated 5/9195.
Sri
I
We appreciate the opportunity to review and comment on the DEIR. VVp would like to request that we
receive a copy of ti'1e Final El and General Plan, when It is available_ If you have any questions,
please cor.tar eat 760 229 or FAX (760) 346-0407,
Sinter
Larry ra ••n,
Senior Planner
LGlbjb --
I
-2
44-9 O lildnradro Drive a Indihn VVe!1s Ca]iIorriia a 92210-.1497
F',F AFIBARAx.LETTEPSTaker,lsr_doc (760 3415-24g9 a FAX (760) 3L1-6-0407
htta,ffwww.d..inr'iarl-we Iis.4;I,u6
Ill MU
Source: CIfjY of lnfil Wells
Updated: Fiovember 301112.0D0
i��y WELLS GENERAL FLAN
+mwws crnw.sls
See text for discussion of land use goals and policies.
u WPM.. air r..ns
LAND USE LEGEND
RESIDENTIAL
I Very Low oursiCy
0.0-3.4 dorect
I__-- I Low ❑enally
f3.7-a.5 dufecl
I •j Medium DensNy
(4,0.7.4 dufac)
Ili* Hod. High £Wro ty
I7.1-12.0 dufacl
COMMERCIAL
Imo;:! Plafeswor I
Ofii*O
MN Resort
t nrnrrtercaai
GO' and
RtiGpailon
Public Fart
Cgmrrun'sty
Commerc3a I
Sporrz
Complex
OPEN SPACE
Open Spews
Putalic FaciIity
;tom Nalarel
P:esesua
t� J Wali rcre.pme
CIVIC
Spat4e1 Study Area Naga,
Lard Use Plan
PIGU)
1IA-
pire_may-ig57135n.,:10
Photos (kaken on 5i9i95 at 11;40 a.m.) of three (3) SiglHorn Sheep on a ridge adjacent to Point
Happy between City Of La Quirita and Indian Wells,
i!.� fr iL5G% ;} wt:13 C3rst3 li
F+--R r -5H
GARY MITCHELL Si ASSOCIATES
• LAND PLANNING
• REGISTERED ENVIRONMENTAL SERVICES
(909) 798-3130
FAX (909) 798-3727
7. L. CITRUS AVENUE, SOU 2[1 • REDLANDS, CA 92373 • E-,»TAIL gar.emiteigiioirnail.cnm
September 10, 2001
Mr, rred Baker: Principal Planner
City of La 0uirite
7S-495 Calle Tampico
I- a Quints, CA S2253
SUBJECT: Comments Regarding Draft Environmental Impact IFp
(SCH Number 2000091023)
Dear Mr_ Raker:
n
-To►�
or
°F DEPARTM
LA�rrly
I have been retained by the Vista Santa Rosa Association to provide you with the
following comments relative to this draft Environments' Impact Report. The t Mowing is
based upon my review of the draft EIR and draft Comprehensive Genera Plan,
annexation area, and proposed expansion of your City's Sphere of Influence.
Specific Questions & issues to be Addressed
• The proposed project represents a fundamental transformation from a low
density, equestrian -oriented and agricultural-re!.ated pattern of land uses
which have existed for many decades to a highly developed urban pattern of
j - hand use allowing up 016 dwelling units per acre. Tne socioeconomic
impacts of this project to tre existing community have not been adequately
addressed by this draft EIR. --
• Rnalysis of required project alternatives. (including ''no project"), are ranked
as having simiar impact levels to various environmental resources_ This 1 - 2
R
statement deserves to have greater description and needs to oe able to
justify this blanket conclusion_
• The draft EIR dos riot adequately assess the fiscal impacts o t proiec.
upon the community. No fiscal impact analysis has been provided that
specifically adaresses the direct as well as indirect fiscal costs and benefits of
the proposed project The public infrastructure investment to support the
magnitude of the proposed development is enormous in comparison to the
maintenance of current development intensi'y. It the draft EIR is correct in ds
projected budget shortfal of $ 5.387 Million per year, there how can the "no
project` alternative be dismissed as to fiscal Impact analysis? Furthermore, if
this fiscal assessment is accurate, then what incentive is there for the City of
La C uinta tc pursue The proposed development, annexation, and expanded
City General Plan planning area?
• The noise impact analysis appears to be inadequate as to e eE
growth of the Thermal Airport, The noise contours depicted in the daft EIR
appear to have been borrowed from prey o:Js studies which were prepared
with the assumption that the current low-densi:y agricultural an use pattern
would be continued. The incremental increase of permitted development
1
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•cl
� � dt t CO'TO tot deS
LELi,962.e,06;}4O EH IZO2U
I :r1 io-91- 0
proposed. (up to 16 dwelling units per acre), would be expected to have more
severe impacts from noise as the Thermal Airport continues its expansion
and air traffic volume_
• LDS5 of prime agricultural land and production area will be very substantially
and negatively impacted by this project. The draft EIR does not adequately
assess these impacts, nor does it provide effective environmental mitigation
measures to lessen these impacts, Loss of prime, productive agricultural
lands is a permanent impact with lorLg--,erm impi„ations_ Agricultural soils
cannot be reclaimed tortuture use; therefore the assessment of the
preservation and enhancement of prime agncultural soils is vita'. to the
assessment of this project and its impacts to the community. —
• The anticipated real effects to current residents and landowners concerning
the keeping of horses, rasing cf agricultural crops, and operation of
businesses related to open spade have not been assessed. There is
inadequate provision made for the "grandfatherirrg' of current land uses,
structures, and investments made by the many farming, businesses and
others who have lived in the community for many years. �-
There is no env»ronmental analysis reviewed which speaks to the issue cf
haw a proposed rfeveLoprnent project can attain a density of up to 16 dweI ing
units par acre_ In lieu of such development standards, the draft EIR must
assume. a "worst case" development scenario of 16. units per acre for the
entire planning area. That analysis has not been done.
Summary Polatrix
▪ The area of the proposed build -out is described as 53,498 acres.
What is the proposed build -out population, in terms of dwelling units and
residents?
• The EIR summary mentions "moderate" increases of residential $
commercial uses. Miat is meant by "moderate"? Define in terms Df maximum
build -out scenarios, and relate by % to current City of La Quints land use mix
to assess the use of the term "moderate"_
▪ The Summary mentions the proposed General Plan forecasts residential
densities up to sixteen unites per acre. How is This level of density consistent
with the statement "__.continue the low intensity development pattern already
established in the City"?
• The draft General Plan forecasts 6,280 acres for 'very !ow ensity residential"
developrent, ever though the planning area comprises 53,498 acres. How
does the EIR base its statement that land use compatibility is assured by the
General Plan?
• Traffic/Circulation impacts are described in a separate study. What is the
assumption of traffic operating levels made in that study? Is traffic level "C"
being assumed? The EIR describes operating levels at level "17" currently
exist in the City of La Quinta. What is being proposed to mitigate this
significant adverse impact.?
• The traffic circulation section makes no mention of worriprehensive
mull ipurposc tails or related circulation improvements other than a golf cart
route system. How can the proposed development be consistent with the
environmental character of the area without a trails system linking equestrian
el - 4
J - 5
J -G
-7
J-8
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J-10
J-11
J-12
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f.z�.Er3B� G0�
d1-10 -Ea ID Di de.$
L /,'GHFFsL50€11,1Qi3,3 Qar.I 1
9S't}T IE4--NI- riE1
and jaggino areas with other areas located in the City and in adjacent areas,
Le. polo club area?
• The EIR slates that ".._Less Intensive Alternatives would result in all
intersections operating at Level of Service D or better_ What is the justification
for this conclusion? The EIR seems to sugges: that only the intensive
development scenario proposed will improve Phis circulation system. Why
wouldn't a lower level of dwelling units and population require a lower level di
traffic and circulation improvements? The India General Plan, whose planning
area is contiguous to the proposed project area, assumes service level "C" for
traffic improvements- Has the draft E!7. analyzed tt'e effects of the
inconsistency between the proposed pre ect and the existing adopted land
use plan of a neighboring city?
• Solis & Geology, The EIR concludes that ".,.build -out of the General Plan is
not expected to significantly increase risks associated with groundsnaking
and other seismically induce Hazards,_." What is the evidence analyzed that
would support this conclusion?
• Visual Impacts- What development standards hoes either the propose+
General PI2n or draft EIR provide to ensure he preservation of the unique
and valuable visual resources of the Santa Rosa Mountains and viewshed?
• Ground surface disruption will result in substantial wind erosion an re a ea
environmental damage to the community. What mitigating measures are
proposed to alleviate INS unavoidable impact?
• Hydrology. The EJF.stetes that conversion of low density agricultural larid to
urban development could result in increased run off." What analysis. has been
performed that contrasts the projeol alternatives? The EIF. consistently states
Mat "only the Recommended Altemative" wound result in acceptable
environmental risks, and that it ipacts dottier alternatives woulc result in the
same levels of impact. Hoer is this xrlcrusion supported by a reasonable
alternative comparative analysis?
▪ Bictopical Resources. 7he EIR states that the iow-density development (up to
15 dwelling units per acre) pattern proposed by the General Plan is not
expected to result in adverse impacts to existing biological resources. What is
the justification for this conclusion?
• Cultural Resources. The EIR mentions several rn tigatirig measures by
suggesting that the City might consider adopting historic standards and other
nen-existing policies relative to preservation of cultural resources. How can
these rniligation actions be effective if they are not adopted prior to
development?
• Noise Impacts. The noise estimates for the Thermal ,Airpurl devebprnent
scenario apoear to reflect the continuation of historic land use patterns. Has
the draft EIR adequately taken into account the proposed urban development
scenario as analyzed from noise impacts as are expected at the Thermal
Airport continues to grow and experience greater air traffic volumes'
• Fiscal limpaots, How have the fiscal impacts been addresse wi out the
preparation of a new fisca' impact analysis' The public infrastructure
improvements required by this magnitude of development will require
substantial investment from both the public and private sectors- The faecal
impacts of this need to be specifically addressed to the "worst -case'
development scenario, up to 16 dwelling units per acre- If ttie draft EIR is
accurate in its estimate of an estimated fiscal budget shcrtfa11 of $ 5 Million for
7
-13
J-14
J-15
J-16
J- 17
J - 18
J- 19
J-20
J-21
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>?•d t.?4EB6L❑d1; UW❑ dET EO 10 ❑1 claS
L::SGEL66,6: F{0Q3f1 JTa2H
L q : t' [ T 6 - @ r - 60
the provision public services to support the required level of infrastructure
imprmvernems, then how can the ElR dismiss the "rrc project" alternative?
• Agricultural Resources, The Coachella Valley is world-recaanized as a
leading agricultural production area. Why have existing valuable agricultural
soils and production lands not teen adequately identified by mapping or other
means by this draft EIR?
• Eioiouic Rc:;aurces. The drat EIR references the preparation of the
Coachella Valley Multiple Species Habitat Conservation Plan, (CV MS-1CH)
Has a separate biological assessment, including field assessment, habitat
survey, and field observation been performed for this environrnerrtal study?
Since this work is currently being undertaken by the public agencies
identified. how can the project impacts to existing biologic resources be
adequately assessed until the CV MISHI-i has been adopted?
• Wier CrualitylResources. The EJR reeds to state the comparative demand
for water resources and concomitant adverse environmental impacts to be
related to the Project Alternatives in a more comprehensive mar rim
• What is the impact of the projeci tc the contaminetior of the Salton
Sea drainage area?
• Has the EIR taken into account the recent gro.mdwater drainage
program utilizing 'tiling' for the owe Thermal water sub basin? What
are the impac:s of the continued use of this water management
system to the proposed project?
• how does the draft EIR analyze the expected impacts of the
wastewater effluent to be generated by the project as to existing and
future groundwater quality and quantity?
Or bete of the Vista Santa Rasa Association, your responses to these comments are
both appreciated and are required by the California Environmental Quality Act_ I will be
most interested in having the opportunity to review your responses and to follow this
project carefully.
Thank you for your con sidetation.
GARY MITCHELL & ASSOCIATES
L12-ii/(AeW
Gary W.(�ltitchell
Registemd Environmental Assessor
4
J - 22
,T-23
J-24
- 25
CCLCRBLFtlF uWF7 d3T CO'id di clac-
July 23, 2001
Ms, Nicole Sauviat. C:riste
Terra Nova Planning And Research, Inc.
400 South Farrell, Suite B-205
Palrn Springs, CA 92262
Dear Ms_ Oristc
B1FI
K
Desert Chapter
I.li,I1,,1l� 31L+III [I .ti,-1.41L111151]
1,i .`' I.I 1I+'I'rs [.i1I1 Ii1i'Iit�i
RLII' ' 111 ul7Gi+1."'1I
After a careful rffrview uf Lhe draft environmental impact report (SOH number 2000091023) for
the i-.a Quin -La General Plan, Annexation No, l2 and sphere of influence amendment, we have the
following comments:
R
sp
Page M-10 and other sections in the document: You appear to consider data only through
199X and do not take into consideration that Ike valley is presently in a serious non -
attainment status and in danger of being reclassified as as serious non -attainment area.
There is no reference to increased requirements for dust control and more: specific dust
control plans.
K 1
Page III-115: Paragraph K is badly worded in that it would acquire a "barrier" around the
entire site, not just that portion that "borders" the hillsides. 1t woukl require a "barrier"
only if the sheep are "detnonstrated to occur on the project site" not on the adjacent K - 2
hillside. What is the reason for the informal consultaticnr? To provide the basis for need?
Fen r e dsign? w
ey
Executive Director
.L, .I` ii:11•' 4141. "j1.14L•Uh11 •.....y111ii.11 •r; lit, rrr.. ;j111�ri1••'—., rrII 41.. ' .I1r•Ir'I+IJr .11 Lii! i .4 114:1,• 1„- ...ar,•,141..,r1
United States Department of the Interior
BUREAU Or LAND MANAGEMENT
IN REPLY REFER Try'
1790C
CA€a0-26
Mr_ Fred Raker
Principal Planner
City Qi La Ouirtta
78-495 Calle Tampico
La Cuinta, GA 92253
Dear Mr. Baker,
P; �m Springs -South Coast Field Office
090 West Garnet Av^nuc
PA). Box 581260
North Palm Springs, CA 92258.1260
Visit us on ;he Interne! a.r
w wtiv. Ca. f7f m. gc'dlpn 1rrrs'p ring s
A1J6 8 2001
AtiG 29 2r•;
We appreciate the opponunity to review the Draft Environmental Impact Report for the La Cuinta
Comprehensive General Ran. We would Ike to offer the faklowirg comments.
1. We ask :hat the plan identi'y 1DLM-managed public lands rithin the City limits as Being under the
jurisdiction of the BLM and to d..knowIedge the management responsibilities of the ELM on these lands
under eaerai -and Policy Managcrnenf Act of 1976, •wlderness designations uncertrie California Desert I L - 1
Protection Act of 1994, and the Santa Rosa and San Jacinto Mountains ,National Monument Act 4f 2000.
(Page I-3, I-9, 11-9, Ilf-7, [11-12, IIf- ,0, exhibit I-3, Map 2 within Appendix C, Biological Report),
2. The city's Hillside Ordinance protects the moun:sins "above the toe-of-slcoes", page •III-5, which
means the alluvial Fans would be developed, We suggest that this be considered as an impact to bighorn
sheep and as a cumulafiv'e impact throughout the Coachella Valley_
3. On page II1-101, third paragraph, the documer states "Projects receiving federal lunding will be
required to initiate consultation with the USFWS 10 determine if the proposed activities will adversely
madly (b'ghorn sheep) Criticai Habitat." 11 is our understanding that all projects affecting critical hahita •
regaroless of the funding source, require corsultation with the U.S. Fish and Wildlife Servicejln addition,
we recommend the addition of ttlgharn sheep to page IV.3, second paragraph_
4. We recommend a feral cat control program and dog leash requirements within the ass and
San Jacinto Mountains Monument !o discourage pets from preying on wildlife at the Midland -urban
interface and other areas (page 111-1 14),
RLM aprecates the efforts PI the City of La Quinta in contributing to rflulti-jurisdictional coordination
efforts including the trails working group. We are interested in pursuing additional collaborative
man lgement projects cons }tent w.th the General Plan and the BLM's planning documents. Please give
me a call if you have any questions at (7Ga) 2 1- 4800. Thanks again for including us in the Draft 'eview
process.
Sincerely,
.fames G. Kenna
Field Manager
-2
L -3
L -4
• - 5
Uerio/UI 15t51 FAX 7EO 431. 594i
U5 LEIS$ AND PVtLbLIFr:
WJO302
LIS Fish and Wildlife Service
Carlsbad Fish and Wildlife Oifi
2730 Laker Avenue, 07cst 4775
Carlsbad, CA 92008
(760) 431-9440
FAX (760) 431-5902 + 961S
CA -Dept. of Fish & Game
China Hills Field [)Bice
Bird Farm Road
Chino, CA 91709
(909) 597.5043
FAX (909) 597-0067
in Rcp1y Refer To:
FWS-ERIV-2202.1
SEP 1 0 2031
Mr. Fred Baker
J riacipal Planner
City of.La Qtunta
7E-495 Calk Tarnp3cu
La Quinta, California 92253
Re: Draft Environmental Irripact Report (SCII Number 2000091023) for the La Quint a
Comprehensive General Ilan, Annexation No. 12 and Sphere of Influence Amendment
Dear Mr. Baker:
Thu U.S. Fish and Wild].ifc Service (Service) and the California Department of Fish and Larne
(Dapartrnent) have reviewed the subject doeumcnt. We provide these comments based on our
respective administration of the Endangered Species Act of 1973, as amended (ESA) and the
California Endangered Species Act (CESA), Take of listed species is prohibited under section 9
of the ESA. and 2aa0 of the CESA but can be authorized under sections 7 (Federal cansnitations)
and 10 (incidental take and recovery permits) of the ESA, and sactious 2080.1, 2081 and 2835 of
the CESA.
GENERAL COMMENTS
The Gcnaral Plan area contains a unique assemblage of wildlife and plants, including many
declining, endemic. and listed species. For desertfloor species dependant upon sandy habitats on
the desert floor, the Coachella Valley Fringe -toed Lizard Habitat Conservation Plan and CVAG's
multispecies pinning effort are primarily focusing on bioregional strategies that would conserve
larger blocks of intact habitat in other -jurisdictions outside the City of La Quiirta These plaEming
efforts do not include habitat conservation objectives within the City because remaining patches
of sandy habitats are becoming too small and isolated for species to survive over the long-term_
As such, the plans have and are identifying mechanisms for the City to participate by offsetting
the adverse effects of implementing- its General Plan by collecting few. to acquire offsite habitats
in other areas that 'haw higher probabilities For species' tong -tee survi val.
We support the City's proposed adoption of policies that would require sn veys forprojects that
may adversely affect the various species proposed for conservation coverage under CVAG'a
multispecies planning effort. Though most of these sensitive species are not currently afforded
M
IVI -1
M - 2
M-3
4D}14I01 15:52 FAX 7E0 431 `ACO
US FT Mt AND IV1LDLIFE Z003
Mr. Fred B alter
State or Federal protection, most are endemic to the Coachella Valley and have declined
significantly in their distribution and abundance, primarily from habitat loss and degradation.
For example, the geographic extent of species dependant upon active sandy habitats have
declined historically by over 95 percent in recent decades. The biological information compiled
and analyzed by CVAG' a multispecies planning program documents current threats and the
status of these species relative to their modeled historical distribution. The ruultispecies program
is treating these species as though they were listed by the State or Federal governments and is,
therefore, formulating conservation strategies based on the premise that they warrant protection.
Therefore, we recommend the City adopt a policy to consider those plants and animals that occur
within the City and. are proposed for con gervntion coverage under CVAG's multispeeles Planning
program to be endangered, rare, or threatened species, pursuant to section 15380(d) of the CEQA
Guidelines. This would provide the City a more effective mechanism to offset the most severe
biological effects of implementing its General Plan and also help assemble a regional habitat
reserve system its the Coachella Valley before those opportunities are foreclosed elsewhere -
We generally concur with the intent of the draft goals, policies, and programs to conserve
biological re -sources in the draft Comprehensive General Plan (pp. 62-63). However, in many
cases, these biological objectives Likely will not be realized, given the stated language waveats
(e.g., "to the greatest ex.terat practical" and "shall consider requiring") and several zoning
contradictions. For example, despite the stated goals ex -messed in Policy 4, Program 4.1, and
Policy 5 (pages 62-63 of the draft Comprehensive General Plan), the proposed zoningtland uses
fail to provide for con. ervadon of unique andlor valuable biological resources in seNeral
important areas, protection of the .Peninsular bighorn sheep, and buffering of sensitive habitats
From urban development (see ciikcussian below formore details). The draft Ell?, briefly discusses
the effects of habitat loss on bighorn sheep but does not analyze how the proposedndtigation
measures would ameliorate significant impacts. The offered mitigation measures (policies on
open space and hillside development) should be analyzed relative co recommended conservation
program in the Recovery Plan far Bighorn Sheep in the Peninsular Ranges, California ([ISFWS
2000). The disparity between implementation of the draft Comprehensive General Plan and the
conservation objectives in the Recovery Plan indicate that conflicts with bighorn sheep would be
significant and likely would preclude achievement of the recovery objectives for the ewe group in
question (see discussion below).
Water courses and alluvial fans in the planning area support De.sertDry Wash Woodlands:, which
renresent a rare plant community recognized by the State. This plant community is comprised of
seven species that are protected under the California Desert Native Plants Act Division 23 of
the Food and Agricultural Code (Fish and Game Code Sec. 1925). These desert woodland
habitats support a greater diversity and abundance of wildlife than other desert habitat types
(England 1984). In addition, these area also provide critical and essential habitat for the
endun ered penimular bighorn shocp.
The Department encourages the conservation of these watercourses and opposes their
elimination, channelirataon, or conversion to subsurface drains. All wetlands and watercourses,
whether intermittent or perennial, trust be retained and provided with substantial setbacks that
ODliO/O1 LE:53 FAX 7513 431 5D01 US FISH AND WILOLiFE
Mr. Fred Baker
3
preserve riparian aid aquatic values and maintain their value to on -site and off -site wildlife ' M - S
f populations. The fluvial channels on alluvial funs axe considered regulated water courses.
The Department has authority under Fish and Game Code sy 1500 et seq., regarding any proposer)
activity that would divert, obstruct, or affect the- natural flow or change the bed, channel, or bank
of any water course or body of water_ A discussion of potential adverse impacts from any filling,
grading, increased runoff, sedimentation, soil erosion, and/or pollutants [-in water bodies on or
near project sites, with mitigation measures to alleviate such impacts, must be provided to meet
permit issuance criteria. We, therefore, recommend ti t the City adopt policy that would
corripliment this trust responsibility of the State.
SPECIFIC COMMENTS
Page ), 112-113. The section. on "Potential Impacts to Mamtitals" does not adequately address
the cumulative effects of buildiilg-out the proposed General Flan. The extent of urban
development contemplated in the Travertine specific plan and up to 4 units per acre (Sow density
residential zoning) in the adjoining section 5 would eliminate many hundreds of acres of bighorn
sheep habitat and introduce hig't levels of Human disturbance into remote and sensitive areas that
currently support a stable bighorn sheep population. Zoning at up to 4 units per acre in
designated critical habitat conflicts with Biological Resources Policy 5 by not providing for a
biologically appropriate transition or buffer hetwcen urban land uses and mountainous/alluvial
bighorn sheep habitat. To address this conflict, we recommend that the City identify strategies,
such as more biologically appropriate zoning; and a habitat acquisition program, for conserving
these and other private. lands in bighorn sheep habitat that are vulnerable to and coned tor future
development.
As described in the Recovery Plan, alluvial fans provide important foraging habitat for bighorn
sheep, and the numerous canyons draining into the Travertine fan provide important perennial
water sources along then lower reaches, as well as lambing and rearing habitat. increased levels
of human recreation, including the focused attraction of humans to desert water sources and
oases by the many thousands of new residents supported by the planned urban development (on
the alluvial fan in question and throughout the General Flail arca at large), likely would be
sufficient to displace future bighorn sheep use of Guadalupe, Devil, and Bear canyons, which are
critical to maintaining a stable population in the local ewc group. Please refer to the numerous
citations in the Recovery Plan that document the adverse behavioral reactions of sheep to Duman
disturbance. Given tht inability to replace the functional loss of these scarce, yet critical
foraging, watering, lambing, and rearing habitats, the proposed General Plan would. reduce the
size of the remaining home range of this ewe group, and consequently reduce the capability of
the diminished home range to sustain future populations at current levels. Such a population
destabilization and associated declirl would constitute a significant adverse effect resulting from
impiemention of the proposed General Plan.
imilnrly, the recreational and other pc tentiai land uses designated for sections 13 and 24,
immediately south of La Quinta Cave, have the potential to disrupt bighorn habitat use patterns in
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D 1D 01 15: 54 FAX 760 431 5901 US 7ISII AND WILDLIII±:
Sep 10 C71 03.48p State o pt of Fifth & Gnme [BM 597-00E7
rot}
p.2
Mr, Fred Baker
4
surrounding areas. For example, the mountainous peninsula bordering the Cove on the east
currently is used as lambing habitat, and its use cad be discouraged err eliminated if human uses
in the area south of the Cave are not properly rnane.ged. The drag MR or subsequent document
should more carefully address and offset these significant adverse effects to bighorn st►s-a:r_
Page 111-114, Mitigation Measures. To address our concerns described above, General Plan
policies should be adopted that more effectively (1) cur serve bighorn sheep habitat and establish
strategies or implementation mechanisms to accomplish this objective, such as creation ofa
habitat acquisition fund, (2) require appropriate avoidance, minimization, imization, atYd mitigation measures
for proposed habitat losses, and (3) require completion of a trails management plan prior to the
construction of any further projects in bighorn sheep habitat. The trails plan should be subject to
the review and approval by the Service and Department and be coordinated with the trails
uianagouat program in preparation under CVAG's muItispecies planning effort, The plan should
include a comprehensive system of appropriate signs, truileads., manageanent and eaforcernent
capabilities, and other factlities to manage access along the habitat:urbann interface to afford
effective control of human uses iu adjoining bighorn sheep habitat.
Page ID-115, item H. The re commended burrowing owl surveys should be expanded to include
other habitats in addition to agriculture, givers the species' wideTread occurrence throughout a
variety of habitat types in the Coachella Valley,
Stem K_ We recommend that the City modify the mitigation measure and pokyta
require, not just "CO -snide, a contingency -eased measure, as described iu the R.ecczvery Plan
Accordingly, for new projects that create a potential attraction to sheep for tubari sources of hand
or water, the City should adopt a policy tlktat would require project -spew conditions of approval
for future fence construction should shy Become att a wd to urban area. To be worlabic, thin
contingency new-:hanisrn should ptunride the whezewithal o require future cartstractsan of a fence
if sheep problems aniSe. Providing the wherewithal would necessitate (1) de..4ication of a f:-a=:i.os
easement, (2) provision of a funding mechanism and (3)establishment of a responsible party, at
the time of project approval.
We appreciate the opportunity to comment on the proposal. Please contact Itrim Nicol of the
Department at (760) 251-827 or Ken Corey of the Service at 060 431,9440 ifyon have
questions regarding the issues raised in this letter.
Sincerely,
Sincerely,
Crleun Black Nancy Gilbert
Habitant Conservation Supervisor Assistant Field Supervisor
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B9-i8-91 14:3r3 CI-Ly of [.5'Iutnta Comm.Dev.Dept 1D= 76G 777 1233 P.R2
Lee Anderson, Jr.
59-777 Calhoun Street
Thermal, CA 92274
September 10, 2001
Mr. Fred Baker, Principal Planner
City ❑f La Quu3ta
7$-495 Calle Tampico
L Quirita, CA 42253
RE: La Quinta C14
Dear Mr. Baker:
1 am taking this opportunity to cornmeal on several issues in -the report that may not be
addressed by others_ Thcsc are thoughts that need to be addressed i fLa Quinta, God
forbid, should be able to annex our area. This area is in the county, east of Munroe: Strut
and historically agriculture_
For most cases agriculturel and equestrian uses shouldbc interchangeable and Lam using
that prcinise in my suggestions.
Agricultural _Resources Page M-2:
(1) The report states that the agricultural overlay "provides for contintuaLion of existing
agricultural activity at the discretion of the landowner until he chooses to chance :ts use"_
This is not good enough. Let agriculture he a permissive use in any area, or at leis[ in
areas that have The La Quinta designation of very low density and low density uses.
Agriculture cannot be protected by an agricultural overlay. li needs its own designation_
An apiculture zone should be basic and agriculture should be a permitted use in any area_
Landowners and the city need the fie iniy to use land for agriculture should an economic
downturn slow building development.
(2) Under mitigation measures there needs to he added ptotectiott for land# that is already
in agriculture, La Quinta should enact "bight to Farm" legislation sirn:lar to that in effect N - 2
in the Riverside County area.
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, A Vol L 1 4J' L1 Yv 111 1l144 vNlYW .SIGY •y y r 4 ii7 — 4 4.f 53 4 +1Ld—
(3) Water Quality Resources Page44-7:
The study states that it estimates that approximately 4.0% of demcstic water corrsurnetl
would be reabsorbed into the ground water table. This Ls not true in the middle talk
area due tv uum err,us clay laycrs that prcvcnt percolation. This is why much of the farming area contains tile Iines.
Thank you for considering these comments, l regret that you allowed only an additional
two wcck extension for study. proper tidy of a repon this big needs more time,
especially during the summer months when so many people take vacations.
Sincerely,
Let Anderson} 3r.
N - 3
Kay Wolff
P.O. Box 1016
Lom Quinta, CA 92253
September 9, 2001
Mr, Fred Baker, Principal Planner
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Dear Fred,
q
ECEI1V °
I "
SEP 14 2Bil L�
CET( OF LAUJI NIA
PLANNING DLP4HTMENT
I am writing in regard to the draft La Quinta General Plan, Environmental Impact
Report, and Master Environmental Assessment. The .implications .of the Annexation No.
12 and Sphere of Influence issues are quite disturbing, as well as the tack of specificity
in the General Plan. In it's current boundaries, the City is projected to face a wonderful
economic future (DEIR Tables 11I-46 stating a projected $20. million annual net positive
cash flow). We are in a position to fulfill the- dreams of our residents: wonderful
neighborhoods with a high level of safety and varied amenities for all: young and old,
rich and not -so -rich. I assume the fulfilment of this dream. is .the goal of the city staff
and the council and commissioners,
The Draft General Plan and DEIR not only appear flawed, but seem t detract from La
Quinta's rosy future; I refer to. these points:
1. The General Plan does not spell out any general locations, acreage, or percent of
acreage for parks, trails or other public use lands, These uses are lumped together
with calf courses, which are a) mostly private, b) costly for citizens to use, and c)
severely impact our water supply, due to the residences that .typically surround
them, .Irt.order .to insure the quality_ of, fife of our_ residents, we need to specifically
assure that facilities for youth and adults are abundant and conveniently located.
Where are the formulas (minimum expectancies) for parks and open space? Open
space needs to be more than mountains and golf courses. We are below our
guidelines for public parks within our current boundaries: letsfix,hat first.
2. The verbs used in the General Plan are too loose: "encourage try to, evaluate,
consider, pursue, etc." Flow about setting some specific goals? .How about some
"wills and shalls'? 1 e'can afford to be selective and make demands on developers,
3. Irt order to avoid the negative impacts of water, traffic, noise, pollution, and Toss of
cultural heritage as pointed out in the DER, I believe. residential developments
should- be exclusively -"very - low .density, residential" and ,interspersed with open
space and public parks and trails. If developers of highs medium, and low density 0 - 3
developments don't like our zoning, let them take their developments elsewhere.
We can afford to be picky. Why become a high density community when we are
positioned to be the most desirable city in the Coachella Valley?
0 - I
0-2
4. The DEIR clearly points out the many negative impacts of the potential annexation
of Annexation No. 12 and the Sphere of Influence. These very. .negative impacts
need to be clearly publicized to the community before the passage of any plans. For
example, -
a) The possibility of being a city of some 208,000 is horrifying! Who moved to La
Quinta to be in a big city? Let's take good care of what we've got, and not
plunge into the managerial and safety morass of a metropolis!- Do we want to be
considerably larger than San Bernardino?
b) The annexed areas would be a tremendous financial drain on the current city,
with an annual negative cash flow of almost $7 million (DEW Tables 111-46 and
47), Since LAF.Co has- stated that La Quires annexation wrill .not be "piecemeal",
that implies that we will have safety obligations prior to the development of rnost
properties, We will have financial responsibilities without significant revenue to
offset these .costs, With assessments already, afoot for polio and fire protection
inside our current boundaries, what wbtild that mean for the future? Most
citizens are against assessments for such services, especially when they may not
favor annexation in the first place.
c) The DEIR mitigation measures to resolve water issues are inadequate, Any
residential .development will surely jeopardize the fast-recedg aquifer in this
Valley. Any governing agency will be faced with its depletion and must proceed
tivith extreme caution.
d} The impact of two airports has not been sufficiently addressed in the DEIR:
noise, traffic, safety, and economic impact. No noise study .was conducted on
projected expansion runways and larger aircraft. If the Regional Airport is going
to be developed,• and owned by La Quinta, what. are the cost to develop new
runways, terminals, etc.? Even if not owned/managed by La Quinta, the
problems of safety and additional noise will impact those who live in the area.
Are these the problems we need within the boundaries of La.Quinta?
e) The cultural element of the DEIR seems only to address the 372 !Native American
archeological sites, but does riot mention our recent cultural history of
agriculture, equestrian, and art. Where is the preservation of date and citrus
groves? Of equestrian trails and ranches? Where is the support for the arts?
The City has let a prime location fora citrus orchard/date grove/park to slip by
(Eisenhower and Tampico): what a lovely reminder of our past that would have
been! The City should have purchased tills,. and should purchase the wash along
Montezuma/Bike Path and preserve it for the future. Equestrian trail with parks
would be charming, and a vvonderfuf'place for fahiilies to exper'ence our cultural
past (just ask Frank Bogert about horseback riding in La Quintal). As for the
Native American sites, where are the trails and parks for pegple to enjoy the
petroglyphs, fish traps, and sites where they lived? Instead of sealing them up,
let's work with the local tribes to develop awareness of their culture. These need
to be accessible on site, not just in the Historical Museum.
I believe that the mitigation factors outlined in the DEIR do not resolve the numerous
negative impacts to the degree that we should expect for our. City. We should defer
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approval of this plan and reject the DEIR until we can find a balance among size,
environmental impact, and amenities due to our current residents. We cannot be
enticed into thinking that bigger is better, because it usually isn't.
Lastly, I chide the City Council for not making a greater effort to involve the citi2ens in
the General Plan process. I know that the letter of the law has mer for publication of
notices, but this is the bare minimum. Where were the ad campaign posters advertising
the fact that the future of our city will be outlined in an important document, and
soliciting input? Where were the .notices in. the '.'Gem" asking ,if :we ant to be a city of
208,000? Do we want an airport, a cemetery, sections of Hwy_86 and railroads, etc.?
Where was the public sampling by. phone or mail -in questionnaires?' Decision -makers
must listen to the public, not just the real estate agents and developers. Enough
money was spent on the study and documents, but v+hat was spent on the process to
really assess the Mill of, La .Quinta residents?: -Du you really want.,to know what the
public thinks, or is the City Coincil the sole arbiter of La Quinta+s "vision'?
Once passed, California Government Code Section 65103(c) requires that we implement
the General Plan. Is this the Plan we want to implement? NOT ME!
Sincerely,
Cc, City Council Members and Commissioners
Other interested parties
82550 Ave 60
Thermal. CA. 92274
September 10, 2001
City of La Quinta
78495 Ca11e Tampico
La Quinta. CA. 92253
SUBJECT: ANNEXATION
Dear Sir/Madam:
El1I
3EP 10 0W
CITY OF LA(UIWTA
PLANNING DEPARTME IT
1 OPPOSE being annexed to your city, I wish to stay agricultural
property, and do not want to be rezoned four houses per acre.
Upon reading the enviromenta1 report on page M-7 under Water
Resources, irritation water from homes does not perculate to
the aquifer. This statement is untrue as our Thermal area is
a non homogeneous strata, it is made up of many hundreds of feat
of very fine sandy clay barrier, that makes that statement
iaTossible. If that statement was a true fact then it would be
easy to find a location for artificial recharge in our area.
In some areas of proposed annexation, surface water is very
high, as proof the barrier is very Efficient.
Certainly, the author of the report is mtsinfarmed and does not
understand ever the basic principle of water recharge. I cannot
believe that the City paid for such a report. How many other
errors does it contain?
We live in a DESERT and presently*, we have had less rain or snow
to naturally recharge our aquifer recover}, and at present wL
are lowering our water table yearly by alarming amounts, and in
the City of La Quinta it Is dropping drastically, and the City
is not developing fully, how will it he when fully developed?
It is ala:siiilg to me to see the waste of good pristine ground
water to irrigate illogical strips of grass along manicured
avenues, and are especially designed at 45' angle or less so
it runs off into the gutter, and as a solvent to destroy the streets.
The City just approved this type of landscaping at Ave 56/Monroe
and Ave 56/Madisorn. This is a crime and should not be permitted
just ber:ause it looks good to the occasional walker, bicyclist
and passerby at 55 MPH.
Please do not annex my property as I DC NOT want to be associated
with this kind of waste. How could learned men design, build and P -5
develop and approve such wasteful things.
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Cont`d ..page 2
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2550 Ave 60, Thermal
Our water is ancient, it's being removed faster than it's capable
of being recharged by mar. or nature. Seems to me if anything
is approved we will continue groundwater mining at a higher rate
than the present, as according to the proposed map most of this
is developed farm land, using canal water for irrigation, and
the water level continues to drop, what will happen when `our
houses per acre is approvedU
We will be continuing groundwater mining instead of groundwater
pumping. I know these from personal experience as a local
Water WeLl and Pump Contractor.
Also what concerns me is new developments i.e. houses and golf
courses install "dry wells" designed to carry run-off of flood
water, or irresponsible irrigated landscape, the latter is .chat
the dry wells receives most and with the waste water goes oil,
fertilizer, antifreeze, rotten grass cuttings from the neighborhood
streets.
I was appalled when asked to clean out some of these "dry wells"
as it was polluted and would not absorb anymore run-off. When
a water well is drilled it is required to have the top 200`
cemented off to prevcut pollutants from entering the aquifer
and the City requires that on developments to directly introduce
thepollutants into the wound, not a good idea, _
Please use common souse and take a good look at what lies
beneath us and is very little understood by the majority
of the people including the ones who make major decisions.
t EEP THE CITY THE SIZE IT IS UNTIL ALL IS UNDERSTOOD.
Concerned Landowner
$//
of
"Jesse M. McKeever
JMM:apm
cc; Supervisor Roy Wilson
Transportation & Land Management agency
Vista Santa Rosa - }betty M. Smith
LSi{5-Ti. ' -101 V • 4�Z
RICHARD M. F0)0(
78365 Highway 111 #338
La Quinta, CA 92253
August 5, 2001
City of La Quinta
78- 95 Calie Tampico
La Quint& California 92253
Dear Sir or Madam:
1 am writing in opposition to the acceptance of the Draft Environmental
Impart Report (SCH NO.: 2000091023).
This report points up the massive impact on the area in guestiDn. The
residents of the City of La Uuinta deserve to be fully informed about the
wholesale desecration of this unique area. Such information should be
dissemirated by a series of well -publicized public information sessions with
presentations by the appropriate agencies as well as by the planning and
research people. This is done 1n other cities all over California with far Tess
to lose.
Until anti unless this is dons, expediting the acceptance of this report
through council constitutes nothing less than the most bletarrt manifestation
of behind -closet! -doors government. -
Sincerely,
i lcherd IVI. Foxx
FROM WALRUS —TECH
PHONE NO. : 760 25k 3201 Aug. 25 2@1 0C3: t9Q?1 P2
CVAS
i�'vache a V I -j ATrlaneobgioil Soci ry
August 25, 2001
Mr. Fred Baker
Principal. Planner
Oity of La Quinta
78-495 Calle Tampico
�a Quinta, GA 02253
Review of Comprehensive Generals Plan
Draft Environmental impact Report
SCI-E NO. °00091023
Dear Mr. Baker:
After a review of the above Comprehensive Geneva! .Plan document, the
Coachella Valley Archaeological Society is in agreement with the findings,
mitigations and recommendations as presented In the Cultural resources
Element of the Draft Environmental impact Report.
It wars noticed in the Management Summary portion of the Paleontologic
Resources Mitig rtiun Man the informally designated "lake Gahuilla bed& are
shown to contain 'fossils of Pleistocene through early Holocene age throughout
their extent. Yet, based on archaeological dating, man of the shoreline
campsites found in the La Quinta area were occupied up until about 300 ors
ago, This should make the lake bia<3 sediments present In those areas very late
Holocene in age, riot Pleistocene through early Holocene
vVe thank you for the opportunity to respond to this report and support the City of
La Quints in their efforts to pmserve and educate the residents of the Coachella
Valley_ Knowledge of our past is important to our future, and every effort should
be made to gain as complete an understanding as possible_
Sincerely yours,
\\ i•1 L U
Katherine Williams, Chairperson
Environmental Ass2 rnent Cum ftuIl 3
Cc Nicole Sauvlat Criste
Post Olt= IIo 7344 •. Palin Spring CA 92263 • G19/773-z277
Ai ` et-I'm/9f +c
R
R-1
R-2
REQUEST FOR SPECIAL. NOTICE
I (We), the undersigned, request notice of all CEQA (Cal iforina Environrnental Quality Act) and other
notice,, and hearings, relating to the City of La Quirtla's Comprehersive General Plan, Annexation Na 12
and Sphere at -Influence Amcndrneni,und al] CHQA and ether notices, and heasmgs, rclaang to any and
aiI projects to annex, ormodify the Sphere oflid] uence; to the south ofHighway 1 l l and the east of the
current city limits of La QuinIEi, (Public Resources Code Sce_ 21092.2)
Signature:
Printed Name: c c. L r I a v
Address:
COIvIIvIENTS TO CITY RE PROJECTS:
_�. e ,
REQST FOR SPECIAL. NOTICE
Pursuant toycur Notice of Availability, I (We), the undersigned, request notice of all CEQA (California
Environmental Quality Act) and other notices, and hearings, relating to the City of La Quintals
Compreberzive CICIerld Plan, Amoxation No, 12 and Sphere of InDucnce Amend:malt, and all CEQA and
other notices, and hearings, relating to any and all projects to annex, or modify the Sphere of trill uewce,
to the south ofHighv► y 111 and the east of the current city limits ofLa Quinta_ (Public Resources Code
Sec, 2109:L )
S grdatur'e.
Printed Name:
Address: &?.___
COMLVMNTS TO CITY RE. PROJECTS:
‘„k 72,L-zfe
_Otel zoaete,_
dew
.dii/ee/aaslz:
1
T
T-1
i.L.L
REQLTEST FOR SPECIAL NOTICE
Pursuantto your Notice ofAvailahility, f (We), the undersigned, request notice ofall CEQA (California
Environmental Quality Act) and other notices, and hearings, relating to the City of La Quinta's
Cornpreher, ve Oral Play Annexation No, 12 and Sphere of Influence Amer rrierrt and all CEQA and
other notice, and hearings, relating to any and all projects to annex, or modify the Sphere of Info
to the south of iighway 111 and the east of he curreM-�t city limits of La Qtiinta (Public Resourc
Sec. 21092.2)
Si _ MJ j -1/(c4.
cri
lid Name 01 . , ( -T H c- L b
Address: ` [
COMMENTS TO CITY RE PROJECTS:
LAL
L "
•
.44.-2 r r %1s
N—}'%_ Cc. Lt
'i
[1
-C
.p.,,t4A •i ` r
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f
SUN COUNTRY RANCH
Norman and Gayle Cady
82-831 Avenue 54 - Vista Santa Rosa
Thermal, California 92274
September 9, 200 l
La Quinta C:ummunity Development Department
Attn: Fred Baker, Principal Planner
78-495 Calle Tampico
La Quinta Ca 92253
ti
Re: City of La Quinta Comprehensive General Plan Draft
Environmental Impact Report, Draft Comprehensive General Plan
and Draft Master Environmental Assessment dated July 2001
Laear Mr. Baker,
11V,
E)) 1 Oak
CIiYOFLAO Jl1V A
fV�fVG QEpAf�,fvT
y husband and 1I have spent considerable tune reviewing and assessing the above referenced
documentation. As individuals, registered voters, proud residents of Vista Santa Rosa,
community involved citizens, parents, grandparents, equestrians, date farmers, ten acre ranch
iwriers with eight horses, four head of cattle, three dogs, thirty chickens, and sixty or so quail,
we have major ceticerris regarding certain text,
Our first item of concern is La Quinla's'`multi-purpose non-motoriz.d" equestrian trail system.
DRAFT COMPREHENSIVE CENERAL PLAN:
Reflects Madison- Mnnrpk, and Jackson Streets North to South per Matt Exhibit g3.10 Multi -purpose Trails.
Avenue 51 to Avenue 58 along Madison Street.
Avenue 52 to Avenue 65 along Monroe Street,
Avenue 50 to Avenue 66 along Jackson Street,
Reflects Avenue 58 (only) West to Ea5t per Map Exhibit' 3.I0 [Multi -purpose Trails.
(Lake Cahuilla ti 'Harrison Street - Then a "blank" area to Polk Street- Ending at I-] 0 Fwy)
Mr. Bilker, why is there only one west to east non -motorized multi -purpose trail drawn? Why are
there no other connector trails hooking up with the three north to south routes? Wouldn't it be
rnore prudent and advantageous to have trails connect and intermingle with each other?
Page 1 of Eleven
Mr. Baker, has the Country Club of the Desert been advised to construct "multi -purpose non -
motorized" trails along their properties, including Avenue 52 south to Avenue 54 along Madison
Street, and Avenue 52 south to Avenue 54 along Monroe Street? Arc these "multi -purpose non -
motorized" trails contained in their general plan? How will these trails be funded? By whom?
.grarian Image Corridor - Map Exhibit #3.6 in Draft Comprehensive Genera] Ulan
Map Exhibit 42.5 in Draft Master Environmental Assessment
From Jefferson Street along Avenue 54 to Van Buren (West to East),
Mr. Baker, has Country Club of the Desert been advised by the City of La Quinta to include
"Agrarian Image Corridor" enhancements,"equestrian facilities: etc_" from Jefferson Street east
along Avenue 54 to Monroe Street'? What about along their boundary from Avenue 52 south to
Avenue 54 along Madison Street? Is it wrirten anywhere in their general plan to include such a
project? How are these "Corridors" to be funded and maintained? By whore?
It is difficult to ascertain whether the Avenue 54 Agrarian Image Corridor (f cin Jefferson Street
east to Monroe Street) is to he located on the north or south side of the street. Should this
Corridor be scheduled for the south side, have the current property owners, KSL,FGA West, and
Mery Gritltn, hem notified? Are they expected to absorb the cost of construction?
From }vtadison Street along Avenue 58 to Filmore (West to East)_
From Madison Street along Avenue 62 to Hwy ] 11 (West to East),
From Madison Street along Avenue 66 to Hwy 111 (West to East).
From Avenue 50 along Madison Street to Avenue 66 (North to South).
From Avenue 52 along Jackson Street to Avenue 66 (North to South),
From Avenue 56 (Airport Road) along Harrison Street to Avenue 6b (North to South)
Mr. Baker, there are at least eight trails reflected in the "Agrarian linage Corridor" - Map Exhibit
#2_5 and 43.6 that have loose endq. They lust slop_ No connector trail listed. 'rrrii1 design is
inconsistent, disjointed, and UNCONNECTED. Remarkably similar to the La Quinta sidewalk
sy stem.
Puce. 30; "Pedestrian and other non -motorized circulation is encouraged in the City wherever
possible. The provision for sidewalks, 'pike lanes, and multi-pu pr ve trails is especially important
alonE major roadways in the community. While "sidewalks" have been constructed in various
parts uf the City, their design and construction has been iwc sc istent, djsiointed, and
t.NCO}NNEiCTED. In future development, pedestrian safety and accommodation should be given
LFnphasis equal to that currently. given .o automobile access"_
Mr, Baker:
It should be noted here- Riding a horse or a bicycle along major roadways is always
dbngerous and never he. Multi -purpose non -motorized trails
should be located along less traveled roads for the benefit and
safety of the rider, our children and our animals_
page 2 of Eleven
Page 39: "Policy 7 - Develop and encourage the use of continuous and convenient bicycle routes and multi-
purpose trails to places of employment, recreation, shopping, schools, and ether }sigh activity areas with
potential for increased bicycle, equestrian, golf cart and other non -vehicular use_"
Mr. Baker, this being said, where in text or on any map or page are these "potential" equestrian,
and multi -purpose non -motorized trailways clearly illustrated?
:MASTER ENVIRONMENTAL ASSESSMENT DRAFT:
Pale i(: "Riverside County Regional Parks and Open Space District 4.1. t; The County of River. ide (not
La Quinta) has designated a nurnhcr of regional and community trails. Regicnai and community trails
are designed for equestrian activity, walking and mountain bike rising."
"Recreational Services and Focilitiee 4.17 The bureau of Land Management (not La Quinta)
maintains a .ystem of hiking and etc ttcstrian trails in the southeastern region of the planning area.
Page 477 "City Trail System} The City has planned and dedicated a comprehensive system of multi -use trails
extending throughout much of the City. Trail facilities are categi rued by 1,11, or 111 classifications.
Class ] trails are completely separated `tom any street or Highway octet are dedicated excieisively for
sltaret; bicycle and nedestrian INC, Class i1 bikeways are on -road bicycle lanes within the paved
seclion of the street. Class 111 trails are hik routes that are located on the street within vehicular
traffic lanes."
Pace 35: "Gal r cart R note System 2.6.3: As with on -street hike paths, cart path
safety is of utmost importance.'
Pam 2; ",411rnrian Tmage Corridor 2.4.4: 1'hoae streets which occur in areas of low density development,
and •hic:'r re`.7ect the agrarian past of the region have been designated Agrarian Image Corridors.
These streets will feature equestrian facilities, low canopy and citrus trees, and street furniture
which reflect a rural character_ The intersections of Agrarian Image Corridors should be highlighted
by citrus trees. Agrarian Image Corridors include.,"
" Avenues 54, 58, 62, and 66" (Wrest to East)
°Madisari,.lickson, and lij-rison Streets" (t*lonhto South
"Agrarian image Corridors: Map Exhibit R2.5 its Draft Master Enviroiurtenta] Assessment
Map Px1 ibis t3.6 in Draft Comprehensive General Plan
Mr. Baker, once again there are at (east eight trails reflected with loose ends. They just stop. No
connector listed. Trail design is inconsistent, disjointed, and UNCONNECTED. Quite similar to
the sidewalk system in La Quinta.
Open Space Element Coal, Policies, and Programs (Draft Comprehensive General Plan -Page 43)
Policy 6: " Develop a comprehensive multi -purpose trail network to link open space."
Page 3 of Eleven
•
~I.Sa:iirCi4art ac 3::
rretaipAs
824310
In summation; please review and reflect on the following "multi -purpose non -motorized trail
system" and "Agrarian Image Corridors" comparison:
LQ Comprehensive GP on
lYTalti-
�urpowTrails July 2001
Map Exhibit 43.10
Avenue 58 (.fast to West from
Lake Cahui]]a to Harnsr n Ss.)
t iadison, Mortroe and
Jackson Street
(North to South)
LQ Master Envir9nn-entaI Assessment
.iuly 2001 - Page32
Airarian image corridors
Avenues 54, 53, 62, and 66
(least to West)
Madison, Jackson. and
Harrison Street
(North to South)
Rvari Snyder, Consultant
workingw/CVAG on Rezio-nai
Trails for Riverside Cutinty
Avenues 50, 56, 58, 60, and 66
(East to West)
North to South Streets
were not discussed,
Mr. Baker, the above comparison clearly illustrates major inconsistencies within La Quinta's
proposed "multi -purpose non -motorized trail system", the "Agrarian Image Corridors"
preuentation, and the Riverside County Regional Trails Plan.
Further, placement of multi -purpose non -motorized trails along heavily traveled streets
demonstrates insufficient research and knowledge regarding the unpredictability of people riding,
whether it be on a bicycle or a horse, As an example, riding a bike or a horse along Mczu-oe
Street with eighteen -wheelers, motor homes, buses, cars and nicks whizzing by at sixty plus
miles ari hour does not even begin tc constitute a leisurely relaxing ride in the country. It most
assuredly sounds more frightening and dangerous than fun and enjoyable. Think about it, Would
you honestly want your chilli out there riding under such conditions?
I have personally provided the City of La Quinta with photographs and pamphlets depicting
successful rural and agricultural communities within Southern California, Included are newer
beautiful pricey homes with their owners harmoniously living amongst country clubs, golfers,
hikers, joggers, bicyclists, tennis folk, and equestrians. Beautiful meandering trails and golf
courses can be seen throughout the area. None of this is even addressed in the Comprehensive
General Plan Draft Environmental Impact Report.
Surely there are less traveled road, or perhaps existing roads that can be adjusted to
accoinrnodate less traffic, or at least slow traffic down, One street comes to mind. Oasis Street,
which runs (unpaved) from Avenue 53 south. There may be additional avenues as well, Perhaps
collectively we could further explore such possibilities.
I would also like to see the Coachella Valley Water District open their canal roads for public ,rail
use. I have written to Corky Larson. and have asked for her support as a very well known and
respected community leader and C'VWU board member. Corky agrees canal roads would
provide a wonderful trail system, and has forwarded her endorsement of my suggestion to Tarn
Levy for review.
Pave E of Eleven
liarrrianyA riaUirdry4 rt
1 have tried to cc_rntact several officers within KSL regarding the re -opening of the trail west of
PGA and west of the canal from Avenue 54 to Lake Cahuilla. Except fora few places, there is
ample room to hike Or ride there along the base of the Santa Rosa Mountains. I am in touch with
Rochelle at the Bureau of Land Management. We plan to walk the "trail" and do a feasibility
study on creating a route to bypass PGA's 17'h green which is physically located in the side of the
mountain (cutting off the existing trail). 13LM has assured me there are folks who actually build
trails where to us it would impossible.
Sadly, "equestrian" and other "riding" provision, welfare, safety and accommodation are rarely
discussed in La Quinla's Comprehensive General Plan/Draft Environmental Impact Report,
Master Environmental Assessment Draft or Comprehensive General Plan Draft. Indeed, it is
painfully apparent minirnal thought and scant appreciation have realistically been given in
welcoming an equestrian neighbor who on the average generates over $200 million annually in
to the East Valley's economy.
Mr_ Baker, we have major concerns relating to La uinta's proposed zoning ordinances, rules
and illusory "agricultural overlay".
Re: Riverside County Ri ,ftt to Farm Ordinance - Ordinance 0625
(Pursuant to Civil Code 1102.6)
"It is the policy of the State ofCuli#ornia and the County of Riverside that no agricultural tLctivity,
operation, or facility, or appurtenances thereof, conducted or maintained for conunerc;;] purposes, and in a
lawful manner consistent with proper and accepted customs and standards, as established by similar
agricultural operations in the same locality, sha[I be or become a nuisance, private or public, due to any
-.:hanged condition in or about the locality, after it has been in operation for more than three years if it was
not a nuisance at the time it bean. The phrase 'agricultural activity, operation, or facility, or appurtenance
thereof' includes, but is not limited to the 4ultivation and tillage of soil, production, cultivation, growing,
and harvesting r t and agricultural commodity, including timber, viticulture, apiculture, horticulture, the
raising of livestoc%, Fur bearing animals, ish or poultry, and any practices perf❑rrned by a farmer or on a
farm as incident to or in conjunction with such farming operations, including preparation For market,
delivery to bt❑rage or to market, or to carriers for transportation to market."
"AGRICULTURAL OPERATIONS which typically occur during the day, but which may ocean at night
include the use of heavy machinery '. hich may GENERATE NOISE arc' club[. Applications of agricultural
chemicals that are applied within state and local permit requirements may have noticeable odors associated
with their application. Organic fertilizers may be employed that generate their own objectionable odors.
When and if frost undior freezing conditions occur, helicopters may be emp[oved al low attitudes to stir up
the air and prevent freezing, Workers traveling to and from agricultural property to engage in work may
generate additional tragic and noise on public streets in the vicinity."
Existing agricultural land uses in the La Quinta General Plan area are currently under the jurisdiction of
Riverside County, The Riverside County General Plan designates them for "Agricultural f&G)"
development, a designation which permits agricultural cultivation, associated uses (including limited
commercial, industria), and single-family residential development atLr44AXJMUM DENSITY ofONE
DWELLING KNIT per TEN ACRES.
I'agc 3 of Elcvcn
Mr. Baker, La Quinta is adamantly proposing low density zoning - four houses per acre (versus
our current one house per t0 acres zoning designation with Riverside County.)
" Page G.-Proposed Land Use Designations -Table lj: Very Low. Density Residential, VLDR (Up to 2
dwelling units per acre). This designation provides a transition between agricultural Jands and
residential uses. It encourages large lot subdivisions and equestrian use."
As a compromise suggestion from our County one -dwelling -on -ten -acres zoning ordinance to
La Quinta's proposal of significantly more homes on considerably'' less acreage, we much prefer
inclusion of a ore residential dwelling inaximum per live acre parcel agricuIturalIequeslrian
zoning ordinance. Bur second choice would be, without compromise, a maximum of
residential dwelling per tyro -and -one-half acre parcel agricultural/equestrian zoning oral nancc•
The "Agricultural Overlay" provides .or the cons inuatic]n of existing agricuiltural activity at
the discretion of the land owner (Page III-24 EIR).
Agr'icuin]ta] uses within this nverhav area shall he nermined to continue as ncev ycc:tr at the time the
Recommended CeneraI Plan is adopted (Page 1II-28 E1R).
Buil foul of the proposed General Plan will result in the construction of. approximately
61 till l new residences (Page 79-Draft Comprehensive Genera] Plan).
Letter tlaied 10-04-2000 from County of Riverside Transportation and
Land Management , gericyt PlanningDeparturent - Aleta J. Laurence. A]CP:
"After reviewing the proposed General Pan Update the County offers the following comments:
(]) The most significant change in the recommended iilternative land use plan are changes to the
azriculrurnI land use dcsienatinn which was eliminated (Page ] 2.)_ Lands under the County's
-jurisdiction outside of the planning area arc primarily agricultural and open space in nature. We would
recommend consultation with the County on these proposed land use designations and that proposed
:arid use designations in the City' s general plan update he compatible with adjacent County land use
designations and agricultural preserves.
(2) The City of La Quinta and the Coachella Valley arc located within one of the most biologically unique
and diverse regions in the country. Build❑ut of the incorporated City, its sphere of influence, and other
planning area lands outside of the sphere of influence, pursurint to the Recornrnended Land Use Plan, has
the potential to cause significant environmental impacts. We recommend that the zoning designation
in the proposed City's General Plan be consistent with the Coachella Valley Multi-Spccics Habitat
Conservation Plan (MSHC] ).
(3) Man residents and landowners Front this area attended a cmmmutuily meeting October d. 201I0
and eyprenrd strong desire in l:eep_their area rural and ecquestrian friendly. book to protect their
rural lifestyles as well as to support the large equestrian oriented tourism industry in tie area.
'rHF C1TY'S CEI ER/AI, PLAN SHO11LD ADDRESS THIS NEIGHBORiNC
RURAL FOiIFSTRIAN LIFESTYLE. ED1 ESTRMN TRAIL LINKAGES
BETWEEN THE COUNTY AND THE CITY, AND EFFECTIVE METHODS OF
BUIFFERING THE R1JRAI. USES FROM ADJACENT. ]V14R11LJRBAN USES IN T13JCITY."
Page 6 of ElovGn
Morrrran:a ix ¢W
82431teillermri 4 y$ta ':;
Mr_ Raker, Mayor John Penn repeatedly states he and the City of La Quinta have
no plans to, no desire to, and nu, intention of changing anyone's lifestyle in
the Community of Vista Santa Rosa" through annexation. Can this be true?
Page 111-28, Section 3-6-FIR ALL A R1C1JLT L and urban ACJ1VIT1ES SHALL CONFORM
TO THE Nola _._S.1ANi AR described in Section 9.100.2] 0 of the City Municipal Code and
other mitigation measures set forth in Section 11I-J (Noise) of this DR.
PanneIil-1dd. 1-Exi title f:onditions: Evaluation of noise levels within a community is important to
protecting the health and welfare of the general public, and can help define the need for remedial
measures for existing noise problems and those associated with future development.
Page IIJ-141, 1-Hoist Rating System: A number of noise ratingsL•ales are used in California to evaluate
]and use compatibility. The equivalent sound, or Lea scale, represents average constant noise level over a
given period time, and is the basis for the. Lt1n and CNEL scales_ Uri value represents a summation of
hourly Les over a period of 24 hours, and includes a weighting factor or renalty for noise occurrin2 in
the nighttime periuti of 10:00 p.m. and 7:00 a.m. 'the Community Noise Equivalent Level (CNEL)
represents a 24-hour average noise level which includes a 5dEA penaltyJor noise occurring during
evening t ime period tfrum 7 p.m. to 10 p.m.1 and a 1 Od13A penalty for noise occurring during
nighttime period (from 10 p.m, to 7 a._qi)
A�werail „TfE1R Noise Element Update Technical Report -F 3: NOISE, as it has been simp]y defined is
"UNWANTED SOUND." It is an undesirable by-product of transporrarion s}'Sterns and industrial
activities within a community flat permeate man's environment and cause disturbance, •fhe full effect of
such noise on individuals and the community will vary with its duration, its intensify, AND THE
TO]..ERANCF. LEVEE. OF T1 TE EXPOSED INDIVIDUALS.
Mr. Baker, it is quite apparent La Quinta is making diminutive effort to accornmodate and
encourage the current rural, agricultural, and equestrian lifestyle and daily routine of Vista Santa
Rosa residents_ 1=xpectirlg this community to arbitrarily accept your token inadequacy offering of
an "Agricultural Overlay" versus qualified perpetuity agricultural and equestrian zoning
ordinances is absurd_ Demanding all uncle -Moped open space property irnErit.liately conform to
"four houses per acre" zoning designation upon annexation is ludicrous.
Several months ago I personally presented the City cal F a Quinta vvrith copies of several rural and
agricultural zoning ordinance schedules currently being utilized by riverside County. 'These
ordinances were obtained from the County Planning Department, and are readily available to
anyone with initiative to inquire.
Sd]rnole of County Zoning Urdinan es Submitted:
R-A ZONE (Residential Agricultural)- Country Estate Lifestyle
A -I ZONE (Light Agriculture)
A-2 ZONE (Heavy Agriculture)
A -ID ZONE (Agriculture -Dairy)
A-P ZONE (Light Agriculture ►r•ith Poultry)
N-A ZONE (Natural Assets)
We firmly believe insertion of these or similar agricultural/rural zoning ordinances in to the
La Quinta General Plan may enhance the likelihood of La Quinta having a more favorable
response to proposed annexation. Clearly, without cooperative zoning ordinance stipulation,
a negative vote for annexation would be appropriate,
Page 7 of Eleven
*a7w'a iind7#i i+EcCr o
82r83, :Athirst; E?w: :s
********-*1*
Mr. Baker, it is totally incomprehensible to us as to how, in all good conscience, the Coachella
Valley Water District Ivlanagernent and the City of La Quinta elected officials can mutually agree
on and approve new construction proposals of over sixty thousand homes within the Vista Santa
Rosa Community While exhibiting flagrant disregard for the subsistence and preservation of our
precious water supply.
Re: DMEA- Pg 103 6.3.6 Seismically Induced Geologic Hat orris -Liquefaction:
"MUCH OF THE EASTERN PORTION OF THE PLANNING AREA CONTAINS
GROUND WATER WITHIN 30 FEET OF THE GROUND SURFACE AND IS
SUSCEPTIBLE TO LIQUEFACTION, LIQUEFACTION IS LARGELY LIMITED I ()
LANDS CONTAINING SHALLOW GROUND WATER (WITHIN 50 FEET OF THE
GROUND SURFACE) AND SANDY, SILTY SOILS.
HAZARDS ASSOCIATED WITII LIQUEFACTION
ACTION
CAN BE MINIMIZED BY RESTRICTING OR PROI-II:
CONSTRUCTION WITHIN SUSCEPTIBLE AREAS."
Re: CVW D letter 10-06-200 from Torn Levv,CM.Cltief Engineer to LID
"TIME GROUNDWATER AQl1lFF.R IS IN A STATE OF OVERiDRAAFT_"
'LAND SUBSIDENCE DUE TO THE OVERDRAFT CIF THg GROUNDWATER BASIN
MAY AFFECT THE SIRUCTL;RAL [NTEGRITY OF FOUNDATIONS AND STRUCTURES
_s
Re: DESERT SLIN NEWSPAPER 5-13-2001 "Si'EC1 AL REPORT: SHRINKING. WATER
RESERVES - WATER CONSUMPTION OUTPACES ABI ITY TO REPLENISH SOURCE"
Torn Levi', CV.Wl General manager and California Water Contractors
Association President, sighs ruefully when asked about !ong-range planning:
"We water guys can never confront the hard issues_ We find a temporary
fix and hope we're retired before we have to answer for it. Then if the
kids are attorneys, they tarn make a living sorting it out."
Mort Rosenblum, AP Special Correspondent, "The desert around here (Palm Springs area)
is So dry that imported Arizona cactus needs vJatering- A quarter million residents use
an Overage of 375 gallons of water a day at home twice the national average.
To water specialists, the over sapped Colorado River basin is symbolic of a calamity facing much of
the world_ Fresh water reserves are disappearing fast. The planet has no more fresh water'han
it did millennia ago, but with today's rocketing growth in arid zones, conflicting needs of Farms,
cities, irrr,ustry, recreation and wetlands promise bitter water wars.
Water manners across America say the public and puiitical IetlderS who can effect
chance seem to ignore the danger, `Planners always say that we can worry about water supplies in
the future,' said Tom 'Forney, New Mexico state engineer.
-Y ;hi a�117'4afl7f17trr^�:�Q
N�t+rudresr,[;a�#ir21
.4; bli 4[sar1W z�.1}irk
Page 8 of Elvvca
Dennis Underwood, former head oft .S. Bureau of Land Reclamation, and now assistant
director of the Met in Los Angeles, lamented, `When it comes to planning, we're still
]coking at the end of our noses.'
Linda Vida, Water Resources Center at University ofCa]ifornia-I3erkeley, 'Nobody is looking out.
The stakeholders want what they want. Nu political leader is willing to go out on a limb and make
some people very unhappy, Ne one wants to deal with tvinv o-rowth •oJcsnurces. They just squeeze
out more. As a result, a drought that otherwise might be managed with water reserves could hit
California far harder than the energy c:risis'."
Re: CAL1T'ORNIA REGIONAL WATER O[1ALITYCONTROL -BOARD- Letter1O-05-211UU
1)" The proposed project has a potential for runoff and finnding which would create nr conrrihute runoff
water that Would exceed the capacity of existing or planned s urm ii,vater drainage system controls.
2)'Ihe proposed project may substantially deplete groundwater supplies or interfere sul}stantiall-
with groundwater recharge such that there will he r NET DEFICIT IN AQUIFER
VOLUME -or- LOWERING OF GROUNDWATER TABLE.
3) The proposed project may substain ady alter the existing drainage pattern of the site nr area, including
alteration of the course ot`a stream or river, in a manner which will result in a suhsrantial erosion or
siltation on or offsite.
4) The proposed project will s,ihstantial]y alter the existing drainage pattern of the site or area including
the alteration of the course of a stream or river, or substantially increase the rate or amount of surface
runoff in such a manner which would result in flooding on or offsite."
Re: COACHELLA VAL1,EY WATER DISTRICT ILFTTFR - May id, 20[]1
;'The proposed nuexatrtA area totals 5,419.9 acres bounded on the north by Airport Boulevard, on
the east by Jackson Street, on the south by Avenue 62, and on the vest by the existing city limits.
The sphere of influence amendment consists of 8,205.4 acrm hounded on the north by
Avenue 50. on the west lty -Jackson Street, on the south by ,avenue 62, and on the east
by Polk, Harrison, and Van Buren Streets.
The annexation area and sphere of influence amendment areas are primarily vacant desert ]antis and largg
residential development. The city's proposed zoning designations for these areas consist of mostly low
density residential with a small amount of nlediutn to high density and mixed commercial Luning.
`TIDE COACHELLA VALLEY GROUNDWATER BASIN
IS IN A STATE OF OVERDRAFT'
Future development within the General Plan area, including the annexation and amended sphere of
influence, WILL CONTRIBUTE IMMENSELY T{) THE \'ALLEY WIDE OVERDRAFT.
Groundwater recharge goals stated in the Coachella Valley Water District Urban Water Management
Plan include continuing the current level of groundwater recharge in the upper valley and
implementing a lower valley recharge program "
Mr. Baker, to date tta comprehensive or definitive lower eastern valley water replenishment
program has been officially implemented by the Coachella Valley Water District. In reality it
would take several }Fears to achieve and successfully execute such a plan.
I�IiIL'.U87i 7J-, fr'.lt++�l�w
Psge 9 of Eleven
Mr. Baker, IN THE MEANTIME, WHILE THE BUREAUCRATS
ARE FALLACIOUSLY STAGGERING OVER WHAT TO DO, OH MY,
WHAT 'TO DO, OUR EAST VALLEY UPPER THERMAL SUB -AREA
WATER TABLE RESOURCE BASIN TS CONTINUING TO
EXPERIENCE AN EVER INCREASING OVERDRAFT" CONDITION!f!!
h.ppendix G-Seisrnir ulo it nrr I FInudin
Azartis 1ulR-
-2. 1-a. l_ . 1-2
"1.igtiefaction/Ground Failure: Porii.ons of the l,a Quints genera] plan are susceptible to liquefaction and
landsliding or rockfall, both very destructive secondary effects of strong seismic shaking. Liquefaction
occurs primarily in saturated, loose, fine to medium -grained soiis in areas where the ground water table is
Sl} feet or less below the ground surface.
Liquefaction does not occur al random, but is rest-icted to certain geologic and hydrologic environments,
primarily recently deposited sands and silts, in areas with high`, groundwater levels. Currently, shallow
ground water, within 5C feet of the hound surfac'-, is present ONLY in the eastern portion of the general
plan area. Therefore, at present, this is the only vons susceptible to liquefaction,
Four general approaches apply to mitigation of liquefaction hazards' 1) AVOIDANCE 2) Prevention,
3)'Engineered Design, 4) Post -earthquake Repairs. A prime way to limit the damage due to
liquefaction is to AVOID AREAS SUSCEPTIBLE TO LIQUEFACTION.
Aopt ndi G -. Ground SubsMen ce Pg.2.8, 2-9, 2-10: Ground subidence is gradual settling or sinking of
the ground surface with little or no horizontal movement. This phenomenon is usually associated with the
EXTRACTION OF oil, gas or GROUNDWATER from below the ground surface with a resultant loss in
volume. Ground fissures were observed in the City of La Quinta in 1948, Regional subsidence related to
GROUNDWATER. WITHDRAWAL is believed to have occurred in the C.oachiclla Valley,
The
GROUNDWATER BASIN IN THE COACHELLA VALLEY IS CURRENTLY TN A STATE OF OVERDRAFT.
GROUNDWATER LEVELS IN'fIiE LA QUINTA AREA ARE DECLJNING
AT AN INCREASING RATE AS A RESULT OF VALLEY WIDE
M I NIN G FOR GROUNDWATER.
GROUNDWATER LEVELS IN 1296 WERE IN MANY AREAS
LOWER THAN THE HISTORICAL LOW GROUNDWATER LEVELS.
These observed reclines in water level have the potential to induce new or renewed land
subsidence in the area affecting the City of La Quints.
The timing of subsidence measurements corresponds with water level declines. Land subsidence is probably
occurring, and a significant part of the measured subsidence likely has occurred since 1991, about the time when
water levels began declining below their previously recor,ed low levels. Land subsidence can result in the
disruption of surface drainage, reduction of aquifer system storage, formation of earth fissures, and damage to wells,
building, reads and utility infrastructure. Mitigation of subsidence requires a regional approach to groundwater
conservation and recharge- Mitigation measures are expected to be difficult to implement........
Page 10 of [Icven
•
CONSERVATION EFFORTS WILL BE MORE THAN OFFSET BY THE RAPID CROWTld
OF THE REGION AND THE 1MANY WATER REOU1RFMFN'TS OF GOLF COURSES,*
*( plus -or -minus S acre-feet per acre per year)
CURRENTLY, GROUNDWATER RECHARGE IN THE LA QUINTA AREA IS MINI1v1AL.
DI►IEA-Fg 57 CVWD; CVWD currently operates eleven active wells throughout the planning area. Two
inactive wells are located within the PGA West development at the southwest corner of 54Yh Avenue and
Madison Street. A new well is proposed al the southeast corner of Airport Boulevard and Madison Street,
Mast existing wells are drilled to depths of 700 to 80D feet.
CVWD`s NEWEST WELLS ARE DRILLED TO DEPTHS BETWEEN 1,000 AND 1,300 FEET.
DMl .'k-Pg.9.3 Groundwater Resources: The water table in the Lower Thermal area had risen in the past
several years, primarily due to the application of impurted water from the Coachella Canal and reduction in
pumpage, while the Upper Thermal sub -area's water table has fallen. It appears that increased
urbanisation may be causing the Lower Thermal sub -area to currently be in overdraft."
Mr. Balser, i have endeavored to highlight some of 'Norman's and roy major grievances regarding
La Quinta's Comprehensive General Plan Draft Environmental Impact Report, La Quinta's Draft
Master Environmental Asscssmrtcnt, and La Quinta's Draft Comprehensive General Plan dated
July 2CI01. Although of issue, 1 have omitted discussing some items such as traffic, air quality,
adequate infrastntcture provisions, electrical power, schools, park and recreational facilities, law
enforcement, fire protection, etc. It is my understanding addressing any questionable items at a
public hearing is entirely appropriate, so we have elected to do so as the need arises.
\Ve are genuinely disappointed in La Quinta's seemingly inherent propensity to blatantly
disregard specific necessities, wishes, desires and suggestions frequently voiced by her
agricultural and equestrian neighbors. Sadly, provision for equestrian enjoyment, welfare, safety
and accommodation are rarely mentioned in the text. Needs and concerns of the farmers were
given negatory attention. It is quite apparent little thought or appreciation has been given to this
esteemed group of people who project an incredibly awesome lifestyle and are making
considerably valuable contributions to the people and the economy of this valley.
We are dismayed at La Quinta's obvious reluctance to accept and accommodate several of Vista
Santa Rosa's current residents by incorporating new zoning ordinances to better service and
enhance the existing agricultural, rural, and equestrian lifestyle.
As I mentioned early can, it is totally incomprehensible to us as to how, in all good conscience.
the Coachella Valley Water District NIarragemeztt and the City of La Quinta elected officials can
mutually agree on and approve new constn}ction proposals of over sixty thousand hornes within
the Vista Santa Rosa Community, while exhibiting flagrant disregard for the subsistence and
preservation of ow - precious water supply,
The availability of water necessary for life, The power of nature to destroy life through draught,
flood, liquefaction, and subsidence. Meanwhile, the bureaucrats are scrambling over who thinks
they can fix what first on the water issue, and the developers are selling their souls to make a
buck regardless of consequences or who may get hurt. The thought process is very Frightening_
,�,.: Respectfully Submitte
t' orirtan f . Cady
September 9, 2001
Date
1:10'1i • )1 13;15 FA 1 G19 259 61)94 hJ:lI'ft{EW WIEDLIN
Matike v P. rfSrd1{e, EMU.
Page 1 of 4
VTA FAX September 10; 2001
Mr. Jerry Herman
Community Development Direct Dr
City of L;1 Qiiii ta, Community Development Deparincnt
78-495 Calle Tampico
La Quirlra, CA 92253
Subject: EvAlxnlrnn of f:oachella Valley Water Resources
Dear Mr. llerman:
1 have been retained by several property owners in the ]ewer Coachella Valley to evaluate the
impact of La Quinta's Draft Comprehensive General Plan tin water resource management .iarls for
the Coachella Valley. La Quinta's Draft Envirnnmenta l Impact Report projects that • ui • out o t e
preferred :alternative will iii cease the ggoundwatei oveldraft. The long term ability ofthc area's
water supply to meet the increased nc:ds of prciected development depend to a urge eaten on tits
successful wplemzntatian of efforts described in (,'VWD's draft water many e.ment plan. This
letter has been prepared to provide vo-.r with an illoependent and objective view of Coachella
Valley's water resources so that La Quinta's land Use decision-; and asu,exatiof plans may'ne trade
with a better understandi.n2 of the strengths arid }imitatir ns C'V U's plan.
I am a consulting hydrogeologist, certifies] by the State of California, with a Masters of Science
dclrcc from San Diego State University in Geologcal Sciences_ M r course wail specialized in
hydrogecdo y and ,11y iucluate research focused on evaluation of methods of measuring
aoundwater recharge_ 1 have 18 years of professional experience as a hydrogec logic consultant.
.i have attached a copy Or my resume that describes my experience in :more detail.
My opinions are hosed on the review of the following documents;
Coachella Valley -Draft Water lvlanagement Plan, Prepared by the Coache] 1a Valley Water
District, November 2000.
•Analog Model Study of the Ground-W'aier Basin of the Upper Coaetieila Valiev, California~
U 1 i ()pen hie Report, Prepared by Stephen J. Tyiey, January 2S, 1971,
Evaluation of a Ground -Water Flow and Transport Model of the TJfpper Coachella Valley,
California USGS Water -Resources lnvestigations Rcpnrt 91-4142, Prepared by Eric G.
Reichard and J. Kevin Meadows, 1992_
Peer Review Report of Groundwater Model Prepared by Mon bc ornery Watson fur Cowbell a
Vallcy Water District, Prepared foil Redwine and Sherrill, 1 iversicie. California, by 5.
l..arson, J Meicer, and 1. Reulsori, September 18, 19913_
City of La Quinta's Draft Environmental Impact Report, by Tura nova Planning &
Research, lac_, dated July 2001 _
16b}4 l mrn to Cm-mnl ltndir$, San [ hcge, CA, 9277411711258 1S9-6'32 FIN &ss 259-e-91
1,5: 55 RECEIVED FROM : 619 259 5G 4
P
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BACKCRO L ND INFORMATION ON -nu COA.CHI.LL..% VALLEYWATER RJ SOURCES
The C"v" D manages the water resources of the Coachella VaIIeyby integrating imported surface
~'rater from several pOtentia.: sources with water con civation, arid reclamation of, stewater and
ii-ng-xtionreturn water. Because of the\'erg limited natural groundviraterrecharge that occurs in the
desert, in the long terra,roundwatcr in the Coachella Valley is not a viable additional. source of
water fort he community However, the permeable alluvial sediments in the valley provide a critical
resource management tool to store imported surface and reclaimed water with minimal ]uss to
evaporation_ The high u°atnr Storage capac4 of the alluvial sediments in the Coachella Valley
allow CVWD to accommodate, iht differences in tinning between peak water demand and the
availability of surface water. As noted in the CV WD Draft Water ivlanagement Plan, for many years
the basin's hi 01 sicragc capacity has been used to essentially mine grounriwater without
consideration of the long rem sastalnability oFthe resource. Ultimately, the ability to sustain. the
types of future land uses described in the CVWD Draft water hrlanagemnnt PLLn and the City of La
Quirrta Draft Environmental impact Report is nearly entirely dependant on the success the CVWD
has in acquiring imported rted surface water. Therefore, goundwater should he perceived not as a water
source, but a rem:mace tool to store imported and treated water.
According to the draft water management plan, groundwater in storage in the Coachella Valley has
dee'ined by l .4 million acre feet from 1936 to 1999. For scale, this wsrlpares to a total water source
wader the preferred alternative of632,001) acre feet per year, including Colorado River Water, SW?
water, Recycled Water, and Desalinated Agricultural Drain Water- The preferred alternative will
rcduc:: this deficit to about 11.0 million acre-feet by 2035. By 2035, the annual change in
groundwater storage is+ 6,800 acre-feet l'!' of the planned annual water sources far the basin.
CO] fMINTS REGARDING T1TE CV VD DRAFT WAIAR DriANAGEMCNT PLAN
The water management plan is a rrasonably' We]I wntten and organized document that eoniorms to
California Department of Water Resources mandards for water management plans_ The plan reviews
a number of water management alternatives and identifies one as a preferred alternative- Clearly,
CVWD-s preferred alternative is, intact:, the best management choice. However, because much of
the document focuses on the evaluation of other alternatives, and because the water resource issues
in the Coachella Valley are fairly complicated, there are areas where, in my opinion, the plan could
be better focused. My observations. regardine the draft water management plan pertain to the plan
obi ecrives, er.rtatttty of water sources, safety factors for water management. and contingency
planning.
PL n Obieetiv
tt appears that an unmated objective in the drafiwater management plan is that water shall not be
a limiting constraint to the ]and and economic devetoprnent forecasted :or the area. This carrirnent
is basedcn. 1) the plans described in the preferred alternative, wltichdernonstrates Low the CVWD
will develop water resowces su13 ictentto meet forecasted water demands and; 2) the absence of any
contineency plans by CVWD other than continued mining of groundwater if sufficient imported
water sources cannot be contracted_ In my opinion, it is unlikely that the CI, triATD car} provide a
meaningful warranty that forecasted -water demands can be iuet considering the competition for
315&4 Camii iw Curmel I fakii0r. rtC. moo. CA 5'2i30 F1L OA 2Sr'-6112 Fax 858 219-6094
-- --provide a reserve supp YFto the c-ommunity in the event of droCipt an' be unpoitcd water sonic
areas, spikes in, crater cost, and provide CVWD with a 3trongcr negotiating position in water
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Page 3 of 4
irt2po> water and the need to stop mining grvtizidwater to prevent water qua n degradation
land subsidence.
Air oriel !ent objective identified in the plan is the elimination ofdecreasing groundwater stomp
wad declining groundwaier levels. Howov+:r} the plan does not vosdiv!, state that an incr c in
WWUndwater stomp iF an objective. An I,wreasc ingrvuridwaierstomp snt oev.aryto tnsend that
water levels do not fall below CVWD's water level criteria of 2949 historic k,:i ettInctvoitor
olevntions. This cr,i feria is ettablinhixl to ml nir#.ije The potcrni al for load subsidence as-inciared u ith
grutirdwuter withdrasyal. Though the plan identifies the lovt+ar valley a$ tryst 5oSceptib14 10
Subsidan cc. suiasideri a moairea'irfg data Indiana that the. uppcE valley has befit; eubie oo scica
centimeters (aheu€ 3 Incises) ofsub$itlerice in the past decade. Considering the tential to iafustructure. Mist planter Consider sty furable amaoit of subsidence w d C
t.
Additionally the plan later shows that bused on i.tndwater model pivdictions for me pre k led
altemative,vrxezlevelsinillappcfwillEyaraex led to fail heloW 19 91Ln-elsthusc` ingthis
elca tq Rather risk of land subsidence.
eriaAte of Water Scum
COiractinS of,mported water is is Song term affort With no 6 aa:it413 that the piannod amown or
imported water v4ill t,clually be setJuircd on a tensible basis. The ability 1u ahuuttitrtporral 1,47,11e7
in the iitete will become increasingly more difficult us California's allocation ort:OlOrad0 ki ar
vigor deer a6oz, and crater demand inoTtascs through DK Califortxits and the Sosriltit eat. Tough the
plan Dieraly acknowledges that them la uncertainty is acquiring imported water, ix rn.aI . no plans
for what acticnj wig be taken in tf4 event that there is a s
#ortfell in water sesurces
Additiocally, it is important to Eemember that CVWD's plans to artificially roehar : The toubvf
valley wilt ticstirtace watt' remain technically unproven. Though initial studies apparently %Isnw
reast)n for optimism. artificial rcc]liargc 440.000 to 60.000 acrafeet or
works project that could easily be deJa ed or reduced in tr :s a major public
Laren if the it method of artiilcial raola prO ° tef fully is ar chatty i. r+ ttis.
iri jC6151�•!0 otie r partially � terikniai.lJ
methods s as flfjt tioa wel fi }da Could eventually deliver surface water to the
you ridwater basin. However, a delay in the implemen tat refit orthe rechargero
either depletion*f ro ater3tousenr1imitieie iixtineavaila�bilit}ofterthat 1i1sheto
mots threugh it 'lie vailey_
stet ten _e.Sitnui
Bce41180 there is nn nalanteo ihai CY D can certain contract' for all
to mem farecasbed water d riandt and h the
l itd ' needod
imported water can be reliabl because it wt Jl probahlrtalceyears is tta just halt azsuch
lrtclude rs 7 brought 10 tJic Condit/la Valley, the profited altera.atis a gild
1 roentasge ofthe esti fated a i hint- water resoutco. lope 140 ivrcelit, to be aj locatarl
to groundwater storage. This + i}t r +rmi3ld *Oak is an increase in grounch Ater t, :pis., then
eby
reducing the potential foi land suirsida n.ce and water quoit), desradation from the Salrpn Se.a
and
from shallow poor quo lily water. Overtimer, this additional water placed in storage v.oulti also
provide a reserve supply to the community in the event or drousiu it7 th imlpa„ d v.ztcr Rime
army, Wirt in water rosi, and provide CVwD with a stronger =witting positron in water
758d Ca amrarnici San 11*a, Cal 4? 1.6 Pt ICiB marn i ix aim 2S940.1
¢9.-t1).si1 13:15 FAS d1J aa;l 13091 MATTHEW N Et7LIN Luria
Marko.. P, WieoFrin, C..26.
Page 4 of 4
contracting, Much like financial budgeting, good water budgeting avoids a `,and to mouth"
merit' [Iry and includes atuntingency for less than optimum supply and demand scenarios. This type
of management may become even more important in the future as the amount of domestic
consumption increases 3i=1ce it I s rtu rCdi fit[ tit to reduce the itrnount of dornestia consumption than
i1 is to reduce the amount of agrikultnre Irader imgation. Of course, the cost of creating a water
savinps is itmi the community is deferring the imnnier'liate use of water under a planned scenario to
protect itself- in the future for unfcrseen water shortages. This may result in the delay of and
passible reduction in scope of future development projects
Contin eRcy.Pianniug
In addition to creating a waterrescurce safety factor, water use and land development priotiti2atiort
needs to be developed in the event ofa shortfall. PriuritiLatir.}n could be developed within the plans
for the preferred alternative, vvithun the p]anriiwg departrnents of the various local governments
within the Coachella Valley, or as some tOrrn of joint effort. Shortfalls could he identified either
by the discrepancy between water demand and water supply, or by a ottndwater elevation.
SUNI Y
The La QuirtlFlDraft Comprehensive Gcneral Planneeds'r- acknowl.cdi eandplan forthe. pussihitity
-I t C'J-4 fl may not iDe ahie rc, provide al l the water necessary to meet torecasted without
continuing a {Trsagrarn of groundwater mining. Competition for imported water will become
increasingly more intense in the fortune and it is reasonably possible that (VV4'D will not always be
aid e to obtain crroughh water as the farecastivrl demand_ L:onsequl}ntly, it is appropriate that the water
rtian%]Pc,rrmcnt p]an allocate a pnrliun of artificial rechurrge to inssreased groundwater storage to meet
.unforeseen water shortages without exposing the community to an increased potential for and
subsidence and ,2rourdwater quality dozed -anon. Additionally, CVWD aria local governments,
ineludilig La Quinta, Need to develop a contingency plan for water shortfalls by prioritizing water
uses.
Please contact me if you have questions reaaroiing this malter-
Sincerely, 4a� Dpr
CC
111
1A1 1HEW
Matthew P. Wied]tn
Ca1it.'om;a R0.istered Geologist, No. 5941
Caiifomia Certified Hydrogeolotiist, No, 97
enclosure
cc (without enclosure); Robert Hargreaves, Hest, Rest & Krieger
Steve Robbins. Coachella Valley Water District
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MAT'1Th.Ew P. WIFDLIN, M. .
CALIFORNIA CERTIFIED Il rDROGCOLOGJIST NO. 97
SUMMARY OFEATERIENCE
Mr. Wiedlin is an independent consulting hydrngeologist. He has 18 years experience in water
resources, gcotechnical and environmental consulting_ - e bus conducted ground water supp]v
ewaltiations throughout an Diego County and ;n Orange County_ Additionally, he has conducted
ground water cheracterization and wcLfcld design studies across the country including Californin
and Federal Srxperfux d sites. Le has also developed approaches to assess and rerncdiate areas as
large, as 1.5 square miles that are impacted by high groundwater conditions. He ha.s prepared
groulidwatur 'low and so]rite transport models. .He hasbeen an expert witness or Can lilting expert
on several +gcundwater related laws -nits and has been responsible ter the direction of ground water
rela:erd litigation support projects. Areas of lechncal specialization include Nodose zone hydrulog
and groundwatcr rccliargc evaluation
PROFESSIQNAL REasTRA 770N
• California Registered Geologist, Certificate No, 5941
• California Certified Hydrageniof st, Certificate Nei_ 97
rj 3l Jr[_.rt i 1 (
• NiS., Geologic Sciences, Sari Diego State UnrverSity-, San Diego, Ct'iliforri a 1986
B.A., Ci-eolosric. Suirnt:cs, TTniversir of C'aJi-f'omia, Santa Bar ara. Califcrnia, 1_981
• Borehole Geophysics For Groundvuattr Applications, A two day short course. sponsored by
the National Association of Groundwater Scientists; 1989
• 4C-Hour seminar on Health and Safety Training for Hazardous Waste Sites, presented by
Clayton Euvirorjnental Consultants, Inc.
• Dense Non -Aqueous Phase Fluids to Soil & Groundwater, A three day course sponsored by
the National Association of Groundwater .Scientists, 1987
• Volatile Organic Cornpounds In Soil, A -tree day symposium sponsored by the University
of Wisconsin and the U_S_ Environmental Protection Agency; 1993
• Applied T.ri'v rse f-iounelwater Modeling A two day short course sponsored by the
i eolc zical Society of America, ] 9L
36S4 Coniaito Caurr7d L Idmg. 3n Diego, CA n2]9 D Ph 658 259-5732 Fix 25R 259.6094 anal] 1 of
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MATTHEi i.'IEfLIN fa.:16-
F rRLICATIONS
MATTHEWP.W EDLIN,11+[5.
C LI 'ORNL, CERTITIED IIYDROGEOLOGIST NO. 97
An Evalhation Of F7eld Capacity As A Pcxrumeter For Grototdwaver .Recharge Estim4irp.s_
Theis presented to the faculty of San .Diego State University in partial fuJtiilsncnt of the
requirements for the Degree, Master of Science in Ccology. Spring 1986, MP, 7.1itcllini.
PROFESSIONAL AF 1LL4noNS
• Association of Groumdwal.er Scientists and Engineers
▪ Cirowidu,ater.Resources Association of California
PROFESSIONAL WORK HISTORY — - - -_
A ril 1997-PresdEt Consulting ydro ,eDIogist
994-April 1997 1-lydrogeoiogisrlC.nrporate Officer, Agtti-Ver, Inc., San Diego
199C-7anuary 1994 Project 1v anag r, I-Lir s + -Associates. Inc., La. Jolla, California
1985 to 1989 , taffHydrogen1ogi5t, Hargis 4- Associates, Inc,, I.a Jolla, California
1983 to 1985 Research Assistant in Groundwater Resources, County Piaaning
]Department, San Diego
1979 to 1981 Sta ff Geologist, Wahier Associates, Geotechnic.aa Engineers, Palo alto
3634 Carninsta Carmel I ni iirty, San Diego, CA 9213 D i'h 858 259-6732 Fax 353 259-6094 email
rnwi�dlirUri� �evl+a ¢v. sdsu. edu
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MAT TII.EW P. VIEDLI , M.S.
CALIFORNIA CERTIFIED HYDROGEOLOGIST NO. 97
R EPRESENTA "E PROFESSIONAL ASSIGNMENTS.
▪ Sweetwater Authority -Implemented a groundwater exploration program of the San Diego
formation #'or an aquifer storage and recovery project. The donation program included
deep drilling, geophysical logging,. well installation, and aquifer tests to cvahaate the
resource potential. Aquifer tests included packering of sections to evaluate the vertical
distribution cf groundwater production_ Developed hydrogenlogic work scope fur
production phase nfthe project.
• United States Navy. - a sub onslltant to the Navy, developed and irnplementcd a ground
water and vadose zone study to evaluate the capacity of t}ae aquifer and the adjacent riparian
habitat to accept injected surface water. Conducted borehole geophysics and correlated lab,
t7eld and geophysical rroperties across the site. Conducted large scale pilot tests of
inti]traticn basins and extended aquifer tests. Measured saturated and unsaturated hydraulic
properties to evaluate the infiltration cap?city of the study area and the associated rise in the
water table. Developed a Five -layer groundwater model to evaluate thc impact of water
injection on the water table and the associated change in nutrient concentrations_
• St. 'v irr cut Dc Paul -Developer and am l-ilrrenlly implemented a study to evaluate thc
sustainable yield of the groundwater resource within fractured rock underlying
Irpproxlrrtitely 1,000 acres of kind in East San Diego County as well as thc regicBa]
groundwater resources of the Campo Creek alluvial aquifer, The study includes
groundwater recharge evaluations based on chluride mass analysis and sail moisture
retention methods, an aquifer storage evaluation supported by rnuitiple aquifer tests and
geophysical investigations, groundwater modeling to assess drawdown impacts on oak
wc-odIands and riparian habitat.
• Agricultural Client- Evaluate the source of groundwater tier a large agricultural complex in
the area between the Santa Maria 'Walley and the San Pasqua_ valley, Assess the hydraulic
relationship betvieen the two basins_
• City of Poway- Review and direct groundwater study for a golf course in Sycamore Canyon,
a tributary to the San Diaguito River Basin_ Evaluate szrstaib]e yield, monitor pumping
activity and groundwater elevations and assess Iwdrauhc relationship to San Diegt rto
Canyon.
• Snctwcrest Hciglits lmprevemeni Association- (valuated the water resources of the IJppt;r
San Antonio Canyon Watershed for the village adjacerxt to Mount Baldy in the Sari G-abrieI
Mountains_ PRev,ded recommendations up sustainable yield, exploration targets_ and water
stura t
• Carolla Engineering -Eva] noted ground waier resources for the City of Carlsbad in north San
Diego County as pan of their muster plan for water supply, storm water, and Sewage,
36g4 Cammito Carwei Lane, San Diego, CA 92130 Ph 858 259-6732 f ax 158 259-6094 in it 3 of 6
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MATTfiEV 1t'IEDLI Of `�•`.
MA 1 1 W[ W P_ WiEDLIN, M.S.
CALIFORNIA CERTIFIED Wiv-mtoci OLOGIST NO. 97
REPRESENTATIVE `ALAS 1CJV TENTS (Continued)
•
Hon Development Company- Evaluated ground water conditions including measurement of
vertical hydraulic gradierrts across geologic. units, aquifer testing, prelimmnary, pumping well
spacing hared on aquifer test data. and preliminary groundwater recharge estimates.
Developed a preliminary groundwater pumping plan to control groundwater heads for a
landslide remwdiaraon project. Additional work is planned for 1999,
• Thorsne BartoI]ota McGuire R. Padilla -As a consulting expert provided independent
groundwater evanu5oimi for plaintiff and defendant in a groundwater related lawsuit.
Performed aquifer testing, vadose zone monitoring and groundwater moriitoring to evaluate
a pilot 0-oundwater extraction recant and the direction and velocity of groundwater flaw.
• Aerospace Company -Responsible fir an extensive groundwater assessment program at a
multiple -aquifer federal CERCLA site in Eurbank, California_ Assessment .incluiied
borehole geophysical surveys, inst flat on of approximately 30 monitor wells, approximately
40 aquifer tests, quarterly monitoring of over 100 monitor wells, water quality, water level,
and well construction database management, and thc preparation of approximately 12
dirrerent technical publications La support of rhe assessment
• Chemical Manufacturing Company -Responsible for an extensive groundwater assessment
program at a multiple -aquifer federal CERCLA site in Torrance, California. Assessment
included; installation of approximately 25 monitor wells using sev ral different eons -traction
techniques, borehole geophysical surveys, approximately 2'0 aquifer tests, quarterly
lnurutanng of over C monitor wells. Data was used to design a el:minimnein well field,
• Aerospace Company- Defined hydrostratigrapl}v, conducted aquifer tests cG prepared sits
assessment reports to support wellficld design for a multiple -aquifer site in order to contain
a chlorinated hydrocarbon plume_
• Palomar Mountain Planning Or ranizatimn-Advised orwanization on the proposed expanded
production of groundwater including the veracity of groundwater recharge, groundwater
storage, and groundwater drawdon estimates_
a San Diego County Planning and Land Use Department -Acted as primary researcher for a
fractured rack groundwater resource and recharge study in eastern San Diego County. Work
performed included creating study objectives and establishing field monitoring networks for
groundwater. levels. unsaturated hydraulic parameters, groundwater chemistry, stream
discharge, and phreatophyte transpiration and precipitation_
Sweetwater Authority -Identified potential locations for groundwater production wells for a
water utility company. Well locations wore based on the distribution of alluvial deposits
and environmental restrictions_
3.6M Canvnito Cutncl Landing, San Diego, CA 92 ]30 Ph 858 25P 6732 Fax 858 :? 59-6D94 vrnail
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CALIFORNIA CERTTJTF D rn DRo1;EoLQGIST NO. 97
REPk) SENT 1 TiflE FJ OFEES.S'IJN-1 .dSSIGNMENT..S (Continued)
▪ Private Develntx:r-> valaated ground water recharge, storage capacity, well yield, and
potentiat drawdown effects fir a proposed 100-acre horse ranch in East San Diego t;ounty.
Presented approach and findings at community rocotings,
• San Diego County Environmental Health Dept_-D€:veloped and directed a reglanal ground
•, 3ter study including development of an observation well field, aquifer testing, stream Clow
gauging
• Thorsnes Partollota IVIcGuire Padilla -As a consulting expert, evaluated high ground
water conditions and identified relationship between shallow water table and regional
aquifer Provided groundwater extraction recommendations.
i Law Firm -A -. ,,n e:tperi witness, evaluated higi} ground water conditions in support of a
geotechnical study., construction defect seat pertaining to moisture problems at a housing
tact. Idcntilic i rel;atioltship bctwccn shallow w iter table and regional aquifer.
+ Utvil and ivlecllanical Engineering Firm- Dec/Copes approach ro evaluate we11 yield for a
rnedi urn si ci iuunicipality if east San Diego' County,
• t olte & Associates -Developed and implemented a prog-atn to measure the extent of
blackish arcundwater associated with a cheese manufacturing facility in the San Joaquin
Valley in California, Using surfac-e electromagnetic instrumentation, the survey identified
the extent of impact and identified releases From several dairy farms in the area_
▪ Noranda Minerals -Evacuated the hydrogeologic conditions for a proposed tailing dam site in
Idaho. Work perfcrrrned iutcluded collecting rock core samples for Fracture analysis,
implementing packer aquifer tens, and geolojc wrapping.
▪ Maier Coil CM -party -Performed vapor transtnissivity test (i.e. Air please aquifer test) to
cva'.uate Feasibility of soil vapor extraction program in Riverside County, California,
Managed Soil Vapor Faction modeling effort to estimate extent and time of cleanup.
▪ Major Oil Company -At a 1. s Ani!e]es Area refinery used multi -phase groundwater and oil
modeling to demonstrate he unfeasibility of recovering free-productin one area of the site.
Characterized the vertical ground water gradient and identified resultant errors in previous
wound writer flow direction and gradient calculations performed by ethers. Modeling and
gradient work was supported by an ulectromaenetic borehole survey and hyciniu.hu
J, irartl ier measurement proam to evaluate hvdrogeo3ogic conditions at an oil rctinery
near Los Angeles, California,
36$4 Ca ninito trainee Lanciirrg, San Diego, CA 91 t 31.1 Ph 858 259-6732 Fax 35 S 259-6 N email
5 of 6
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NATTHEw ITT EDL.I to
NIA "THEW P. WIEDLIN, ALS.
CALIFORNIACFR`I'1FIIF_1) HY1)ROGEOLOGIST NO. 97
ILEPRESENTA TTI E PROFESSIONAL L ASSIGNMENTS' ' (Continued)
• National Environmental Engineering Firm -Using steady state numerical calculations,
evaluned hydrocarbon saturation, mobility, and potential recovery by fluid pumping at a
military base in San Diego County. Calculations were based Ixntli an lab and field measured
pararneter5_ Specific hydrocarbon volume (volume per unit area) m a function of product
tivckness, soil capillary properties, and fluff~ properties were calculated. Vertical
hydrocarbon saturation profiles corresponding to static fluid levels anti capillary data were
calculated assuming steady state conditions_ Vertical hydrocarbon hydraulic conductivity
profiles corresponding to the static fluid levels, lab hydraulic conductivity and capillary
values were calculated to evaluate free product mobility. Estimate potential hydrocarbon
recovery rates.
• Aerospace Company -Responsible far an extensive groundwater assessment program at a
multiple -aquifer federal CERCLA site to Burbank.. California Assessment included
borehole geophysical surveys, installation of approximately 30 monitor wells, approximately
40 aquifer tests, quarterly monitoring of over 100 monitor wG;1s, water quality, water level,
andwell L.crzstruciion database Tnanagtmcnt, and the preparation of approximately 12
different technical publications in support of the assessment.
• Chemical Manufacturing Company -Responsible for an extensive grounthsrater assa.srnerlt
proTaln at a multiple -aquifer federal CERCLA site in Torrance, California_ Assessment
included, installation of approximately 25 monitor wells using several different construction
techniques, borehole geophysical surveys, approximately 2(3 aquifer tests, quarterly
monitoring oi_ over 50 rn)nitor wells. Data was used to design a uantainmcnt well field.
+ Aerospace Company- Defined hydrostrat]graphy, conducted aquifer tests & prepared site
assessment reports to support we11f1e1d design for a multiple -aquifer site in order to contain
a chlorinated hydrocarbon pltxrue.
K FLRENC;ES
NAME
POSITION
COMPANY
David i Euntley,
Professor/Consultant
Father Bill Met2dorf
Javid Sirn:no11
Richard 13eiyea
PIIONE NO.
San Diego State University
E:xezurive I)irectcr
City Engineer
PtuTniseland Ranch
St Vincent de Paul Society
City of Poway
Vice Presiuent of
F,nvirorrmerrtal Risk
CcAmerica Bank
Steve Cooiong
Senior Er:>nneer
6I9 224-6422 fh)
619 687-1315
85 S 679-4351
714 424-3313
Navy -Southwest Division
Jim Smythe �� I Chief Engineer
4 _
619 532-2811
Sweetwater Authority
6i9 420-1413
368-1 Camidto Carmel 1iniing, San Diego, CA 92130 Ph 858 259-67 i2.1'ax 858 259-5094 •nisi!
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Mr. Fred Baker
Principal Planner
City of La Quinta
78-495 Cal1e Tampico
La Quinta, CA 92253
Vista Santa Rosa Planning Committee
John Powell, Jr., Chairman
Lee Anderson, Jr.
Richard Fooac
John Gamlin
Albert Keck
Rich Meyers
Ellen Lloyd Troyer
Duane Young
P. O. Box 297
Coachella, CA 92236
September 5, 2001
RE: CITY OF LA QUINTA COMPREHENSIVE GENERAL PLAN/DRAFT
ENVIRONMENTAL IMPACT REPORTISCH 2O00091023
Dear Mr. Baker:
Thank you for the opportunity to comment on the referenced document. The proposed
Annexation No_ 12 and Sphere of Influence amendment includes 'Vista Santa Rosa, approximateLy
19-square miles within territory described more broadly by the EIR as "Thermal." Vista Santa
Rosa had, until last year, been a part of the Thermal community. However, acting upon a request
by some residents, Supervisor Wilson split the Thermal Community and formed a new
Community Council. The Vista Santa Rosa Community Council acts in an advisory capacity to
Supervisor Wilson's office on all matters affecting, or potentially affecting the community, as
defined by its boundaries. It meets monthly, and has not had an opportunity to approve or reject
the comments made cn the attached pages. Rather, the comments are presented by individuals
from the Vista Santa Rosa Community Council Planning Committee. Therefore, the comments
cannot be considered the official position of the Vista Santa Rosa Community Council, but are
representative of the thoughts and concerns of a few of its constituents.
The Planning Committee is comprised of individuals appointed by the Vista Santa Rosa
Community Council to study and rcpon back on land use matters affecting Vista Santa Rosa. The
Planning Committee's Mission Statement, adopted by the unanimous vote of its members, is:
"The development of the Vista Santa Rosa area in a positive, proactive and sensitive
manner that incorporates the ambiance and cuilttrai charm o, f the area, preserves the
property and use rights of land owners and welcomes proposals and ideas from residents,
land owners, developers and civic entities to develop high quality residential,
recreational and commercial projects."
In our view, the most significant local issue pertains to the proposed "Agricultural Overlay," The
Ellt makes several references to this important general plan component; yet, the associated text is
not available in the document for review. This makes it difficult to fully gauge potential impacts
and the effectiveness of the associated mitigation measures. We believe the Agricultural Overlay
is of critical importance and urge the city not to defer its inclusion in the general Ian tcx
available for public review. When our group met with Mayor Peita, Councilmern er Sniff and Ms,
di Iorio ors August 13, the city extended an invitation for us to meet with its environmental
consultant_ We would like to do this as soon as possible to hear its thoughts regarding how our
comments will be addressed in the Final EIR_ We will contact you to arrange the meeting.
Sincerely,
4
Ellen Lloyd Traver
Fur the Vista Santo Rotia Planning Committee
cc: Jerry Herman
Community Development Director
City of La Quinta
P. O. Box 1504
La Quinta, CA 92254
COMMENTS RE: CITY OF LA QIJ]NTA COMPREHENSWE GENERAL
PLAN/DRAFT ENVIRONMENTAL IMPACT REPORTIS U 2000091023
Section ILI-A, "Land Use Compatibility" characterizes 77° 0 of the land area within Annexation
No. I2 as "developed" (Elk III-14), The text also states that approximately 70% (3,782 acres)
is currently dcslgnated for agriculture and very low density residential. The discussion should
clarify whether land currently in agricultural production or other type of rural use is included
within this classification. Much of the area is vacant, in agricultural production, or devoted to
large parcel ranch and equestrian uses. In other words, the area is more accurately described as
"rural" than developed_ The opportunity to safeguard rural lifestyles as urbanization advances is a
key issue for many in the area. For our purposes, "rural lifestyles" includes those uses currently
allowed under the existing zoning and general plan classifications of Riverside County. Farmers
should have the choice to continue with land in agricultural production, much the same as
ranchers should be able to enjoy the use &their lands for horse ranching or other purposes
currently allowed under the existing county ordinances_
The city has assigned a pre-dcrninant general plan classification of"LIAR" (2-4 d.u.lacre) with an
"Agricultural Overlay" overlying much of the same territory. However, the EIR does not provide
a great deal of explanation with respect tr' the overlay. The discussitmn should be expanded to
include more detailed information concerning the Agricultural Overlay and how it will allow for
continued agricultural, equestrian and other niral lifestyles, as both interim and permanent uses_
Specific concerns exist about potential land use conflicts arising as the urban edge expands
outward, and there is an interface with agricultural uses. More particulars are needed that shed
light on how the policies and standards of an Agricultural Overlay would ameliorate conflicts_
Problems at the interface between agricultural uses and new developments could result in practical
or legal difficulties and could have quality of life impacts.
Section tll-B, `°Agricultural Resources" purports to use an Agricultural Overlay (as noted
above), in order to "...preserve agricultural uses to the extent desired by landowners." The text
continues, "Lands within the Agricultural Overlay will be allowed to continue cultivation as under
the existing General Plan, until such time as the landowner chooses to develop." While such
statements should offer comfort to those wlio intend to or are engaged in agricultural pursuits
andlor rural lifestyles, the lack of specifics raises many questions. Rather than defer the details of
the Agricultural Overlay to the future, the policies and standards should be drafted now. Many of
the mitigation measures suggested by the EIR could be incorporated as standards in the
Agricultural Overlay_ Some of'the rriitiga1ion measures appear to address regulatory matters
pertaining to agricultural use of property rather than measures intended to address impacts related
to agricultural resources, i.e. 3. E. & F. Detailed information regarding the overlay would be
useful; including the type of agricultural ]and uses coupled with definitive policies and Standards.
Further, the overlay should anticipate potential conflicts along the urban edge (as anticipated by
the EIR) and offer solutions that have a tangible relationship to underlying technical data. For
example, buffer design should be a function of evaluating the contributing factors associated with
the impacts. Some examples are the type of agricultural activity, the proposed adjacent land use,
the prevailing wind directions, noise contour modeling, pesticide drift, etc. The technical
information should be used to arrive at a scientifically defensible buffer that will adequately
mitigate potential impacts_
Section TD-C, "TratT.c.Cireulation" contemplates a circulation network featuring a system of
arterial, secondary and collector roadways overlying a grid established by section lines, The Vista
Santa Rosa Community Council's "Vision Committee" has developed several preliminary "Vision
Statements' for the area one of which may include large tracts of land developed as very low -
density equestrian oriented communities. In some instances, the type of circulation network
proposed may be over -designed to service the relatively low volumes of traffic generated by such
enclaves and the cross -sections may be out of character with the design of such communities.
One of the challenges (of creating a cohesive, functional circulation system could be a land use
pattern that juxtaposes the more traditional, higher density urban uses with rural lifestyle -type
communities. Solutions will be needed that accomplish the disparate purposes of not
compromising the design integrity of such areas while maintaining the integrity of the circulation
system. One suggestion is that a roadway cross-section he added to its circulation element that is
compatible with a rural lifestyle community, yet achieves the required Levels of Service,
Section III -ID, "Soils & Geology" indicates that much, if not all of the Vista Santa Rosa area
features engineering and geologic properties that make it susceptible to geologic hazards such as
wind erosion, ground failure, and expansive/collapsible soils. Table 1-4, "Land Use Buildout
Statistical Summary„ projects a total of 12,225 units at buildout for Annexation No. 12_ Using
the average household size 0f2.75 persons per household (as purported by the F1R), this equates
to a population of almost 34,000 persons at buildout. Obviously, this is considerably more people
exposed to the potential risk of geologic hazards than the current EIR estimated population of
639 residents. Of particular concern are liquefaction and in particular, subsidence risks.
Subsidence risks are noteworthy because they are associated with pumping of groundwater, as the
EIR suggests. At the current time, the Coachella Valley Water District groundwater management
plan for thc eastern Coachella Valley is being drafted. The EIR should consider the data and
findings being usedysby. CVWD in its study, and incorporate mitigation measures consistent with
CVWD, if suitable. Also, the CVWD groundwater management plan envisions a long period of
stabilization of the overdraft and repienishrncnt of the basin to historic levels. It would be
interesting to see a timeline that compares the anticipated absorption of units within Annexation
No.12 to the implementation of the groundwater management plan. It seems like there would be
a correlation between thc exposure of persons to potential geologic risk and the timing/success
probability of the CV\VD plant_
Section 111-F, "Water Resources/Quality" comments that approximately 40% of domestic
water consumed is reintroduced into the groundwater table through percolation. Ito ever, other
sections of the EIR note that the Thermal area features lacustrinc deposits associated with ancient
Lake Cahuilla, which contain relatively significant amounts of clay_ Clay layers can act as barriers
to groundwater recharge, or what the EIIt refers to as "aquitards," This is evidenced by the
extensive tile drain system in the area, which illustrates how percolation in some locations is in
fact, very poor. It should be noted that the pilot recharge facility located near Avenue 62 and
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Madison Street to which the E. refers lies upstream of what geologists commonly believe was
the shoreline of ancient Lake Cahuilla. Therefore, the percolation characteristics of the surface
and subsurface soils may be very different_ The EIR should consider local factors in the area and
make an assessment concerning how much domestic water can actually be expected to be
recaptured in the groundwater basin.
The characteristically slow percolation rates in the area should also cause the EIR to revisit the
premise that delenlioniretention basins will play any meaningful role in efforts to filter runoff and
stabilizelrecharge the groundwater basin.
A beefed up discussion of the CVWD groundwater management plan, including its data sources,
findings and conclusions, if available, could be incorporated into the EIR. This would help ensure
that there is synonymous thinking regarding the existing conditions and would be useful in
gauging potential impacts and appropriate mitigation measures.
Section lit[-G, "Biological Resources", seems to infer that the city is planning to opt into the
Multiple Species Habitat Conservation Plan now being prepared by the Coachella Valley
Association of Governments and it members (of which La Quinta is one). However, whether this
decision has been made or not is unclear_ The text should clarify whether if the city does not opt
into the Iv,ISHCP, the mitigation measures as proposed are deemed adequate to mitigate any
potential impacts
Section 111-I3, "Cultural Resources." The Torres -Martinez tribe, though not subject to the
general plan, is considered to be a part of the Vista Santa Rosa area. Therefore, we would urge
the city 10 actively solicit the input of the tribal council concerning cultural resources, and for that
matter, on all issues pertaining to general planning and land use.
Section III-S , "Visual Impacts.°" As attempts to define a vision for the area encompassed by
Annexation No. 12 and much of the SOI emerges, preservation of scenic vistas to the Santa Rosa
and San Jacinto Mountains is considered a very important matter. Other mitigation treasures that
could be considered on a project -by -project basis include appropriate use of landscape materials
to allow views, wall heights and materials, grading, etc.
Section Ill-L, "Public Services and Facilities" The provision of public facilities and services
to annexed areas is an area of significant concern. Reliance is placed upon agencies outside the
city, and over which the city has Iittle or no control. However, some of the mitigation measures
assign the responsibility for mitigation on these same agencies. Services that the city does provide
will require funding conunitmenis that once in place, will constitute an annual fiscal drain_
Therefore, the viability of city -provided public services is seen as inexorably linked to the analysis
contained in "Section Ill- , Socio-Economic Resources."
The figures for Annexation No. 12 indicate a deficit of about $5.4 million at buildout. This
analysis is based on achieving an average density of 3 units per acre over the annexation area. It
is assumed that the city anticipates offsetting the deficit with general fund surpluses resulting from
the development and/or annexation of other areas featuring land uses possessing positive fiscal
attributes to the city, i.e. commerciallindustria] development and resort/hospitality. The EIR text
should correlate the liming of Annexation No_ 12 with atuiexation in other areas in order for the
reader to better understand the projected cash flow on an annualized basis. This way, an
assessment can be made of the potential impacts of tuning shifts, or the underachievement of
projected revenue sources in any particular year. Also, it would be interesting to know what the
consequence would be of the density/intensity yield of Annexation No12 being underachieved,
e.g. if the area were to develop Qt 2 units per acre, rather than 3, with a corresponding reduction
in other non-residential uses as well.
IRIS CAPITAL GROUP
Private Investments and Real estate
150 A. Robertson Blvd Suite 320
Beverly Hills, CA 90211
Tel. (310) 657-6464 Fax (310) 657-8662
August 27, 2D01
Mr_ Fred Baker
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Re: City of La Quint Judy 2001
Draft Comprehensive General Plan
Draft Environmental Impact Report
SCD No.: 2000091023
Draft Master Environmental Assessment
Dear Mr. Baker,
This Draft EIR is not an objective assessment of the environmental impacts. It is biased
and therefore does not satisfy the requirements of CEQA.
The above referenced Draft Environmental Impact Report (ETR) for the Proposed
Comprehensive General Plan ("The Plan") does not adequately address the following
issues which should be resolved and corrected before the EIR is adequate per CLQA and
any General Plan is updated_ Many of these issues were raised before regarding your
Notice ofPreparation of an Environmental Impact Report for the City ofLa Quinta
General plan up date notice to the General Plan, but were ignored_ Again, I raise then
and refer you again to the letter by Ellen Trevor dated May 21,2001.
Per state law you are required to adequately address the issues that have significant
impact and not with a biased view, but with an objective view which does not seem to be
occurring.
The issues that need to be addressed so that the EIR would actually be adequate and legal
per CEQA guidelines arc as follows:
1. The Agricultural Overlay is unclear_ The Plan does not define in detail what types
of properties are incorporated into the Agi icultural Overlay yet refers to it
constantly throughout the report. In fact there is no clearly written and defined
agricultural overlay per the City ofLa Quinta. Therefore, the EIR is invalid until
this is clearly defined. ,
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2 The Socio-Econornic impact of the proposed development on the equestrian
industry and uses within the Annexation Area No. 12 (AA) and the proposed
Sphere of Influence (SOI) have not been addressed even though this issue has
been raised numerous times to the city of La Quinta in letter and verbal form, in
City Council meetings, and in letters regarding the Proposed Notice of
Preparation of the FIR. The Draft ETR still ignores the Iikely damage to the horse
industry that currently brings in about S70,000,000 annually into the local region,
and is projected to grow to $120,000,000 in the next few years. Development of
the annexation and SOI area with 2-4 houses per acre with no equestrian overlay
and protections, wide roads, and resort, commercial and industrial development,
with only 100 fool buffer zones, will ultimately decimate this burgeoning industry
by destroying stabling and training facilities, shrink the agricultural pasture lands
making livestock and horses too expensive to keep, and decimate the local alfalfa
industry. The Proposed La Quinta General Plan Alternative, will negatively
impact the equestrian community and severely reduce local employment and
tourism due to the equestrian industry, particularly for the Cities of Indio and
Coachella.
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3, La Quinta has provided no equestrian overlay or provision for equestrian use as a
mitigation measure which would be easy to incorporate into the Plan, even though
a significant portion ofthe entire area proposed to be annexed and put into the
Sphere of Influence(SOI) is equestrian oriented. This must be addressed and
thoroughly mitigated through wider buffer areas, reduced development density,
smaller roadways particularly through the "Vista Santa Rosa " maintaining two
lane rural roads and imposing 35 mph speed limits along with soli curbs and side
of road areas for safe equestrian passage. The Vista Santa Rosa is bounded by
Avenues 52 and 66, Harrison and Monroe.
4. Per the County Regional plan, equestrian trails were to be incorporated
throughout the area. They have been virtually left out in certain areas such as
along Avenue 60, changed to golf cart paths or obscured in the Proposed General
Plan and not addressed in the ELF, in traffic issues, cultural resources, or socio-
economic impacts. e_ The EIR does not address this issue and the Plan does not
accommodate the trails that should be shown and were provided for in the
Specific Plan for PGA West and in the Regional .Plan,
5_ Wildlife corridors and movement to open space will be destroyed. The trail
system would of allowed wildlife movement throughout the area_ A valid, safe
and complete equestrian trail system would allow for the corridor/movement of
wildlife throughout the area and to open space. With the lack ofan adequate trail
system through this area, La Quinta will have destroyed any ability of the native
wildlife to have survived. The trails should go throughout the area, and roads
made smaller down to ro lanes with soil edges instead of curbs to provide and
protect wildlife movement and equestrian usage.
The proposed development density, road system, and traffic load will destroy the
ability to utilize the roadways safely for agricultural or equestrian uses, The
proposed traffic increase to 1,250,000 traffic trips per day will make unsafe usage Z - S
ofthe roads for livestock, horses, or farm equipment. Per CEQA this must be
thoroughly addressed and mitigated which has not been done.
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7, Per CEQA, traffic plans must accommodate the movement of agricultural
equipment when the annexation is of agricultural land. This has not been done.
Furthermore, the traffic, plan would not accommodate horse trailers. The
roundabout at Jefferson and 52°`' right near the Polo club is impossible for a ]ar• e
trailer to navigate safely.
8, The proposed roadway system and traffic plan would destroy the scenic resources
of the area, {)ne of the most beautiful roadways in the entire area is palm tree -
lined Avenue 60, between Jackson and Van Buren. Yet it is planned to be major
arterial. The impact of the roadway system destroying scenic resources must be
addressed and mitigated_ The roadway system is too large and aggressive
throughout the Vista Santa Rosa area. It should be reduced to two lanes soft
curbs, no lights, and 35 MPH speed limits.
9. The claim that "This land use designation of up to two units per acre provides a
transition between agricultural lands and more intense urban uses and promotes a
progression of compatible land uses." This is invalid as a transition as the densit
will provide significant problems for neighboring agricu]turaliranch uses.
10. Mitigation of buffer areas of 100 feet are completely inadequate. It should be 500
feet and the zoning density decreased significantly-
11 _ The No Project Alternative would be a better choice. It would preserve the
current agricultural land use designations and preserve the ability to farm and
allow the g.rowth of the equestrian industry_
12. The traffic impact at build -cut which would generate approx. 1,200,150 daily
vehicle trips per day in the area, would have a significant impact. It would not
operate within acceptable levels in the annexation, and SOI area. 15 roadway
segments would exceed capacity. This would cause a significant impact on
agricultural and equestrian usage. To state otherwise is biased_
11 Water Resources will be significantly impacted per CNIVID. The EIR does not
adequately mitigate or address the depletion of the groundwater and the depletion
ofhocal wells of the residents in annexation and SOI areas. Again the EIR is
biased. Per The LIR states that CVWD has demonstrated that groundwater
recharge at this location south of Lake Cahuilla since 1996 has been feasible_
This is not completely tnie and misleading_
14, The claim that 40% of domestic water is re -absorbed into the groundwater table
and not lost is not true in the lower eastern Coachella basin, Moreover, any
recharge water is not as clean as the original groundwater. The impact ofthis has
not been adequately addressed. There will be a need to build out new treatment
plants —who pay for this and what is the socio-economic impact of this on the
area residents? Who will mitigate the residents for their wells drying up as the
overdraft on the water table is furthered by the proposed development.
15, The ELK claims La Quinta will protect domestic water supplies. How? The
socio-econornic impact on the residents of switching from septic and wells to
CV M'D has not been addressed. Again, who pays for this and the sewer lines`?
and what is Ihe impact an the residents.
16. There is no real provision for Open Space or biological resource survival, The
EIR states "the general Plan artiriexation and LOI land use designations all propose
to maintain a low density development pattern and preserve sensitive biological
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areas as undevelopable open space." Identifying golf courses as open space is not
per government code_ A golf course is not a valid resource area for biological
survival as golf courses have a high usage of pesticides and chemical fertilizers_
This must be addressed. Implementation is not expected to have a significant
adverse impact on biological resources_" —This is not truel .No where in the midst
of the area La Quinta claims to be preserving is there any really useful open space
except the edge of some rocky knolls that are really impossible to utilise except
for rack climbers and bighorn sheep. The lack ofwild]ife corridors and
greenbelts without walls, that allow access to real open space areas, will
significantly impact the biological resources of the area.
17. The potential increase in pesticides and chemical fertilizers due to the increase
golf courses and median and roadway strips has not been considered on the
groundwater and wildlife.
18. The destruction of prime farmlands has not been fully addressed or mitigated.
Over 30% of all the dates in North America are grown in the Vista Santa Rosa
area of the plan alone. In the entire annexation and planning area, the number
could be virtually 80%. This issue has not been fully addressed or sufficiently
mitigated.
19. The destruction of the scenic resources of the area has not been fully addressed or
mitigated. The views of the Santa Rosa mountains is one of the most special parts
of the area, loved by all who live in the area Cr visit There is nothing in the plan
that truly protects that, such as the elimination of walls and berms, and the plan
for view corridors.
20_ Air pollution increase in the basin is falsely represented as it will be significant
due to the increased motor trips_ '
21. More open space is defined as golf courses Golf courses may or may not be
public or visible so it is not real "open space"_ And is a misuse and misleadine
term.-I-22_
22. II-3 Agricultural Resources: Never mentions equestrian uses, pasture and
alfalfa, which is inadequate,
23. The planned additional 66,811 residential units at 75% build -cut, is outrageous
for the area, and will have a more than significant impact on all aspects of the
arca. That is a virtual another Los Angeles_ This will destroy the local economy
as the reason people come from LA is to get away from the density. The
negative impact to the local economy of the proposed development must be
considered_
24. On page 1IT-10, the EIR states the proposed land use densities and assignment do
not appear to pose any significant land use incompatibilities with existing or
planned land uses in adjacent jurisdictions." This is completely untrue and biased.
All the true and cumulative impacts must be addressed. 25. Open space Land uses—III-12 No real open space is actually being planned_ Golf
courses are not Open Space. The park area actually planned in the annexation and
sphere of influence area is only 20 acres, in an area comprising over 12,000 acres.
This is completely inadequate for the public and potential residents.
26. The Summary oflmpacts is invalid and biased. On page II1-I3, the E.IR states
that "impacts within the City of La Quints and on surrounding lands resulting
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from adopting implementation cfthe proposed General Plan are not expected to
be significant" This is completely false_ How can an additional 1,250,000 daily
traffic trips and 66,000 new homes immediately adjacent not be significant? This
is a biased EIR. The impact on agricultural alone will change the financial
dynamics of Indio and Coachella and Riverside County. The ultimate elimination
of equestrian ranches will impact the horse industry and dynamics of that vital
industry in the desert to say nothing ofthe removal of year round activities being
changed to resort and second homes thus dirninishing year round activity for
many businesses.
27_ The EIR states that the approval of the SOI amendment would not result in any
significant adverse environmental impacts to lands within the SOI or its vicinity,
per their OR. This not true, and again biased, It would diminish the local
residents self -destiny and would encourage more development, as La Quints is
pro -development. It will diminish the equestrian interest in the area and thus
reduce the value ofthe local properties, as the plan does not accommodate
equestrian interests.
Sincerely,
Tracey Darroll
Resident and Land Owner
83-5&1 Avenue 60
Thermal (Vista Santa Rosa), CA 92274
Cin.CIrI.
Tel. ?HI 347.6:,'i
Fax: r6 : • 3.I 2-6i°]/
Tel: 760 . 347-(vk0
FEC.. 7E1 Sa_ 6}07
CITY OF INDIO
Y �1
Ihji:
crry OF LQUINTA
L,NfIN� DEPARTMENT
Mr. Fred Baker, Principal Planner
City of La Quinta
78-495 Calle Tampico
La Quinta, CA 92253
Development Services Department
September 10, 2001
Subject: Environmental Review - La Quinta General Plan E1R
Tel 761.1.3d3-654' Li —ear Mr_ Baker:
Fa;: 760 24 2-r;SY:
Tel: 761:7.t'-r,sfio Pursuant to your July 13, 2001, transmittal. we have reviewed the Draft
'' ';''-'Ej Environmental Impact Report (DEIR) for the City of La Quinta General Plan. While
your transmittal indicated that the last day to file comments was August 25 (Sunday)
• 7;-3711I the law requires a minimum of 45 days for the review of the DEIR. Therefore, the
end of the minimum required comment period was August 27, 2001, the 45" day
Tel: MU 342-6540 from your date of transmittal. However, your office notified us that they have
raa: 760 34,.
extended the comment period to September 10, 2001. Therefore, we respectfully
721: ) . sal as2_ offer the following comments submitted within the noticed comment period.
]. 7-43I7
The environmental analysis of the General Plan includes approximately 52,498
tial; '1fi0 31;4.:3u
• 76l1 . ;,1?-2,59, acres encompassing the City of La ❑uinta's corporate boundaries (20,254 acres);
a proposed annexation area (5,420 acres); a sphere -of -influence amendment
1I:17 7(11 317-105R 08,205 acres); and lands outside the sphere (19,610 acres). The City of Indio is
Ti.l' .?a7'SIII 19,619 acres located outside the sphere of Influence of the City of La Quinta - and
• 76l1 . 6551 it is to that area in particular that we address our comments and concerns. Because
of the proposed project's potential effect on the City of Indio, we have carefully
reviewed the DEIR to ascertain whether it addresses all of the potential impacts, as
established by the California Environmental Quality Act (CEQA) and the State
CEQA guidelines_
particularlyconcerned about the latter of these areas under consideration — the
Fred Baker, Principal Planner
City of La Quints
September 10. 2001
Page 2
Our conclusion - the DEIR fails to meet the minimum legal requirements for both
procedural and substantive aspects necessary to carry out a complete, thorough
and objective analysis in accordance with CEQA. to particular, the DEIR is flawed
and deficient in the areas of:
• Proper notice to affected and adjoining governmental jurisdictions.
• General Plan, zoning and land use descriptions of Indio Ranchos Country
Estates and Polo Resorts properties immediately adjacent to your area of
interest and north of Avenues 50 and 52 in the City of Indio are not identified or
are inadequately described. These are areas of particular concern to the City of
Indio, its residents and investors and must be addressed in the DEIR.
▪ Traffic impacts upon the City of Indio including impacts upon such major
ncrthlsouth roads as Jefferson, Madison, Monroe, Jackson, Calhoun and Sian
Buren which provide the most direct access to both Highway 111 and the I-10
freeway and all of the inter -related intersections thereto resulting from the
potential of 80,000 new dwelling units rather than 66,000 dwelling units identified
in the DEIR.
• Traffic impacts upon the City of Indio including impacts upon such major
eastlwest roads as Avenue 52, Avenue 50, Avenue 49, Avenue 48, Highway
111, Miles Avenue, Fred Waring Drive and all of the inter -related intersections
thereto resulting from the potential of 80,000 new dwelling units rather than
66,000 dwelling units identified in the ❑EIR.
• Cumulative impacts upon all areas of sensitivity to thresholds including
mitigation measures, public improvements and other financial offsets for
enhanced infrastructure to affected public agencies necessary to properly
mitigate the significant impacts.
• Consideration of reasonable municipal service agency alternatives to the project
including leaving the area within the City of Coachella Sphere of Influence,
placing the area into the City of lndio's Sphere of Influence, creation of a Vista
Santa Rosa Municipal Advisory Council under the jurisdiction of the County of
Riverside or the incorporation of a city of Vista Santa Rosa,
• In other instances, the DEIR contains summary and canclusionary statements
that are not supported by any information, documentation or analytical data.
Fred Baker, Principal Planner
City of La Quirite
Septernter 10, 2001
Page 3
In determining the proper scope of an E1R, it is necessary to consult with the
appropriate agencies, municipalities, and public who will be impacted by the
proposed actions, Because a portion of the area being considered for annexation
and a sphere -of -influence amendment currently lies in the city of Coachelia's
sphere -of -influence and the fact that both cities of Indio and Coachella would bear
impacts from buildout of the proposed General Plan, the absence of a "Notice of
Intent to Prepare an EIR" to the City of Indio has resulted in a void of information
relative to impacts upon the City of Indio. Traffic, noise, land use, and water
resource impacts upon the City of Indio were not fully analyzed or disclosed in the
DE]R. It should be noted that the City of India was not sent a Notice of Preparation
(NOP) for the DEIR. It is unclear to us whether such notice was overlooked with the
City of Coachella - and if it was, there may be additional shortcomings in this DEIR.
Although the document contains a substantial amount of information, the DEIR is
inadequate since it fails to fully analyze the General Plan's impact on several
environmental categories including mineral resources, hazards and hazardous
materials, and parks and recreation. These categories were identified in the Initial
Study as less than significant and potentially significant, This is very questionable
since the buildout will add about 66,811 new dwelling units (see comment below
regarding the potential maximum buildout)_ Ail of the environmental categories
identified above that have been excluded in the DE1R are required to be analyzed
in EIRs for general plans.
AA
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The DEIR fails to include an accurate project description, In particular, the DEIR
ignores the fact that the area being considered for annexation and sphere -of -
influence amendrnent is currently in the City of Coachella's sphere -of -influence. This
oversight is significant for all parties involved (citizens and property owners in and
surrounding areas, investorsldevelcpers, affected public agencies) irr the decision
making process regarding this very important land resource opportunity. All AA — 9
members of the public are owed a reasonable description and comparison analysis
of ail options in analyzing your proposal. In fact, one of the actions necessary to
achieve the project's end result is a t_AF O Sphere of Influence Amendment by the
City of Coachella deleting a portion of their SCI.
The DEIR fails to provide any thresholds of significance as a baseline for AA
determining whether the impact for each of the issue areas is significant,
Fred Baker, principal Planner
City of La Quinta
September 10, 2001
Pase4
The analysis in the DEIR underestimates the impacts of buildout of the proposed
General Plan and the proposed annexation and sphere -of -influence amendment
areas on the adjacent cities of Indio and Coachella_ This is especially apparent in
the impact analysis for public services and utilities, The ❑EIR uses 2.75 persons per
household to determine the impacts_ This number is considerably lower than the
household size figures used by the California Department of Finance (3.263
persons per household), and the Southern California Association of Governments
(3.24 persons per household - 2005 and 3.14 pers❑ns per household - 2020). The
DElR's low household size figure is used throughout the analysis, significantly
underestimating the impacts of the buildout of the General Plan on a!I public
services and utilities by 20 percent — that is as much as 13,362 additional
households and dwelling units.
Alternative analysis in the DEIR is inadequate because it does not comply with
GFQA's requirement to provide alternatives that substantially lessen or avoid
environmental damage. Instead. the DEIR presents a 'more intense development
scenario" which does not lessen or avoid environmental damage and has impacts
greater than General Plan buildout.
Besides containing substantial errors in forecasting impacts, the DEIR also Lacks I
consistent application of the cumulative impact analysis, especially as it pertains to
the proposed annexation and sphere -of -influence amendment_ Time and time
again, the cumulative impact analysis for an environmental category consists of a
brief, superficial discussion that is factually lacking.
In sum, the DEIR discounts or entirely ignores many significant, adverse
environmental impacts associated with buildcut of the Generat Plan and the
pr❑posed annexation and sphere -of -influence amendment areas_ An ER must be
prepared with a sufficient degree of analysis to provide decision makers with
information which enables them to take necessary and appropriate actions. The
DEIR's analysis of the project's impacts fails this test, being seriously misleading
and inaccurate.
The following is a list of some of the deficiencies in the DEIR. V 1e conclude that the
DEIR is inadequate in its present form and that the DE1R requires additional
information and analysis of such substantial nature that it cannot be completely
corrected by simply responding to the comments which follow. The additional
information, needed for the Riverside County LAFCC to make an informed and
intelligent decision in accordance with CEQA Guidelines, is so extensive as to justify
additional peer review by recirculating the EIR as a draft for public review. Prior to
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Fred Baker, Principal Planner
City of La Quinta
September 10, 2001.
Page .
recirculating the EIR, the issues raised in these comments need to be fullyAA - 1
addressed, Without the benefit of peer review, the information presented to LAFCO
will contain many of the flaws identified below.
Detailed Comments
Page 1-4 Project Description
The project description does riot disclose that a substantial portion of the area being
considered for the proposed annexation and sphere -of -influence amendment is
currently in the city of Coachella. Rather, the DEIR addresses the City, its SGl and
land outside the S01. While the existing City area encompasses 31 square miles;
existing SQI area includes another 2.7 square miles; the area outside the SO1
encompasses an additional 49 square miles. Clearly the preponderance of the area
reported in the DEIR is located outside the City of La Quinta Sphere of Influence
and yet the level of information provided for this area is described at best, as being
"broad." Perhaps a better term might be to describe the DEJR's description and
analysis of this area outside the S01 is "vague.'
Page 1-9 Existing Land Uses
There is a discrepancy between the number of acres and dwelling units disclosed
in the second and third paragraphs, and those shown on Tables 1-1 and 1-2.
Normally, this would be a simple mathematical error that could be easily corrected.
However, it may be indicative of a common and critical error in this document, i.e.
making incorrect mathematical forecasts for critical issues.
1
Pagel-10
The second paragraph refers to the properties within the jurisdiction of the City of
Indio. It is a general description that offers an inaccurate depiction of what exists
and planned for areas critically close and adjacent to the proposed Sphere of
Influence amendment area. In particular, existing land uses located in the two
square mile area bounded by Avenue 52 on the south, Madison and Jackson
Streets on the west and east, and Avenue 50 on the north are oriented around
major equestrian facilities including the Empire Polo Grounds, the El Dorado Polo
Grounds and the Horses in the Sun (HITS) equestrian facilities. These land use
activities are core equestrian facilities that have resulted in the establishment of very
significant equestrian investments for the area, including new estate sized lots and
housing with equestrian permitted accessory uses. In addition, the area immediately
i
AA —116
AA-17
AA-18
Fred Baker, Principal Planner
City of La Quinta
September 10, 2001
Page 6
north of Avenue 50 is also zoned and used for equestrian oriented single family
residential properties.
The Indio General Plan and zoning for these areas (Country Estates Indio Ranchos
zoning and Indio Ranchos Polo states Specific Plan) recognize existing land uses
and projects future land use policy to be of an equestrian nature. To ignore their
presence in and around this portion of the Vista Santa Rosa community would be
a disservice to both existing and future landowners of the area; not to mention the
land use ramifications of non -equestrian properties locating nearby equestrian
oriented activities such as these. It would seem "good planning„ to build upon the
equestrian orientation that is being pursued by both the City of Indio and the Vista
Santa Rose community.
Page I-12
On Table 1-1. two columns of information are reported: "City of La Quinta" and
"Sphere/Planning Area." The latter column croups together the land area currently
in the City of La Quintas Sphere of influence and the land area currently in the City
of Coachella sphere of influence. The table needs to be enlarged to accommodate
a split of the latter category into two distinct categories for analysis to better enable
the reader the opportunity of comprehending and assessing the issue of deleting
the 19,619 acres from the Coachella SOl and placing that area or a portion thereof
into the La Quinta SOI.
Page 1-13
On Table I-2. what is the land use buildout for the City of La Quinta, the proposed
annexation area, the sphere -of -influence amendment area, and the remaining
planning area? In the Office category as well as the Commercial and Industrial
subtotals, there are many typographical errors which makes it difficult to distinguish
the correct buildout numbers for Office, Commercial and industrial land uses. What
is the correct buildout for Office? What are the correct Commercial subtotal? What
are the correct Industrial land uses? This could be an easily corrected simple error_
However, it is indicative of a pattern of errors in this document that includes
providing incorrect information for critical issues.
Pages 1-19 and 1-20
On Tables 1-4 and 1-5, what are the existing land uses (not the existing General Plan
designations) for the proposed annexation area, sphere -of -influences amendment 1AA— 21
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AA—Z20
Fred Baker, Principal Planner
City of La Quints
September 10, 20C1
Page 7
area, and the remaining planning area? How many acres of the proposed
annexation, sphere -of -influence, and remaining planning area are currently being
used for agricultural? Classifying their existing land uses as either "very low density
or low density" is misleading and incorrect.
Pages 1-20 and 1-21
The discussion regarding residential land uses is also misleading and incorrect.
What are the existing residential land uses? How many dwelling units and
residential acres are currently in the city of La Quinta, the proposed annexation
area. the sphere -of -influence amendment area, and the remaining planning area?
What information and methodology have been used to derive the assumption of "75
percent of the maximum densities permitted"? How many acres of "residential
development" are currently being farmed or used for agricultural?
Page 1-22 and 23
There is no mention that a portion of the area within the proposed annexation and
sphere -of -influence amendment is currently within the sphere-af-influence for the
city of Coachella. How many acres of the proposed annexation and the sphere -of -
influence amendment areas are in Coachella's existing sphere -of -influence? How
many acres of Coachella's existing sphere -of -Influence are currently used for
agricultural? What is the average household size for the proposed annexation and
the sphere -of -influence amendment areas according to the 2000 Census? What
information and methodology have been used to derive the household size of 2.75
persons per household? This is lower than the figure used by the California
Department of Finance and SCAG.
Page 1-25
Information provided in the first and second paragraphs regarding the number of
acres designated for Very Low Density Residential (7,089 vs. 6,280) and Low
Density Residential (22,705 vs. 11,335) is not consistent with the numbers shown
on Table 1-1, Why is there an discrepancy? How many acres are going be
designated es Very Low Density and Law Density Residential?
Page 1-27
i
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AA-22
AA —23
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Impacts on water resources are one of the many critical components in the DE1R
where impacts have been vastly underestimated. If the population is AA — 25
Fred Baker, Principal Planner
City of La Quinta
September 10, 2001
Page 8
ld
underestimated. then water usage is underestimated. derived whentl�ecw Ga�fornia Departmentas the low of
size of 2.75 persons per household
Finance and SLAG have projecteused ��lcor�e uop2 2.75 3.2 and above? household figure?at are
How
the assumptions and methodologies
is it determined that only 75 percent of the residential lands would have maximum
densities permitted? How was the population figure of 207,970 derived? According
to Table 1-2, at buildout, the General Plan will result in 78,952 dwelling units. Using
the law household size of 2.75 personsdusehold,n populatione iVo maliythis
is
217,118 persons, not 207,970 persons asisclosed itheDEIR.
would be a simple mathematical error that could be easily corrected. However, it
may be indicative of a common, and critical error in this document, that includes
making incorrect mathematical forecasts for key issues_
Page 1t-1
What are the existing land uses (not the existing General Plan designations) for the
City of La Quinta, the proposedmanexation 1lingrea, units andrhat type of dwelling units
ndment
area, and planning area? How Y d
(single family vs. multi family, seasonal, low income housing) in La Quinta, the
proposed annexation area, sphere -of -influence amendment area and remaining
portion of the planning area? How many etsquare feet annexation fa eamercial and sphere of-ofial
AA — 26
uses are in La Quints, the proposed
amendment area, and remainder of the planning area? Flow many acres of parks
and open space exist? How many acres and square feet of public/quasi-public
facilities currently exist? How are many acres are currently in agricultural
production? Why was there no mention of the �nfluence areasct that a antial are currently fly irtion n the
f the
area of the proposed annexation and sphere -of -influence af
city of Coachella's sphere -of -influence?
Page 11-2 Existing Land Uses
Why is there such a large discrepancy between the information provided in the AA 27
discussion of the existing land uses and the information provided on Table
Page 11-2 Surrounding Land Uses
The information provided in the DEIR is inadequate regarding surrounding land
uses in Indio and Coachella. Where are Indio and Coachella's residential, A 28
commercial, and industrial areas in relationship to the proposed General Plan,
annexation area, and sphere -of -influence amendment area? Where are the
1
AA - 25
Free Baker, Prnnc:pah Planner
City of La Quints
Septernber 10, 2001
Page 9
potential land use conflicts?
Page 11-3
The DER downplays the fact that approximately 40 percent of the existing area
(19,938 acres) in the General Plan which is currently used for agricultural purposes
will be converted to urban development. What are the potential land use conflicts
between proposed residential developments and existing agricultural operations?
What about potential conflicts with surrounding equestrian properties to the north
in the City of Indio? The close proximity to the Polo Grounds and the Desert HITS
facilities?
AA — 29
Page !l-6
The majority of the plannin❑ area is located in a high liquefaction hazard area. This AA
needs to be identified in the existing setting as well as identified as an issue of
future analysis and mitigation,
Page II-13
Domestic Water
No mention is made of the serious groundwater overdraft situation in the Coachella
Valley or that the amount of water which is being pumped in from Colorado River
to recharge the areas is being reduced. There is also no discussion of the
subsidence caused by the groundwater overdraft situation. There is no inf❑rmation AA 31
provided regarding how ;much growth the Coachella Valley can support in the future
and whether the development being proposed by the General Plan can be
facilitated and by what means or costs to other existing development policies.
VVastewater Treatment
No information is given as to the current capacity of wastewater treatment facilities
that will be serving the planning area and whether they can support the additional
development from the proposed General Plan at buildcut; or a phasing plan for
implementation.
Solid Waste
No information is provided as to the capacity of the landfills that will be servicing the
planning area and whether the landfills can accommodate projected development.
AA-32
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Fred Baker, Principal Planner
City of La Quints
September 10, 2001
Page 10
Page III-2
The DEIR does not provide any information regarding existing land uses within the
proposed General Plan area. How many dwelling units and type of dwelling units
(single family vs, multi family, seasonal, low-income housing, equestrian oriented)
in the City of La Quinta, the proposed annexation area, sphere -of -influence
amendment area, the adjoining areas in the City of Indio and the remaining portion
of the planning area? What is the comparative assessment between existing
residential, current land use policy and what is being proposed? How many square
feet of commercial and industrial uses are in La Quinta, the proposed annexation
area, sphere -of -influence amendment area, and the remainder of the planning
area? What is the difference between existing commercial/industrial land uses and
what is proposed? How many acres exist or are proposed for putllic parks and
recreation areas? How will General Plan buildout impact public parks and recreation
areas? F-Iow many acres and square feet of public/quasi-public facilities now exist,
and how many are proposed? How many acres are currently in agricultural? How
many agricultural acres will be lost to urban development as proposed by the
General Plan?
Page III-3
How was it established that only 75 percent of the residential lands would have
maximum densities permitted? What are the methodology and information used to
substantiate the 75 percent assumption? How did the analyst derive a 22 percent
lot coverage assumption for buildout of commercial use? What are the methodology
and information used to substantiate the commercial lands? How did the analyst
derive a 34 percent lot coverage assumption for buildout of industrial uses? What
are the methodology and information used to substantiate the industrial lands
assumption? How do these assumptions differ from what is currently happening in
the Coachella Valley?
Page III-4
Exhibit III-ldoes not distinguish between Agricultural and Very Low Density
residential land uses. According to the DEIR, 19,938 acres currently are designated
Agricultural. There is a significant difference between the two land uses, and this
difference needs to be shown. Also, there is no indication that the proposed
annexation and sphere -of -influence amendment areas currently are in the city of
Coachella's sphere -of -influence. In addition, there is no indication of what the
existing land uses are for the adjacent jurisdictions affected by the proposed
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Fred Baker, Principal Planner
City of La Quinta
September 10. 2001
Page 11
General Plan. Exhibit III-1 reds to be corrected to show the difference between
the Agricultural and Very, Low Residential land uses, Coachella's existing sphere -of- AA - 36
influence, and existing land uses for adjacent jurisdictions (cities of Indio and
Coachella).
Page 111-6
Why are there inconsistencies between Table 111-1 (Current General Plan - Land
Use Buildout Statistical Surnrnary) and Tables 1-1 and 1-2? Table III-1 states that
there are 19,938 acies of Agriculture (1 du/10 acres), out of which 16,132 acres are
designated for urban development. Why are there no existing dwelling units listed
for these urban areas? Also, there lacks mention in either Tables 1-1 or 1-2 of
agricultural land, when Table III clearly states that 16,132 agricultural acres are set
aside for urban development. Thus, the sub -totals for each of the categories on
Table 111-1 are in conflict with those in Tables 1-1 and 1-2.
Page III-10, fourth paragraph
The DEIR does not address land use impacts on adjacent jurisdictions. which
contain rural residential, agricullural, and private recreational areas. The higher
residential densities and assignments proposed by the General Plan would be
incompatible with adjacent jurisdictions` land uses and could create significant
impacts.
Page 111-13
What methodology and approach have been to utilized to assess land use impacts
resulting from buildout of the proposed General Plan? What threshold of
significance was used to evaluate land use impacts?
Summary of impacts
No information or analysis is provided regarding land use impacts on adjacent
jurisdictions. The majority of the proposed annexation and sphere -of- influence
amendment areas currently are in agricultural use. The proposed General Plan
would designate these areas for residential development with no transitional land
to buffer the existing agricultural operations. This would cause significant land use
impact. -
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Fred Baker, Principal Renner
City of La 0uinta
September 10, 2001
Page 12
Page 4II-14
How many acres within the proposed annexation area currently are used and
designated as either Agricultural or Very Low Density Residential?
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Page 111-15
The city of Coachella's current sphere -of -influence should be designated on Exhibit AA — 42
111-3.
Page LHI-17
No information is provided in the DEER identifying land uses in jurisdictions adjacent
to the proposed annexation area. The majority ❑f the adjacent land uses are
agricultural. The proposed General Plan would designate areas currently used for
agriculture to urban development. This could result in significant land use
incompatibilities.
Page 111-18
In the proposed sphere -of -influence amendment area, the DEIR fails to specify the
number of acres currently used for agricultural, nor does it identify land uses in
jurisdictions adjacent to the proposed amendment area. How many acres in the
proposed sphere-of-infiuenoe area support agriculture? The proposed General Plan
would change land currently designated for agriculture to urban use, This would
result in significant land use incompatibilities with existing and adjacent land. Again,
the DEIR fails to mention that the proposed sphere -of -influence amendment area
currently is in the city of Coachella's sphere -of -influence.
Page III-20
The majority of the proposed sphere -of -influence area and adjacent land uses
currently support agricultural operations. The proposed General Plan would
designate an area currently used for agriculture to urban development. This would
create significant land use incompatibilities with existing adjacent land uses.
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Fred Baker, Principal Planner
City of La Quint@
September 1G, 2001
Page 13
Page 111-22
The DER stags that the County Agricultural Resources Map shows a combined
total of 28,657 acres of Prime Farmland or Farmland of Statewide Importance exist
within the planning area. This conflicts with the 19,938 total agricultural acres AA — 46
presented on Table 111-3. Why is there a discrepancy between Table 111-3 and the
discussion Section of the DEIR? How many acres of productive agricultural land
currently are in the planning area?
Page 111-23
Willia neon Act Contracts
AA-47
The DEIR fails to identify parcels currently under Williamson Act contracts. What are
the proposed land uses according to the General Plan?
Page III-24
What were the methodology and approach taken to assess agricultural impacts
resulting from buildout of the proposed General Plan? What was the threshold of
significance for evaluating the impacts on agricultural lands? The DEIR should
utilize the LESA methodology recommended by State Department of Resources.
Agricultural Land Use Impacts
lrr Table 111-9, the DEIR states that a total of 19,938 acres are in agricultural
production and recommends 17, 615 acres be designated as low -density residential
with an agricultural overlay. What will the remaining 2,323 acres of agricultural lands
be designated? How many acres of State Prime Farmland or Farmland of Statewide
Important would be designated for residential land uses? How many agricultural
acres under the Williamson Act contracts would be designated for non-agricultural
uses?
The DEIR fails to acknowledge that buildout of the proposed General Plan would
convert prime Farmland and Farmland of Statewide Importance to non-agricultural
uses, therefore, a significant impact will result,
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Fred Baker, Principal Planner
City of La Quints
September 10, 2001
Page 14
Page III-35
What are the existing average daily traffic (ADT) volumes for the proposed
annexation, sphere-of-intiuence, and the remaining planning areas? No information
is provided in the DEIR. Also, no information is provided as to the existing Level of
Service (LOS) and ADT for the areas that will be affected in the adjacent
jurisdictions (cities of Indio and Coachella). Since the adjacent jurisdictions will be
affected by General Plan traffic, existing traffic information is needed.
Page III-36
Where ere the routes for public transit services? What is the existing rider ship for
public transit service? How many trains provide passenger service? Where is the
train station in Coachella Valley, and how tar is it from the proposed planning area?
Page III-37
Are there bicycle and pedestrian facilities in La Quinta and the proposed General
Plan area? If so, where are they located? Are there any plans for bicycle and
pedestrian facilities? Are provisions made for electric golf carts? -
Page 111-38
What methodology and approach have been utilized to assess traffic and circulation
impacts resulting from General Plan buildout? What are the thresholds of
significance for determining whether traffic impacts are significant?
Page III-39
Level -of -Service on Roadway Segments
How many segments have a volume -to -capacity (WC) ratio between 0.91 and 0.99?
Where are those segments located? Are there any segments with a V!G ratio
between 0.91 and 0,99 located in the adjacent jurisdictions'
Page III-40
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AA-52
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What assumptions have been used for the traffic model? What assumptions were AA _ 56
made regarding access to network roadways and actual impacts to capacity?
Fred Baker, Principal Planner
City of La Quints
September 10, 2001
Page 15
Page III-43
intersection Analysis
Which intersections located in adjacent jurisdictions will be impacted by traffic
associated w th General Plan buiidout? Which intersections in Table ill-14 are
located in adjacent jurisdictions? The most direct lines of access from the proposed
Sphere of Influence Amendment area and the I-10 freeway or Highway 111 are via
Jefferson, Madison (along an uncompleted segment to the north), Monroe, Jackson,
Calhoun and Van Buren, It Is the City of Indio's contention that the addition of
upwards of 80,000 new dwelling units will have significant impacts upon these and
connecting roadways#intersections and will require mitigation if better alternatives
are not pursued_
Mammary of Roadway Impacts
What are the ADT volumes projected to result from buildout of the Recommended
Land Use alternative, and how will volumes affect circulation systems in adjacent
jurisdictions? Your traffic analysis must identify the roadway segments in the
adjacent jurisdictions that will likely operate with volumes exceeding their design
capacities? And mitigation of such impacts is required.
Roadway Classifications
What are the existing roadway classifications and do they differ from those
proposed? How do the proposed roadway classifications correspond to existing
roadway classifications of adjacent jurisdictions?
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Page III-58
Which mitigation measures address traffic impacts on adjacent jurisdictions? A'' — 60
Page III-72
Project Impacts
What methodology and approach were used to assess soils and geological impacts AA — 61
resulting from the proposed General Plan? What thresholds of significance were
used to determine whether impact on soils and geological are significant?
Fred Balser, Principal Planner
City of La Quinta
September 10, 2001
Page 16
Page III-74
What are the wind erosion and blcwsand impacts resulting from the construction AA — 62
activities associated with General Plan implementation?
Page III-75
What assumptions have been used to determine that no substantial amount of
development will occur within the proposed annexation and sphere -of -influence
areas in the near future?
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Page HI-84
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What methodology and approach were used to assess impacts on storm water run-
off and flooding? What thresholds of significance were used to determine whether
the proposed project would have significant impacts on hydrology? What are the — 6
storm water and flooding impacts resulting from the buildout of the proposed
AA 4
General Plan on adjacent jurisdictions (the Cities of Indio and Coachella)? What
mitigation measures will be taken to reduce storm water and flooding impacts on the
adjacent jurisdictions?
Page III-91
MEM
What methodology and approach were used to assess impacts on groundwater
resources in the Coachella Valley? What are the thresholds of significance used to AA
determine whether the proposed project would have a significant impact on
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groundwater resources? What is the basis for the assumption of a 23 percent
increase in commercial lands and a 43 percent increase for industrial lands stated
in the DEIR?
The DEIR assumes a low household size which underestimates water consumption
impacts. This is especially apparent in the impact analysis for public services and
utilities. The DE1I3 uses 2.75 persons per household to determine impact. This
number is considerably lower than the household size figures used by the California
Department of Finance (32e3 persons per household) and the Southern California AA— 66
Association of Governments (3,24 persons per household in 2005 and 3.14 persons
per household in 2020). The DEIR should be revised to reflect these updated
household size assumptions to analyze water consumption and impact ❑n
groundwater resources resulting from the buildout of the proposed General Plan.
Fred Baker, Principal Planner
City of to Quinta
September 10, 2o0it
page 17
There is no impact analysis for the increase in water consumption of commercial AA — 67
and industrial land uses resulting from buildout_
Page 111-1 t 1
What methodology and approach were used to assess impact on biological
resources resulting from the buiidout of the proposed General Plan? What
thresholds of significance establish criteria to determine whether the proposed A _ r $
project would have significant impacts en biological resources? Would the urban
development proposed by the General Plan affect biological resources in adjacent
jurisdictions?
Page III-120
Where historic resources exist within the planning area? Which historic sites are on
the State and National Registers? Are there any local historic resources? AA — t;
Page 111-121
What methodology and approach were employed to assess impact on historic
resources resulting from General Plan buildout? What are the thresholds of
significance used to determine whether the proposed project would have significant AA — 70
impacts on historic resources? Which historic resource would be affected?
Page I1L- 32
What methodology and approach were used to assess air quality impacts resulting
from the huildout? What thresholds of significance have been used to determine
whether the proposed project would have significant air quality impacts?
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Page I31-138
What assumptions and information were used to determine the average trip length? AA —
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Page IIS-139
What are the air quality impacts on adjacent jurisdictions? Are there any sensitive
land uses within the adjacent jurisdictions which will be affected by carbon
monoxide hot spots?
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Fred Baker, Principal Planner
City of La Quinta
September 10, 2001
Page la
Page 111-141
What air quality impacts on adjacent jurisdictions will result from buildout within the
proposed annexation and sphere -of -influence amendments areas?
Page 111-149
Which computerized noise model was used and what were the assumptions? What
are the thresholds of significance used to determine whether the buildout would
have a significant noise impact? Where are the sensitive receptors? Are there any AA — 75
noise -sensitive land uses in the adjacent jurisdictions which will be affected by
development?
Pace 111-151
What was the basis for the assumptions regarding train trips and aircraft
operations? What impact will the future train trips and aircraft operations have on
proposed urban development? What assumptions were made regarding noise
impacts generated from commercial and industrial development, Haw were noise
impacts assessed? Where are sensitive receptors in relationship to planned
commercial and industrial development?
Page 11I-155
What are the noise impacts on sensitive uses in adjacent jurisdictions resulting from
buildout within the proposed annexation and sphere -of -influence areas?
Page Ill-160
What methodology and approach were utilized to assess visual impacts? What
thresholds of significance were used to determine whether the General Plan would
have significant impacts on visual resources? Are there any view corridors that will
be affected by proposed development? Will scenic views from surrounding areas
be affected by the proposed urban development?
Page 1I1-162
The urban development proposed within the annexation and sphere -of -influence
areas are not consistent with the rural, agricultural and open space land uses of the
existing General Plan designations_ The DEIR needs to be revised to reflect this,
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Fred Baker, Principal Planner
City of La Quints
September 10. 2D01
Page 19
Also, the proposed urban development designations in the annexation and sphere -
of -influence areas will be in, direct contrast with the adjacent scenic rural open
spaces and will impact visual resources and view corridors.
Page 1I1-166
According to Table I-2, the number of dwelling units resulting from buildout is 78,952
units, not the 66,811 units reported here. The school enrollment analysis should be
revised. The breakdown between single family and multi -family is different than the
one used in the air quality analysis (Table 111-24). Mat is the proposed capacity of
the Mountain Vista Elementary School and how will it ease the elementary student
overcrowding which will result from the buildout of the proposed General Plan? The
average persons per household size is increasing_ How will this affect the
methodology and approach (student generation rates) taken to assess school
enrollment impacts resulting from the buildout? What thresholds of significance are
used to determine whether buildout would have significant impacts on school
facilities? What are the specific student enrollment impacts on the Desert Sands
Unified School District? On the Coachella Valley Unified School District?
Page 111-170
The DER uses a low household size figure and therefore underestimates impact
on library facilities_ The DEIR uses 2,75 persons per household to determine the
impacts. This number is considerably lower than the household size figures used
by the California Department of Finance (3,263 persons per household) and the
Southern California Association of Governments (3.24 persons per household in
2005 and 3.14 persons per household in 2020). The DEIR should be revised to
reflect a current household size figure in analyzing public services. Also, what
methodology and approach were used to evaluate impact on library services and
facilities? What are the thresholds of significance used to determine whether the
project would have significant impacts on libraries?
Page III-172
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The DEIR sfiauld be revised to reflect a current household size figure to analyze
impact on police protection services. Also, what methodology and approach are
used to assess impacts on police protection services resulting from the buildout of
the proposed General Plan? What are the thresholds of significance used to
determine whether there would be significant impact on police protection services?
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Fred Baker, Principal Planner
City of La Quints
September 10, 2OOt
Page 20
Page Ill-174
What methodology and approach were used to assess impact on fire protection
services? What are the thresholds of significance used to determine whether there
were significant impacts? Which fire agency currently serves the amendment and AA - 83
sphere -of -influence areas? Are fire stations planned for the proposed General Plan
area? If so, where?
Page III-1 7 5
What methodology and approach were used to assess impacts on health care
facilities and services? What thresholds of significance were used to determine
whether there would be significant impacts? Are any public health facilities planned
to meet the increased population?
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Page !II-177
Where are existing solid waste facilities in relation to the proposed annexation and
sphere -of -influence amendment areas, and what are the landfill capacities and
closure dates? How much solid waste is currently generated? How much solid
waste will be generated in the future? What methodology and approach were used
to assess solid waste impacts? What thresholds of significance were used to AA - 85
determine whether there would be significant impacts? It is unrealistic to assume
that the buildout pursuant to the proposed General Plan (19,137,51 square feet of
commercial and 28,835,849 square feet of industrial) will not result in any
hazardous waste generation_
Page lil-181
What is the service area for the existing sewage treatment plant? How much
wastewater will be generated within the project area? What methodology and
approach were used to assess wastewater impacts? What thresholds of
significance were used to determine whether significant impacts would result?
Page 11I-1 B3
The DER uses a low household size to estimate water usage and therefore
underestimates the impacts on domestic water service. (See prior discussion;). The
DEIR should be revised to reflect an updated average household size to analyze
impacts on domestic water services, What methodology and approach were used
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Fred Baker. Principal Planner
City of La Quints
September 14, 200t
Page 21
to assess domestic water service impacts? What thresholds of significance were
used to determine whether significant impacts result? VVhat impacts occur due to
development in the proposed annexation and sphere -of -influence amendment
areas?
Page 11I-186
What methodology and approach were utilized to assess electrical service impacts?
What thresholds of significance were used to determine whether significant impacts
wilt result?
Page II!-189
What methodology and approach are taken to assess natural gas service impacts
resulting from the buildout of the proposed General Plan? What are the thresholds
of significance used to determine whether there were significant impacts resulting
from the buildout of the Proposed General Plan on natural gas services? What are
the impacts from the proposed annexation and sphere -of -influence amendment?
What impact will this have on the adjacent jurisdictions?
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Page 11I-19O
What methodology and approach were used to assess cable service impacts?
What thresholds of significance were used to determine whether significant impacts AA - 90
will result?
Page III-198
The DEIR uses a low household size assumption to assess public service impacts
(see previous discussion) and therefore underestimates impact. The DEIR should AA - 91
be revised to reflect an updated household size assumption to analyze impacts on
public services.
Page IV-1
Is the loss of 26,312 acres of Prime Farmland considered an unavoidable significant AA -
impact?
Fred Baker, Frincipal Planner
City of La Quinta
September 10, 2001
Page 22
Page V-1
The "More Intense" Alternative should not be considered in the DEER since this
alternative does not comply with CEQA regulations by reducing or eliminating
environmental impacts. With the "More Intense" Alternative eliminated from
consideration, the DER does not present an adequate range of reasonable
alternatives to meet CEQA requirements_
Page V-13
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What impacts to existing agricultural resources result from a "No Project"
Alternative? What are the impacts of the No Project" Alternative on land use within AA - 94
the adjacent jurisdictions?
Page V-14
Under CEQA regulations, Alternative 1: More Intense Development should not be
considered as an alternative in the DEIR because it does not reduce or eliminate
any significant environmental impacts. Linder Alternative II: Less Intensive
Development Scenario, what are the impacts to existing agricultural resources?
How many acres of Prime Farmland would be converted to urban land uses? How
does the Less Intense Alternative impact land use in adjacent jurisdictions? How
would the land use impacts associated with the project differ from No Project and
Less Intense Development Alternatives? How would land use impacts on adjacent
jurisdictions differ between the No Project and Less Intense Development
alternatives?
Page V-16
What traffic impacts in adjacent jurisdictions (circulation and intersections) result
from the No Project Alternative?
Page V-1 7
Under Alternative It: Less Intensive Development Scenario (Table V-4), the traffic
impacts are greater than the proposed project_ How does the Less intense
Alternative impact circulation and intersections in adjacent jurisdictions? How would
traffic impacts differ from No Project and Less Intense Development Alternatives?
How would traffic and circulation impacts on adjacent jurisdictions differ among the
alternatives?
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Fred Baker, Principal Planner
City of L Quint
September 10, 2001
Page 23
Page V-15
The DEIR does not provide adequate information to compare the relative impacts
with respect to soils and geology. How would project differ from the No Project and
Less Intense Development Alternatives?
Page V--19
The DEIR does not provide adequate information to compare the relative impacts
on hydrological systems among the alternatives. Haw do the No Project and Less
Intense Development Alternatives affect flooding in adjacent jurisdictions?
Page V-20
The DEIR does not provide the quantitative information necessary to analyze
potentiate water quality and resources impacts for the alternatives. What
assumptions were used for the population projections? Will groundwater overdraft
or water quality impacts result from the No Project and Less Intense Development
Alternatives? How do impacts of the project compare to the No Project and Less
Intense Development Alternatives both within the project area and regionally? ?
Page V-22
The DEIR does not provide sufficient information to enable comparison of the
potential biological resource impacts among the alternatives. Wald the No Project
and Less Intense Development Alternatives impact biological resources in adjacent
jurisdictions? Flow do impacts associated with the project compare to the No Project
and Less Intense Development Alternatives both locally aid regionally?
Page V-23
The DEIR provides no information to enable comparison of potential cultural
resources impacts among the alternatives. Will the No Project and Less intense
Development Alternatives impact cultural resources in the adjacent jurisdictions?
How do the air quality impacts of the project compare to impact from No Project and
Less Intense Developrhent Alternatives both locally and regionally?
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Fret Baker, Principal Flannel -
City of La Quhta
September 10, 20Dl
Page 24
Page V-23
How might the No Project and Less Intense Development Alternatives affect air
quality in the adjacent jurisdictions? How do project air quality compare to impacts AA _ 103
front the No Project and Less intense Development Alternatives both locally and
regionally?
Page V-25
How might traffic noise associated with the No Project and Less Intense
Development Alternatives impact adjacent jurisdictions? How do noise impacts AA - 104
compare between the alternatives?
Page V-27
Mal are the regional visual resource impacts associated with the No Project and
Less Intense Development Alternatives? How do visual impacts compare between AA - 105
the alternatives?
Page V-29
The DEIR underestimates the public services and utilities impacts because the
analysis utilizes a low average household size of 2.75 persons per household. As
discussed above, the California Department of Finance and SCAG project a larger
average household size, at least 3.2 and above. The public services impacts of the
alternatives should be re -analyzed using this updated household size_ 1-iow would
the public service impacts differ from the No Project and Less intense Development
Alternatives both locally and regionally?
Page VI1-1
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Prime Farmland is considered a non-renewable environmental resource_ The ❑EIR
should state that Prime Farmland will be permanently lost due to implementation of AA - 107
the proposed General Plan,
Page 11I!I-i
How do the growth -inducing impacts of the proposed General Plan impact adjacent 1 AA - 108
jurisdictions' agricultural resources?
Fred Baker, Principal Planner
City of La Quwnta
September 10, 21)011
Page 25
Page VIII-2
The DEIR underestimates the cumulative impacts by using a figure of 2.75 persons
per household (see discussion above). The DEIR lacks consistent application of the
cumulative impact analysis, especially as it pertains to the proposed annexation and
sphere -of -influence amendment, Buildout of the proposed General Plan, together
with development within the proposed annexation and sphere -of -influence areas,
would have a significant cumulative impact on the adjacent jurisdictions.
In conclusion, the environmental analysis contained in the DEIR exhibits significant
flaws, The analysis substantially underestimates the type and severity of significant
impacts associated with the buildout of the proposed General Plan and within the
annexation, and sphere -of -influence amendment areas. Because of
inconsistencies in the document and the underestimation of impacts, the DEIR
requires substantial reworking to comply with CEQA and also requires recirculation.
In particular, a thorough analysis of impacts on the cities of Indio and Coachella
associated with the proposed annexation and the sphere -of -influence amendment
are critical -
Sinter ly r
yoursern yours,
Gar j l-
Developm ervic r es Director
cc: City Manager
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