HomeMy WebLinkAboutDSRT SURF Final EIR FEIRFinal
Environmental Impact Report
(SCH No. 2019011044)
For The
DSRT SURF SPECIFIC PLAN
PREPARED FOR
CITY OF PALM DESERT
73-510 Fred Waring Drive
Palm Desert, CA 92260
PREPARED BY
J TERRA NOVA PLANNING & RESEARCH, INC.`
42635 Melanie Place, Suite 101
Palm Desert, CA 92211
October 2019
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
TABLE OF CONTENTS
Page
1.0 INTRODUCTION .................................................................................................................. 1
1.1 Introduction ............................................................................................................ 1
1.2 Organization of the Final EIR .................................................................................. 1
1.3 Draft EIR Public Review Period ............................................................................... 2
1.4 Certification of the Environmental Impact Report and Project Selection Process . 2
1.5 Consideration of Recirculation ............................................................................... 2
2.0 RESPONSE TO COMMENTS ................................................................................................. 4
2.1 Introduction ............................................................................................................ 4
2.2 Response to Comments .......................................................................................... 5
A. Governor’s Office of Planning & Research, State Clearinghouse ............... 5
B. Riverside County Airport Land Use Commission (ALUC) ............................ 6
C. California Department of Fish and Wildlife ................................................ 7
D. South Coast Air Quality Management District ......................................... 15
E. Law Offices of John Belcher ..................................................................... 24
F. Liridona Leti ............................................................................................. 35
3.0 CHANGES TO THE EIR ....................................................................................................... 36
APPENDICES
Appendix A Comment Letters
Appendix B Revised CalEEMod Outputs
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EIR (SCH # 2019011044)
Final EIR/Response to Comments
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1.0 INTRODUCTION
1.1 Introduction
This Final Environmental Impact Report (EIR) has been prepared in accordance with the California
Environmental Quality Act (Public Resources Code §§21000-21189.3) and the State CEQA
Guidelines (California Code of Regulations, Title 14, Chapter 3, §§15000-15387).
The Final EIR includes the Draft EIR, written comments received during the public comment
period, responses to those comments, and changes or errata to the Draft EIR. The City of Palm
Desert (City) prepared this EIR to evaluate the potential environmental impacts associated with
the construction and operation of the proposed DSRT SURF project. The City is the Lead Agency
for the Project.
According to State CEQA Guidelines §15089, the requirements for a Final Environmental Impact
Report are:
a) The Lead Agency shall prepare a final EIR before approving the project. The contents of a
final EIR are specified in Section 15132 of these Guidelines.
b) Lead Agencies may provide an opportunity for review of the final EIR by the public or by
commenting agencies before approving the project. The review of a final EIR should focus
on the responses to comments on the draft EIR.
1.2 Organization of the Final EIR
As directed by CEQA Guidelines §15132, the Final EIR consists of three sections:
Section 1 – Introduction. This Section provides an introduction and summarizes the CEQA
requirements for preparation of responses to substantive public comments on the Draft EIR.
Section 2 – Response to Comments. This Section includes comments received during the public
comment period and the City’s response to each comment. Where the same question or concern
has been raised by multiple commenters, the first instance when the comment was addressed is
referenced in the response.
Section 3 – Changes to the Draft EIR. Changes to the EIR’s text resulting from comments and
their responses are provided in this section.
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1.3 Draft EIR Public Review Period
The Draft EIR was released for public comment on May 21, 2019. The document was sent to the
California State Clearinghouse, public agencies, and individuals who had expressed an interest or
requested to receive the Draft EIR. In addition, a Notice of Completion/Notice of Availability was
published in the Desert Sun. The Notice of Completion/Notice of Availability was also sent to the
Riverside County Clerk. Copies of the Draft EIR were also made available at Palm Desert City Hall,
on-line at the City’s website, and at the City’s library.
The public comment period ended on July 5, 2019. During the public review period, the City
received a total of 6 comments in the form of letters and emails.
1.4 Certification of the Environmental Impact Report and Project Selection Process
The City of Palm Desert City Council will consider the EIR at a meeting on November 14, 2019. In
order to certify the Final EIR, CEQA Guidelines §15090 prescribe that the City Council must find
that:
a) The Final EIR has been completed in compliance with CEQA;
b) The Final EIR was presented to the decision-making body and that the decision-making
body reviewed and considered the information contained in the Final EIR; and
c) The Final EIR reflects the Lead Agency’s independent judgment and analysis.
If the City Council certifies the Final EIR, it can then consider approving the project, in whole or
in part.
1.5 Consideration of Recirculation
CEQA Guidelines §15088.5 requires a Lead Agency to recirculate a revised EIR only if significant
new information is identified following the release of the Draft EIR. “Significant new information”
can include, changes in the project or environmental setting as well as additional data or other
information, for example, a new significant environmental impact or a substantial increase in the
severity of an environmental impact. New information is not considered significant unless the EIR
is changed in a way that deprives the public of a meaningful opportunity to comment upon a
substantial adverse environmental effect of the project or a feasible way to mitigate or avoid
such an effect that the proponent has declined to implement.
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The City has evaluated the information contained in this Final EIR as well as all other information
in the record, and has determined that no significant new information has been added to the EIR
after public notice was given of the availability of the Draft EIR for public review. Therefore, CEQA
does not require recirculation of the Draft EIR.
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2.0 RESPONSE TO COMMENTS
2.1 Introduction
The Response to Comments on the Draft EIR for the Project has been prepared in accordance
with CEQA Guidelines Sections 15088, 15089 and 15132. This Section of the Final EIR contains
reproductions of all comments received during the public comment period.
The following comments were received on the Draft EIR from various public agencies and
interested parties. These comments address aspects of the Project or Draft EIR, including
clarification of information, comments upon the adequacy of environmental analysis, and similar
issues. The complete letter or email is included Appendix A. If the letter or email included
attachments, these are provided as well. Each letter or email has been provided brackets
identifying each specific comment for which a response is provided and a corresponding
comment identification number. Following each comment is a specific response that matches the
comment number.
A list of all comments received is provided in Table 2-1. Individual comments and the City’s
responses follow.
Table 2-1
Master List of Comments Received
Assigned
Letter
Commenter Name
Agency / Affiliation / City of Residence
A State of California
Governor’s Office of Planning and
Research
State Clearinghouse and Planning Unit
B Paul Rull Riverside County Airport Land Use
Commission
C Heather Pert for Scott Wilson California Department of Fish and
Wildlife
D Lijin Sun, J.D.
South Coast Air Quality Management
District
E John Belcher Law Offices of John Belcher
F Liridona Leti Palm Desert resident
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2.2 Response to Comments
A. Governor’s Office of Planning & Research, State Clearinghouse
Comment A-1 The State Clearinghouse submitted the above named EIR to selected state
agencies for review. The review period closed on 7/5/2019, and the comments
from the responding agency (ies) is (are) available on the CEQA database for
your retrieval and use. If this comment package is not in order, please notify
the State Clearinghouse immediately. Please refer to the project’s ten-digit
State Clearinghouse number in future correspondence so that we may
respond promptly.
Please note that Section 21104(c) of the California Public Resources Code
states that:
“A responsible or other public agency shall only make substantive comments
regarding those activities involved in a project which are within an area of
expertise of the agency or which are required to be carried out or approved
by the agency. Those comments shall be supported by specific
documentation.”
Check the CEQA database for submitted comments for use in preparing your
final environmental document: https://ceqanet.opr.ca.gov/2019 011044/2.
Should you need more information or clarification of the comments, we
recommend that you contact the commenting agency directly.
This letter acknowledges that you have complied with the State Clearinghouse
review requirements for draft environmental documents, pursuant to the
California Environmental Quality Act. Please contact the State Clearinghouse
at (916) 445-0613 if you have any questions regarding the environmental
review process.
Response A-1 The City thanks the State Clearinghouse for assisting it in complying with
CEQA. The City has checked the Clearinghouse database, and found that one
comment letter was submitted, from the California Department of Fish and
Wildlife. That letter is responded to below, as Comment Letter C.
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B. Riverside County Airport Land Use Commission (ALUC)
Comment B-1 Thank you for transmitting the above project to ALUC for review. Please note
that the project is located outside the airport influence area, and therefore
ALUC has no official comment on the project.
Response B-1 The City thanks ALUC for participating in the review of the EIR, and
acknowledges that the project is located outside the airport influence area of
the Bermuda Dunes Airport.
Comment B-2 However, I wanted to let you know that ALUC is currently reviewing a similar
“surf lagoon” project (ZAP1046TH19) in the unincorporated County area of
Jacqueline Cochran Airport that is tentatively scheduled for a public hearing
meeting on June 13, 2019. The staff report for this project can be viewed on
the ALUC website here http://www.rcaluc.org/Agendas/Meeting-Agendas
about 1-2 weeks before the meeting. In the report, ALUC staff analyzes a
biological wildlife hazard study for the potential impact of the “surf lagoon” on
aircraft via bird strikes. The study proposes several mitigations (sic) measures
to help minimize the occurrences of aircraft bird strikes.
The City may find this information useful when considering the DSRT Surf
project.
Response B-2 The City thanks ALUC for providing the information relating to the project
located to the Jacqueline Cochran Airport in Thermal. However, because the
proposed Project is not within an area of low-flying aircraft, bird strikes are
not anticipated to be an impact of the proposed Project.
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C. California Department of Fish and Wildlife
Comment C-1 The California Department of Fish and Wildlife (CDFW) received a Notice of
Availability of a DEIR from the City of Palm Desert for the DSRT SURF Specific
Plan, Precise Plan, Tentative Tract Map 37369 and Associated Disposition and
Development Agreement (SP 18-0002 and PP18-0009) Project (Project)
pursuant the California Environmental Quality Act (CEQA) and CEQA
Guidelines.
Thank you for the opportunity to provide comments and recommendations
regarding those activities involved in the Project that may affect California fish
and wildlife. Likewise, we appreciate the opportunity to provide comments
regarding those aspects of the Project that CDFW, by law, may be required to
carry out or approve through the exercise of its own regulatory authority
under the Fish and Game Code.
Response C-1 The City thanks the Department for participating in the review of the EIR, and
acknowledges its role in providing comments germane to the Fish and Game
Code.
Comment C-2 CDFW ROLE
CDFW is California's Trustee Agency for fish and wildlife resources , and holds
those resources in trust by statute for all the people of the State. (Fish & G.
Code, §§ 711.7, subd. (a) & 1802; Pub. Resources Code , § 21070; CEQA
Guidelines§ 15386, subd. (a).) CDFW, in its trustee capacity, has jurisdiction
over the conservation, protection, and management of fish, wildlife, native
plants, and habitat necessary for biologically sustainable populations of
those species. (Id., § 1802.) Similarly for purposes of CEQA , CDFW is charged
by law to provide, as available, biological expertise during public agency
environmental review efforts, focusing specifically on projects and related
activities that have the potential to adversely affect fish and wildlife
resources.
CDFW is also submitting comments as a Responsible Agency under CEQA.
(Pub. Resources Code, § 21069; CEQA Guidelines,§ 15381.) CDFW expects that
it may need to exercise regulatory authority as provided by the Fish and Game
Code. As proposed, for example, the Project may be subject to CDFW's lake
and streambed alteration regulatory authority. (Fish & G. Code, § 1600 et seq.)
Likewise, to the extent implementation of the Project as proposed may result
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in "take" as defined by State law of any species protected under the California
Endangered Species Act (CESA) (Fish & G. Code,§ 2050 et seq.), the project
proponent may seek related take authorization as provided by the Fish and
Game Code.
Response C-2 The City acknowledges the Department’s role as both a Trustee and
Responsible Agency, and recognizes its role in the CEQA process.
Comment C-3 The CDFW has jurisdiction over the conservation, protection, and
management of fish, wildlife, native plants, and the habitat necessary for
biologically sustainable populations of those species (i.e., biological
resources); and administers the Natural Community Conservation Planning
Program (NCCP Program). The CDFW offers the comments and
recommendations presented below to assist the City of Palm Desert (City; the
CEQA lead agency) in adequately identifying and/or mitigating the project's
significant, or potentially significant, impacts on biological resources. The
comments and recommendations are also offered to enable the CDFW to
adequately review and comment on the proposed project with respect to
impacts on biological resources and the project's consistency with the Coachella
Valley Multiple Species Habitat Conservation Plan (CVMSHCP).
The CDFW's comments and recommendations on the DEIR include:
Project Description
The Project Description on pp. 1-2 through 1-6 of the DEIR lacks a description
of the timing of operation of the wave machines. Artificial water bodies in
desert climates often act as attractants to waterfowl (e.g., Canada geese). If
the surf lagoon wave machines are idle for extended periods, waterfowl may
establish residence at the surf lagoon, thereby creating a potential human-
wildlife conflict between waterfowl and surf lagoon customers. CDFW
recommends that the Project Description be revised to include a description
of the frequency, timing, and duration of the wave generating equipment
operation.
Response C-3 The hours of operations of the wave machine are provided on page 1-6, as the
first row of the “Surf Lagoon Operational Details.” In that sub-section, the
hours are stated as 6 AM to 12 AM for wave machine/surf pool operations.
Therefore, the surf pool will be inactive for a period of 6 hours every night
(from midnight to 6 AM). It is therefore unlikely, given that most waterfowl
are diurnal, rather than nocturnal, that they would establish residency on the
pool on any given night. Further, when the wave machine is operational,
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surfers will also be in the water. Much like the experience of surfing on the
Pacific Ocean, waterfowl tend to avoid human contact, and their extended
presence on the lagoon is unlikely. The Department’s recommendation to add
operation data is noted, but no change is required since the information is
already provided in the Draft EIR.
Comment C-4 Though not identified in the Project Description, CDFW assumes that the water
in the surf lagoon will be chlorinated. This information should be clarified,
given that mosquito abatement may be necessary if the water is not treated
and is proposed to remain undisturbed for extended periods of time (for
example, when the wave machines are idle). CDFW recommends that the
Project Description clearly identify any proposed mosquito abatement
activities, or describe why such activities will be unnecessary.
Response C-4 Please see Response C-3 as it relates to operation of the surf lagoon. The surf
lagoon will be treated to meet County standards for such facilities, and as
noted above, the wave machine will be inactive for up to 6 hours per night.
Further, when the wave machine is inactive, filtration will continue, and much
like a swimming pool, standing water will not occur. As a result, there will be
no need for mosquito abatement activities.
Comment C-5 Environmental Setting, Impacts, and Mitigation, Biological Resources Section,
Subsection 2.4.6 (Project Impacts) and 2.4.7 (Mitigation Measures)
Subsection 2.4.6 (Impacts) on pp. 2.4-19 through 2.4-21 of the DEIR lacks a
description of the possibility of waterfowl establishing residence at the surf
lagoon during Project operation when wave machines are idle for extended
periods of time. CDFW recommends that a Contingency Plan be developed and
included as a Mitigation Measure in Subsection 2.4.7 to minimize human-
wildlife conflicts if waterfowl are attracted to the surf lagoon.
Response C-5 Please see Response C-3. The wave motion and human activity on the surf
lagoon will prevent waterfowl from establishing residence on the lagoon, and
there is no need for a “contingency plan” to minimize human-wildlife conflicts.
For clarity, the following addition will be made to page 2.4.20:
“Tables 2.4.1 through 2.4.3 summarize information on all special-status
species that have been reported in the Project vicinity, or that have the
potential to occur onsite based on geographic distribution and presence of
potentially suitable habitat. Given the level of existing disturbance onsite from
parking lot development, grading, installation of irrigation systems,
development of surrounding parcels, and daily disturbances of human activity
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on the adjacent Desert Willow Golf Resort, there is a low potential for the
proposed Project to adversely impact sensitive biological species.
Furthermore, the Surf Lagoon component of the Project will operate daily
from 6 AM to 12 AM, resulting in constant motion on the surf lagoon. This
water activity, combined with the human activity associated with surfers, will
prevent water fowl from taking up residence in the Surf Lagoon.”
Comment C-6 Environmental Setting, Impacts, and Mitigation, Hydrology and Water Quality
Section, Subsection 2.10.5 (Existing Conditions)
It is stated on p. 2.10-8 of the DEIR that "If required, the surf lagoon water will
be treated before being sent to the evacuation line." The evacuation line
carries discharge to the existing golf course lake. CDFW was unable to locate a
definition for "treated" within the DEIR. Given that the water will be
discharged to a lake accessible by wildlife, CDFW recommends that a definition
of "treated" be included in the DEIR to provide public review and comment for
any potential impacts to fish and wildlife resources. CDFW recommends that
the definition clearly identify how the water may be treated, what would
trigger treatment, and the chemical constituents proposed to be used, if
chemical treatment is deemed necessary.
Response C-6 The use of the term “treated” in the DEIR does not include chemical treatment.
Water treatment throughout the Project, as described on pages 2.10-13
through 2.10-18, will be required to comply with Regional Water Quality
Control Board, City and County requirements, including the City’s NPDES
permit. A system of holding tanks and drywells, as well as Best Management
Practices provided in the Project’s WQMP and SWPPP, will assure that all
water discharged within the Project, whether into the ground for percolation
or into the existing golf course lakes, meets all water quality requirements.
Through the implementation of these requirements of law, water released to
the golf course lakes will meet or exceed water quality requirements.
Comment C-7 Environmental Setting, Impacts, and Mitigation, Hydrology and Water Quality
Section, Subsection 2.10.6 (Project Impacts)
Subsection 2.10.6 states on pp. 2.10-18 and 2.10-19 of the DEIR states (sic):
"The Project will provide water for the lagoon in one of three ways:
installation of a new groundwater well at the southeastern corner of the
site; connection to the existing Desert Willow groundwater well located
south of the site near Country Club Drive; or utilization of the potable water
from CVWD."
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Table 2.10-1 (Total Project Water Demand) identifies that the total Project
water demand would be 165.21 acre-feet per year (AFY). However, water
savings from a turf reduction program at the golf course are projected to be
106.75 AFY. The net total water demand after accounting for the water savings
associated with turf reduction will be 58.46 AFY. CDFW recommends that no
new groundwater extractions be implemented, either through a new well or
increased extractions from an existing well. The Coachella Valley has been in
groundwater overdraft for many years and although groundwater levels have
been improving in some areas (due to ongoing groundwater replenishment
activities), the groundwater basin is still, nonetheless in overdraft. Page 42 of
Appendix I to the DEIR (Water Supply Assessment and Water Supply
Verification for the DSRT SURF Project) states:
"The effectiveness of the Groundwater Replenishment Program has been
demonstrated by rising water levels in the Palm Springs area and by
slowing water level declines in the mid-Coachella Valley portion of
Whitewater River (Indio) Subbasin. According to the 2016 CVWMP
[Coachella Valley Water Management Plan] Status Report, it is anticipated
that long-term groundwater overdraft will be eliminated by 2022 in the
Coachella Valley with increased groundwater levels in the Palm Springs
area and the eastern Coachella valley...However, groundwater levels in the
mid-Coachella Valley area will continue to decline until programs are
implemented in this area to reduce groundwater pumping."
The Project site is located in the middle section of the Coachella Valley.
Although, projections indicate that groundwater overdraft may be eliminated
in the groundwater subbasin as a whole by 2022, it is identified by the Water
Supply Assessment that groundwater declines are still occurring in the mid-
valley area.
Response C-7 The CVWD approved the Water Supply Assessment (WSA) for the proposed
Project on May 14, 2019. The WSA correctly found that the CVWD has
sufficient supplies to serve the proposed Project, based on its current demand,
the demand expected from future growth, and its current and future supplies
in normal, single dry and multiple dry years.
The commenter deleted from the second citation an important factor; the
correct citation states:
“According to the 2016 CVWMP Status Report, it is anticipated that long-
term groundwater overdraft will be eliminated by 2022 in the Coachella
Valley with increased groundwater levels in the Palm Springs area and the
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eastern Coachella Valley, which exceeds the goal set by the CVWMP to
eliminate overdraft by 2030. However, groundwater levels in the mid-
Coachella Valley area will continue to decline until programs are
implemented in this area to reduce groundwater pumping." (emphasis
added)
As noted in the complete text, the CVWD continues to work toward
eliminating overdraft. A full description of the CVWD’s water supply and status
as regards overdraft is provided on pages 16 through 24 of the Water Supply
Assessment, Appendix I of the DEIR. As described therein, CVWD regularly
updates the status of the groundwater basin in its annual Engineer’s Reports.
Further, the CVWD has adopted the Coachella Valley Water Management Plan
(CVWMP), which details recharge and source substitution methods being
implemented by CVWD and the Desert Water Agency. These methods include
programs to increase recycled water supply to golf course and recharge
activities in the central portion of the Basin. As stated in the EIR (and quoted
above) the CVWD has implemented plans that will eliminate overdraft
throughout the basin by 2022.
Comment C-8 Given that the Coachella Valley is in groundwater overdraft, and the Project
site is located in an area where groundwater levels are still declining and/or
have been declining in the recent past, CDFW is concerned that if the Project
chooses not to use potable water (i.e., water is instead sourced via the
installation of a new groundwater well at the southeastern corner of the site,
or connection to the existing Desert Willow groundwater well located south of
the site near Country Club Drive) reliance on groundwater for this Project
would have impacts to biological resources not identified or analyzed in this
DEIR. If the Lead Agency wishes to pursue the use of groundwater for this
Project CDFW recommends that additional analyses be completed and
presented in a revised and recirculated EIR for public review and comment. As
currently prepared the DEIR lacks sufficient information on the potential
impacts of additional groundwater extraction at this location.
Response C-8 Please see Response C-7. Most importantly, as described in both the DEIR
(page 2.10-9) and the WSA for the Project, CVWD’s domestic water supply is
groundwater from the Whitewater River Groundwater Basin. Therefore,
whether the Project utilizes the domestic water pipes located in Desert Willow
Drive, the existing golf course well, or a new well on the Project site, the source
of water will be the same – groundwater from the Whitewater River Subbasin.
The Project will utilize tertiary treated water, currently available at Desert
Willow Drive, for irrigation of landscaped areas. As described in the DEIR, Table
2.10-1, the Project will generate demand for 165.21 acre feet per year (AFY).
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The Project’s implementation of a comprehensive turf reduction program on
both courses at Desert Willow will result in a reduction in water use of 106.75
AFY in the area immediately surrounding the Project. As a result, the Project’s
net water demand will be 58.46 AFY. Given that the water demand for the
hotels alone is 60.99 AFY, the net water demand will be less than that required
for the two hotels. This represents significant water demand reduction by
design, and results in less than significant impacts on water demand from the
proposed Project.
The commenter provides no evidence that reliance on groundwater would
impact biological resources not identified or analyzed in the EIR. The site does
not contain any natural spring or riparian habitat. There are no wetlands or
other potential ground-water-based environments on or adjacent to the
Project site (DEIR Appendix C, page 26). The lakes in the Desert Willow Golf
Course are all engineered, man-made bodies of water that store groundwater
extracted for irrigation and storm water generated on and around the Desert
Willow project. The DEIR correctly analyzed all the biological resources on the
site, and determined that with the implementation of mitigation measures
related to migratory birds and burrowing owl, the Project’s impacts on
biological resources would be less than significant.
Comment C-9 ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports
and negative declarations be incorporated into a database which may be used
to make subsequent or supplemental environmental determinations. (Pub.
Resources Code , § 21003, subd. (e).) Accordingly, please report any special
status species and natural communities detected during Project surveys to the
California Natural Diversity Database (CNDDB) . The CNNDB field survey form
can be found at the following link: http://www.dfg.ca.gov/ biogeodata/cnddb/
pdfs/CNDDB_FieldSurveyForm.pdf. The completed form can be mailed
electronically to CNDDB at the following email address: CNDDB@
wildlife.ca.gov. The types of information reported to CNDDB can be found at
the following link: http://www.dfg.ca.gov/biogeodata/ cnddb/plants_and_
animals.asp.
Response C-9 Comment noted. As stated in the DEIR, page 2.4-20, no sensitive plant or
wildlife species were identified on the Project site. Burrowing owl habitat is
present on the Project site, but no sign of occupancy or individual was
identified during the biological resources survey. The DEIR requires pre-
construction surveys for the species, along with MBTA surveys. Should any
sensitive species be identified in those surveys, the Project biologist will
comply with the requirements of law.
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Comment C-10 FILING FEES
The Project, as proposed, would have an impact on fish and/or wildlife, and
assessment of filing fees is necessary. Fees are payable upon filing of the
Notice of Determination by the Lead Agency and serve to help defray the cost
of environmental review by CDFW. Payment of the fee is required in order
for the underlying project approval to be operative, vested, and final. (Cal.
Code Regs , tit. 14, § 753.5; Fish & G. Code , § 711.4; Pub. Resources Code, §
21089.)
Response C-10 Comment noted. The City will pay the appropriate filing fees when the Notice
of Determination is filed with the County of Riverside.
Comment C-11 CONCLUSION
CDFW appreciates the opportunity to comment on the DEIR to assist the City
in identifying and mitigating Project impacts on biological resources and we
request that the City address the Department's comments and concerns prior
to adoption of the DEIR. In particular we request clarification regarding the
ultimate water source to be used for this project. If you should have any
questions pertaining to the comments provided in this letter, please contact
Charles Land (760) 200-9418 or at Charles.Land@wildlife.ca.gov.
Response C-11 The City thanks the Department for its participation in the CEQA process. The
Department’s questions regarding water supply have been addressed in the
comments above. The City will transmit the Final EIR/Response to Comments
to the Department and all other commenters as required by law prior to the
City Council’s consideration of the EIR.
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D. South Coast Air Quality Management District
Comment D-1 South Coast Air Quality Management District (South Coast AQMD) staff
appreciates the opportunity to comment on the above-mentioned document.
The following comments are meant as guidance for the Lead Agency and
should be incorporated into the Final EIR.
Response D-1 The City thanks South Coast AQMD for participating in the review of the EIR,
and for providing comments and guidance relevant to air quality standards
and regulations.
Comment D-2 South Coast AQMD Staff’s Summary of Project Description
The Lead Agency is proposing the construction of a six-acre surf lagoon, 45,000
square feet of retail uses, 11,250 square feet of restaurant uses, 350 hotel
rooms, and 88 residential units on 17.69 acres (Proposed Project). The
Proposed Project is located on the northeast comer of Country Club Drive and
Portola Avenue. Construction of the Proposed Project is expected to occur in
two phases over two years, reaching full buildout in 2021. Phase One of the
construction includes the surf lagoon, retail uses, and restaurant facilities.
Phase Two of the construction includes the hotel rooms and residential units.
South Coast AQMD Staff’s Summary of Air Quality Analysis
In the Air Quality Analysis section, the Lead Agency quantified the Proposed
Project's construction and operational emissions and compared those
emissions to South Coast AQMD's recommended regional and localized air
quality CEQA significance thresholds. Based on the analysis, the Lead Agency
found that the Proposed Project's construction activities would result in 99.73
pounds per day (lbs/day) of NOx emissions, which is slightly below South Coast
AQMD's air quality CEQA significance threshold of 100 lbs/day for NOx, after
the implementation of Mitigation Measure (MM) AQ-9. MM AQ-9 requires the
preparation of a dust control management plan. Additionally, the Lead Agency
found that the Proposed Project's operational air quality impacts would be
significant and unavoidable for NOx at 116 lbs/day during regular operation
and 152 lbs/day during a special event, after the implementation of MM AQ-1
through MM AQ-8. MM AQ-1 through MM AQ-8 require five percent of vehicle
parking spaces to include electric vehicle (EV) charging stations, a five-minute
idling restriction, energy efficient appliances, street sweepers, and
landscaping, light colored roofing, and an employee commute reduction
program.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
16
Response D-2 Comment noted. South Coast AQMD has provided an accurate summary the
Project Description and the Air Quality Analysis.
Comment D-3 South Coast AQMD Staff’s General Comments
South Coast AQMD staff has comments on the Air Quality Analysis and the
proposed mitigation measures. South Coast AQMD staff found that the haul
routes identified in the Draft EIR, which were used to calculate emissions from
haul truck trips during construction, appeared to be shorter than the distance
found in aerial imagery. To further incentivize the use of EVs by patrons visiting
the Proposed Project and to further reduce operational NOx emissions during
regular operation and special events, South Coast AQMD staff recommends
that the Lead Agency include six percent of vehicle parking spaces to include
EV charging stations instead of five percent and designate eight percent of
vehicle parking spaces for clean air vehicles in the Final EIR. Please see the
attachment for more information.
Response D-3 South Coast AQMD staff provided an Attachment to their comment letter that
includes additional information regarding the above construction haul trips
and EV comments. The Attachment comment regarding haul trips is labeled
Comment D-5, and is fully addressed in Response D-5. The Attachment
comment regarding EVs is labeled Comment D-6, and is fully addressed in
Response D-6.
Comment D-4 Conclusion
Pursuant to California Public Resources Code Section 21092.S(a) and CEQA
Guidelines Section 15088(b), South Coast AQMD staff requests that the Lead
Agency provide South Coast AQMD staff with written responses to all
comments contained herein prior to the certification of the Final EIR. In
addition, issues raised in the comments should be addressed in detail giving
reasons why specific comments and suggestions are not accepted. There
should be good faith, reasoned analysis in response. Conclusory statements
unsupported by factual information will not suffice (CEQA Guidelines Section
15088(c)). Conclusory statements do not facilitate the purpose and goal of
CEQA on public disclosure and are not meaningful, informative, or useful to
decision makers and to the public who are interested in the Proposed Project.
Further, when the Lead Agency makes the finding that the recommended
mitigation measures are not feasible, the Lead Agency should describe the
specific reasons for rejecting them in the Final EIR (CEQA Guidelines Section
15091).
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
17
South Coast AQMD staff is available to work with the Lead Agency to address
any air quality questions that may arise from this comment letter. Please
contact Robert Dalbeck, Assistant Air Quality Specialist, at
RDalbeck@aqmd.gov or (909) 396-2139, should you have any questions.
Response D-4 The City thanks the South Coast AQMD for its participation in the CEQA
process. The South Coast AQMD’s questions regarding air quality impacts have
been addressed in the comments and responses below. The City will transmit
the Final EIR/Response to Comments to the South Coast AQMD and all other
commenters as required by law prior to the City Council’s consideration of the
EIR.
As described below, the City has taken the South Coast AQMND’s
recommendations under consideration, addressed questions, and included
mitigation measures or explained why they have not been included in the
responses below.
Comment D-5 Air Quality Impact Analysis - Haul Truck Emissions
1. In the Air Quality Analysis, the Lead Agency quantified haul truck emissions
by calculating the vehicle miles traveled (VMT) per day by haul trucks. The
Lead Agency identified the number of haul truck trips expected per day
and multiplied the trips per day by a distance of 2.5 miles because the
exported material would be taken to the Classic Club. South Coast AQMD
staff is concerned that the Lead Agency may have under-estimated the
haul trip distance. As shown in Figure 1 below, the shortest haul route
distance from the Proposed Project to the Classic Club is approximately 3.5
miles. Calculating the Proposed Project's haul truck emissions based on a
2.5-mile hauling distance instead of a 3.5-mile hauling distance might have
under-estimated the Proposed Project's construction emissions.
Therefore, to
conservatively analyze a
worst-case construction
impact scenario, South
Coast AQMD staff
recommends that the Lead
Agency recalculate haul
truck emissions based on a
3.5-mile trip length, or
provide additional
information to justify the
use of a 2.5-mile trip length
in the Final EIR. If the Lead
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
18
Agency finds, after revising the Air Quality Analysis, that a new significant
impact or a substantial increase in the severity of the air quality impact
than that analyzed in the Draft EIR that cannot be reduced to less than
significant levels with existing MM AQ-1 through MM AQ-9, the Lead
Agency should commit to reevaluating the Proposed Project's Air Quality
Impacts and recirculating the Air Quality Analysis section of the Draft EIR
for public review and comments (CEQA Guidelines Section 15088.5).
Response D-5 The air quality modeling originally assumed a 2.5-mile haul route. Adhering to
South Coast AQMD’s recommendation, haul truck emissions were
recalculated in CalEEMod Version 2016.3.2 using a 3.5-mile trip length to
conservatively analyze a worst-case construction impact scenario. During the
process of revising the CalEEMod assumptions, two additional changes were
made in the model to reflect CARB and USEPA equipment emission standards
and other construction practices that were not previously considered, as
recommended by South Coast AQMD.
The first modification made to the model, consistent with South Coast AQMD’s
recommendation (see Comment D-7) was updating all construction
equipment engines to Tier 4 per CARB and USEPA off-road emissions standards
for equipment rated at 50 horsepower or greater during Project construction.
These standards were recommended in South Coast AQMD’s comment letter
Attachment, item 3.a, for Construction-Related Air Quality Mitigation
Measures. An additional mitigation measure, MM AQ-10, will be added to
require Tier 4 engine standards (See Response D-7, below).
The second modification made to the model was equipment operational hours
during the grading period where hauling occurs. Originally, the model assumed
that all pieces of equipment were to operate for 8 hours per day, essentially
operating non-stop during a standard work day. To account for worker breaks,
refueling, loading of the haul trucks, and miscellaneous maintenance, the
hours of operation were changed from 8 hours per day to 7 hours per day.
The following table provides the comparison of previous Project construction
emissions and the recalculated emissions with modifications, as discussed
above. See Appendix B for the revised CalEEMod outputs.
DSRT SURF Specific Plan
EIR (SCH M 2019011044)
Final EIR/Response to Comments
Construction Emissions Comparison: Proposed Project
(lbs./day)
CO
NO,
ROG
SO,
PMrs
PMzs
ORIGINAL — 1/30/2019
Max. Daily Emissions
65.67
99.43
65.90
0.14
9.58
6.11
SCAQMD Threshold
550.00
100.00
75.00
150.00
150.00
55.00
Exceeds Threshold
No
No
No
No
No
No
REVISED — 7/9/2019
Max. Daily Emissions
64.85
92.32
65.90
0.14
9.58
6.11
SCAQMD Threshold
550.00
100.00
75.00
150.00
150.00
55.00
Exceeds Threshold
No
No
No
No
No
No
Source: CaLEMod Version 2016.3.2.
As shown in the table above, construction -related emissions would remain
below South Coast AQMD thresholds. Given that emissions will remain less
than significant, that the change in haul trip length is not significant, and that
the addition of the Tier 4 engine requirement represents a standard of law, no
substantial change has been made to the EIR, and recirculation is not
necessary or required.
Please note that this change affects a number of pages in EIR where emissions
are discussed. The locations of changes, and the proposed change are
provided in Section 3.
Comment D-6 Recommended Revisions to Existing Mitigation Measure AQ-1
2. The Lead Agency has committed to installing electric vehicle (EV) charging
stations in five percent of all vehicle parking spaces at the Proposed
Project. To facilitate the implementation of the 2016 California Green
Building Standards Code, Part 11 for nonresidential projects with 201
vehicle parking spaces or more to include EV charging stations in at least
six percent of all vehicle parking spaces, South Coast AQMD staff
recommends that the Lead Agency incorporate the following changes to
MM AQ-1 in the Final EIR. Additionally, South Coast AQMD staff
recommends that the Lead Agency include designated parking for clean air
vehicles in at least eight percent of all vehicle parking spaces for
nonresidential projects with 201 vehicle parking spaces or more.
MM AQ-1: At least 369' of all vehicle parking spaces shall include EV charging
stations and 8%of all vehicle parking spaces shall include designated parking
for clean air vehicles.
Response D-6 Comment noted and the suggested update to MM AQ-1, above, will be made
in the Final EIR.
19
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
20
Comment D-7 Additional Recommended Mitigation Measures
3. CEQA requires that all feasible mitigation measures that go beyond what
is required by law be utilized to minimize or eliminate any significant
adverse impacts. South Coast AQMD staff recommends that the Lead
Agency review the following recommended mitigation measures for
incorporation in the Final EIR to further reduce construction and
operational emissions.
Construction-Related Air Quality Mitigation Measures
a. Require the use off-road diesel-powered construction equipment that
meets or exceeds the California Air Resources Board (CARB) and U.S.
Environmental Protection Agency (USEPA) Tier 4 off-road emissions
standards for equipment rated at 50 horsepower or greater during Project
construction. Such equipment will be outfitted with Best Available Control
Technology (BACT) devices including a CARB certified Level 3 Diesel
Particulate Filters (DPFs). Level 3 DPFs are capable of achieving at least 85
percent reduction in particulate matter emissions. A list of CARB verified
DPFs are available on the CARB website.
To ensure that Tier 4 construction equipment or better will be used during
the Proposed Project's construction, South Coast AQMD staff recommends
that the Lead Agency include this requirement in applicable bid
documents, purchase orders, and contracts. Successful contractor(s) must
demonstrate the ability to supply the compliant construction equipment
for use prior to any ground disturbing and construction activities. A copy
of each unit's certified tier specification or model year specification and
CARB or South Coast AQMD operating permit (if applicable) shall be
available upon request at the time of mobilization of each applicable unit
of equipment. Additionally, the Lead Agency should require periodic
reporting and provision of written construction documents by
construction contractor(s) to ensure compliance, and conduct regular
inspections to the maximum extent feasible to ensure compliance.
In the event that construction equipment cannot meet the Tier 4 engine
certification, the Project representative or contractor must demonstrate
through future study with written findings supported by substantial
evidence that is approved by the Lead Agency before using other
technologies/strategies. Alternative applicable strategies may include, but
would not be limited to, construction equipment with Tier 3 emissions
standards, reduction in the number and/or horsepower rating of
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
21
construction equipment, limiting the number of daily construction haul
truck trips to and from the Proposed Project, using cleaner vehicle fuel,
and/or limiting the number of individual construction project phases
occurring simultaneously.
b. Require the use of zero-emission or near-zero emission heavy-duty haul
trucks during construction, such as trucks with natural gas engines that
meet CARB's adopted optional NOx emissions standard of 0.02 grams per
brake horsepower-hour (g/bhp-hr). At a minimum, require that operators
of heavy-duty haul trucks visiting the Proposed Project during construction
commit to using 2010 model year or newer engines that meet CARB's 2010
engine emission standards of 0.01 g/bhp-hr for particulate matter (PM)
and 0.20 g/bhp-hr of NOx emissions or newer, cleaner trucks. Include
analyses to evaluate and identify sufficient power available for zero
emission trucks and supportive infrastructures in the Energy and Utilities
and Service Systems Sections of the Final EIR, where appropriate. Require
that contractor(s) maintain records of all trucks visiting the Proposed
Project and make these records available to the Lead Agency upon request.
The records will serve as evidence to prove that each truck called to the
Proposed Project during construction meets the minimum 2010 model
year engine emission standards. The Lead Agency should conduct regular
inspections of the records to the maximum extent feasible and practicable
to ensure compliance with this mitigation measure.
c. Maintain vehicle and equipment maintenance records for the construction
portion of the Proposed Project. All construction vehicles must be
maintained in compliance with the manufacturer's recommended
maintenance schedule. All maintenance records shall remain on-site for a
period of at least two years from completion of construction.
d. Encourage construction contractors to apply for South Coast AQMD
"SOON" funds. The "SOON" program provides funds to applicable fleets for
the purchase of commercially-available low-emission heavy-duty engines
to achieve near-term reduction of NOx emissions from in-use off-road
diesel vehicles. More information on this program can be found at South
Coast AQMD's website:
http://www.agmd.gov/home/programs/business/business-
detail?title=off-road-diesel-engmes.
Response D-7 As described in Response D-6, the EIR will be modified to include
recommendation “a” to require the use off-road diesel-powered construction
equipment that meets or exceeds the California Air Resources Board (CARB)
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
22
and U.S. Environmental Protection Agency (USEPA) Tier 4 off-road emissions
standards for equipment rated at 50 horsepower or greater during Project
construction. The mitigation measure will read as follows:
MM AQ-10 Off-Road Emission Standards
It shall be required that all off-road diesel-powered construction equipment
meets or exceeds the California Air Resources Board (CARB) and U.S.
Environmental Protection Agency (USEPA) Tier 4 off-road emissions standards
for equipment rated at 50 horsepower or greater during Project construction.
Because all criteria pollutant emissions are below South Coast thresholds for
construction, and therefore do not create significant adverse impacts, the
addition of items “b” through “d” as mitigation measures are not necessary.
Comment D-8 Operation-Related Air Quality Mitigation Measures
a. Provide incentives for vendors and material delivery trucks that would be
visiting the commercial/retail uses of the Proposed Project to encourage
the use of ZE or NZE trucks during operation, such as trucks with natural
gas engines that meet CARB's adopted optional NOx emissions standard of
0.02 grams per brake horsepower-hour (g/bhp-hr). At a minimum,
incentivize the use of 2010 model year. Include analyses to evaluate and
identify sufficient power available for zero emission trucks and supportive
infrastructures in the Energy and Utilities and Service Systems Sections of
the Final EIR, where appropriate.
b. Establish a shuttle bus system to accommodate special events, aimed at
reducing vehicle miles traveled and idling times associated with traffic
congestion of visitors of the Proposed Project.
c. Maximize the use of solar energy including solar panels. Install the
maximum possible number of solar energy arrays on the building roofs
and/or on the Proposed Project site to generate solar energy for the facility
and/or EV charging stations.
d. Maximize the planting of trees in landscaping areas and parking lots.
Response D-8 As discussed in the DEIR on page 2.13-16, operational-emissions of NOx
related to customer/passenger vehicle trips could have potentially significant
adverse impacts. The suggestions (a-d) made by the commenter do not
directly address the impact associated with NOx related to passenger vehicle
trips. Although the incentive program for vendors and material delivery trucks
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
23
may result in a slight reduction to operational emissions, this measure cannot
be enforced with 100% guarantee that all tenants will participate in the
incentive program. As a result, its addition would not represent an effective
mitigation measure, and would not reduce NOx emissions.
Additionally, suggestions “b” through “d” have already been incorporated into
the Project design and operations, and are not necessary as mitigation
measures. Please see DEIR page 1-6 as it relates to shuttle buses for special
events, page 2.2-33 as it relates to the incorporation of solar panels in the
Project design, and page 1-3 as it relates to landscaping requirements.
Comment D-9 Responsible Agency and South Coast AOMD Permits
4. It is important to note that generally, operation of portable engines and
portable equipment units of 50 horsepower (hp) or greater requires a
permit from South Coast AQMD or registration under the Portable
Equipment Registration Program (PERP) through the California Air
Resources Board (CARB). In the event that using portable cement
manufacturing, aggregate crushing, and screening equipment of 50 hp or
greater is expected at the Proposed Project, the Lead Agency should
consult with South Coast AQMD's Engineering and Permitting staff to
determine if a South Coast AQMD permit will be required and if
compliance with any South Coast AQMD rules and/or regulations are
required. If a permit from South Coast AQMD is required, South Coast
AQMD should be identified as a Responsible Agency for the Proposed
Project in the Final EIR. If the Proposed Project is required to adhere to any
South Coast AQMD rules and regulations, South Coast AQMD rules and
regulations should be discussed in the Air Quality section of the Final EIR
to demonstrate compliance. Any assumptions used in the Air Quality
Analysis in the Final EIR will be used as the basis for permit conditions and
limits for the Proposed Project. Should there be any questions on permits,
please contact South Coast AQMD's Engineering and Permitting staff at
(909) 396-3385. For more general information on permits, please visit
South Coast AQMD's webpage at: http://www.aqmd.gov/home/permits.
For more information on the PERP Program, please contact CARB at (916)
324-5869 or visit CARB's webpage at:
https://ww2.arb.ca.gov/our-work/programs/portable-equipment-
registration-program-perp.
Response D-9 Comment is noted. The City shall consult with South Coast AQMD's
Engineering and Permitting staff should a South Coast AQMD permit be
required and if compliance with any South Coast AQMD rules and/or
regulations are required.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
24
E. Law Offices of John Belcher
Comment E-1 This law firm represents Save Our Mojave, a 501(c)(3) non-profit organization
working to raise public awareness about some of the most pressing issues
facing California's deserts, including unchecked damage to the environment
and wildlife.
Save Our Mojave has reviewed the Environmental Impact Report ("EIR") for
the proposed DSRT SURF Project (the "Project"). The project proposes the
development of a 6-acre surf lagoon and surf center facilities (restaurant, bar,
retail, and similar facilities) and up to 350 hotel rooms and 88 residential villas
on 17.69 acres in the City of Palm Desert, Riverside County. As described in the
DSRT Surf Specific Plan:
The Project will be implemented in two phases. The Surf Lagoon Planning
Area will include development of a 5.5-acre surf lagoon and surf center
facilities to include restaurant, bar, retail, and similar facilities together
totaling 11.85 acres. The Hotels and Villas Planning Area will include the
development of up to 350 hotel rooms and up to 88 resort residential
villas on approximately 5.84 acres. Parking facilities throughout the
Project will include surface parking, underground parking, and
improvement of an existing off-site parking lot southeast of the Project
site for overflow parking during special events. Primary Project access will
be provided via two access drives on Desert Willow Drive, and emergency
access will be provided at a third access point at the southwestern portion
of the Project, into the adjacent developed Westin Desert Willow project.
In addition to daily operations, the surf lagoon and surf center will also be
capable of accommodating special events that will attract additional
surfers and ticketed spectators. The number of special events is not
currently known. However, for purposes of this document, it has been
assumed that up to one event per month could occur, for a total of 12
special events per year.
Response E-1 Comment noted. The commenter cites page ES-2 of the DEIR.
Comment E-2 The EIR describes the proposed Project and assesses the potential adverse
impacts on the surrounding physical environment, but concludes that the
effects could be mitigated to "less- than-significant" levels, or that they are
"significant, but unavoidable." After investigation and after review of publicly
available documents, Save Our Mojave believes that the Project does not
adequately mitigate the impact of the Project on the environment and local
wildlife, and neither does it adequately explore the cumulative impacts of this
Project relative to others in the area.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
25
"CEQA does not require technical perfection in an EIR, but rather
adequacy, completeness, and a good-faith effort at full disclosure." CEQA
Guidelines § 15003(1). Absent complete environmental impact analysis of
the effect on the local environment and wildlife, the EIR is not a "good faith
effort at full disclosure."
Response E-2 The commenter’s opinion is noted. However, as described in the Responses
which follow, the DEIR is adequate, complete and provides full disclosure of
the Project’s direct, indirect and cumulative impacts.
Comment E-3 Above all, we are extremely concerned about the level of water usage required
for the continuos (sic) operation of this Project. The EIR admits repeatedly that
the Coachella Valley relies on groundwater for its primary supply source, and
that "the amount of water in the aquifer has decreased over the years due to
pumping to serve urban, rural and agricultural development in the Coachella
Valley, which has withdrawn water from the aquifer at a rate faster than its
natural rate of recharge." The solution has been to import the majority of the
water supply, primarily from the Colorado River.
Response E-3 As described in the EIR and Water Supply Assessment for the project
(Appendix I), the CVWD balances its withdrawals of groundwater with natural
surface water recharge, the recycling of water at two of its treatment plants,
and recharge from at several facilities located in the western and eastern
Coachella Valley (DEIR page 2.10-9; Appendix I pages 16 to 24). As a result of
these activities, the Basin is no longer in overdraft. The CVWD has long-
standing State Water Project (SWP) contracts which it uses for recharge
efforts. The SWP allocations are established each year. In years of high supply,
the CVWD recharges greater amounts of water; whereas in low supply years
recharge is limited. As described in Response C-7, the CVWMP includes
comprehensive management of the water resource, consistent with State law.
Comment E-4 Coachella Valley's water conservation plans rely heavily on source substitution
with the Colorado River, but the Colorado River is also experiencing historically
low levels and drought conditions. Countless other communities also rely on
the Colorado River as a water source, so this practice is not sustainable in the
long term. In fact, the EIR only analyzes and accounts for the water supply
through 2040, which is relatively soon. With exponential population growth
expected, and the continuing effects of climate change, this analysis needs to
account for a much longer period of time. The updated Coachella Valley Water
Management Plan even admits:
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
26
There are a number of uncertainties inherent in the demand projections,
including:
• Growth forecasts or rates of growth may be too high or too low
• Impacts of economic booms and busts
• Reductions in fish farm operations
• Rates of development on Tribal lands
• Rate of agricultural/vacant land conversion to urban use
• Future water demand factors for various land uses
• Growth outside the Whitewater River subbasin
• Number of future golf courses developed in the East Valley
• Acceptance and effects of water conservation measures
It quickly goes on to say that "climate change could affect the long term
supplies of both the SWP and Colorado River and water demands within the
Valley" MWH, Coachella Valley Water Management Plan Update § ES-16
(2012).
Response E-4 The commenter cites the Executive Summary of the CVWMP, but fails to
recognize that the document went on to analyze goals for water conservation,
techniques for conservation and management of the resource, and extensive
analysis of both the implementation of the CVWMP to date, and future efforts.
In addition, the CVWD has issued regular Status Reports on the CVWMP, the
latest being in 2016. In that report, as described on pages 36-37 of the WSA,
the Basin is no longer in overdraft due to the management of the resource
implemented in the CVWMP. Further, the CVWD does not assume or rely on
its annual assigned allocation. Instead, as described on pages 58 and 59 of the
WSA, the CVWD’s planning assumptions are that it will receive 50% of its
allocation on an annual basis. This represents a conservative estimate of the
potential for source substitution. The CVWD also has implemented
conservation measures which have resulted in reductions in demand, and
continues to plan for further conservation. Finally, the CVWMP includes
expanded use of recycled water, to include not only golf course uses, but
landscaping areas as well.
As it relates to the WSA’s analysis to 2040, the timeframe was established by
SB 610 and SB 221, when they were passed into law. California Water Code
Sections 10910 and 10912 were amended at that time to require water
purveyors to analyze water supply based on land use on a 20 year horizon.
Analysis beyond that timeframe would be speculative and not based on fact.
The WSA and DEIR, therefore, correctly analyze the CVWD’s water demand
and supply.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
27
As it relates to population growth, all of CVWD’s planning documents,
including the CVWMP and its Urban Water Management Plan (UWMP) are
based on population growth data developed by the Riverside County Center
for Demographic Research, and were adopted by the Southern California
Association of Governments. The continued analysis of population projections
in the region resulted in a lowering of anticipated population growth in the
UWMP in 2015 (WSA page 53).
Finally, as it relates to climate change, the WSA thoroughly describes that
CVWD has and continues to consider climate change, including a water supply
buffer in its assumptions (WSA pages 42-43, and Appendix A).
Comment E-5 The Project (even with extensive mitigation) is projected to demand over 18
million gallons of water per year, around 1.25 million of that being loss due to
backwash and evaporation from the pools, spas, and the surf lagoon. If not for
artificial recharge from other declining sources, the area would have nowhere
near enough water supply for the demand and it is therefore unsustainable to
continue to grow the demand by such great margins. Projects that allow for
such a high degree of wasted resources, i.e. the amount of water lost due to
evaporation, should not be permitted to put pressure on already declining
aquifers. This is especially true when the climate crisis is creating an uncertain
future where sustainability and demand on aquifers are getting harder and
harder to predict.
Response E-5 As described in the DEIR, pages 2.10-18 through 2.10-25, the proposed Project
will generate a total water demand of 165.21 AFY. The Project is required,
however, to implement a turf reduction program on both Desert Willow golf
courses. The area to be replaced currently generates a demand for 143.08 AFY.
With implementation of the turf reduction requirement, the same area will
generate a demand of 36.34 AFY (EIR Table 2.10-5). This water demand is
currently accommodated by recycled water and groundwater pumped from
the existing wells on the property. By replacing the turf with drought tolerant
landscaping, the Project will reduce water demand by 106.75 AFY on the golf
course. The Project’s net water demand will be 58.46 AFY. The CVWD
determined that it has sufficient supplies to accommodate the project when it
adopted the WSA on May 14, 2019.
The Project will implement water conservation measures prescribed by the
Uniform Building Code in effect at the time that construction is undertaken.
These conservation measures include both interior fixtures, and outdoor
irrigation of low-water demand landscaping. The Project’s landscape plans
must meet or exceed the City’s landscaping ordinance, which sets strict limits
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
28
on irrigation. Further, the Project’s irrigation will use recycled water currently
available at the golf course. These measures, considered in the calculation of
water demand provided in Table 2.10-1 of the DEIR, assure that the Project
will not waste resources.
As it relates to climate change, please see Response E-4.
Comment E-6 We are also deeply concerned about the impact of the Project on the area's
burrowing owl population. Long-term studies need to be conducted on
burrowing owls in the area. Previous studies are minimal and preconstruction
surveys, while protecting specific owls in the short-term, would not accurately
represent any long-term effects on local populations.
Western burrowing owls are at risk of going extinct in areas of California, and
habitat degradation and fragmentation are the most pressing issues facing the
species. This project has a potentially significant impact. As burrowing owls are
ground nesting, there are almost no possible methods of mitigation, and any
amount of disturbance in their direct habitat would eliminate them. Attempts
have been made to relocate burrowing owls in other areas of California, but
the success rates has (sic) been inconsistent. Attempts have also been made
to create imitation burrows to attract owls to a new area, but those have also
been mostly unsuccessful.
San Diego Zoo conservationists affirm that current mitigation strategies have
no proven record of success and further research is required into the best
methods of mitigation for this species.
Response E-6 The commenter is incorrect. The burrowing owl has been extensively studied
in the Coachella Valley, particularly in the Coachella Valley Multiple Species
Habitat Conservation Plan (MSHCP). As described on pages 2.4-20 through 2.4-
21 of the DEIR, the burrowing owl is a covered species under the MSHCP, but
its take is not authorized by the Plan. The DEIR further describes that the
biologist identified suitable mammal burrows on the Project site, but did not
find either sign or presence during the site specific survey. The species,
however, is mobile, and could occupy the site prior to construction. As
required by California Fish and Game Code and the Migratory Bird Treaty Act,
to avoid take of the species and assure that the Project has no impact on it,
Mitigation Measures BIO-2 and BIO-3 are provided in the EIR. These measures
include performance standards, including compliance with CDFW protocol, to
assure that the species is not impacted. Should pre-construction surveys
identify the presence of the species on the site, CDFW consultation is required.
CDFW, as the State’s expert agency on the protection of the species, would
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
29
recommend and work with the biologist to determine what course of action is
most appropriate. The EIR fully discloses that the species does not occur, but
provides for effective mitigation should it be located prior to the initiation of
construction. The EIR and mitigation measures correctly conclude that impacts
to the species will be less than significant with the implementation of
mitigation measures.
Comment E-7 Protection of the burrowing owls themselves is not the only relevant factor, as
the owls rely heavily on ground squirrels as a primary source of prey. The
Project could also potentially impact local ground squirrel populations, but this
discussion is absent from the EIR. Further surveys need to be done in order to
better understand the permanent direct and indirect impacts on the area
ground squirrel population.
Response E-7 As stated in Response C-6 and in the EIR, burrowing owl were not identified
on the site, nor was their sign found at or near the burrows the biologist
identified. Given that the species does not occur, the commenter’s assumption
that it would have a significant impact on ground squirrel populations is
unfounded. Also as stated in the EIR (page 2.4-11) no ground squirrels were
identified during the site survey. Table 2.4-3 identifies one sensitive ground
squirrel species, the Coachella Valley (Palm Springs) round-tailed ground
squirrel, as absent from the site, based on degraded habitat and distance from
the nearest reported sighting of the species. Therefore, there is no likelihood
of impacts to ground squirrels, or as a result, indirect impacts on burrowing
owl, on the Project site, and no further analysis is required.
Comment E-8 The Project will also result in significantly compromised air quality in the area
throughout the construction process, and potentially once the development is
completed. Removal of stabilized soils and biological soil crust creates a
destructive cycle of airborne particulates and erosion. As more stabilized soils
are removed, blowing particulates from recently eroded areas act as abrasive
catalysts that erode the remaining crusts thus resulting in more airborne
particulates.
Response E-8 The EIR correctly identifies that the Project area, and the Coachella Valley, are
in non-attainment for PM10, and unclassified for PM2.5. The EIR also describes
that the Project site is subject to the 2003 PM10 Coachella Valley State
Implementation Plan (CVSIP), which was adopted specifically to address
attainment of PM10 standards (EIR page 2.3-2). The EIR also includes Table
2.3-2, which shows the number of days when the federal and State standards
for PM10 were exceeded. As shown in that table, the more stringent State
standard has not been exceeded since 2013. The CVSIP imposes strict
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
30
standards for construction activities as they relate to PM10, and requires all
projects to prepare PM10 management plans that must be approved by the
local jurisdiction prior to initiation of activities on a project site. The proposed
Project will be subject to these requirements. As shown in Table 2.3-6, with
the implementation of the standard requirements of a PM10 management
plan, the proposed Project’s construction activities will result in 9.58 pounds
of PM10, and 6.11 pounds of PM2.5, far below the SCAQMD threshold of 150
and 55 pounds, respectively.
Comment E-9 As stated in the current EIR, development-related NOx emissions would
"violate State or Federal air quality standards for NOx emissions, which
subsequently will substantially contribute to the existing ozone violation in the
Salton Sea Air Basin." The EIR had already discussed the compromised air
quality in the area due to environmental and weather factors, admitting that
particulates are often held in the area, creating ongoing air quality issues. The
EIR in fact, goes on to say that even with full implementation of the mitigation
measures, the "impacts associated with operations of the proposed Project at
build out will remain significant and unavoidable” and "operational impacts
will continue to exceed NOx emissions under the current analysis methods." A
development with this effect on emissions is unacceptable amidst the current
state of our climate crisis.
Response E-9 The commenter’s opinion is noted. The EIR correctly identifies that NOx
emissions will exceed SCAQMD thresholds during operations. The EIR also fully
discloses that the exceedance is the result of vehicle trips. The EIR then
imposes mitigation measures, to the greatest extent practical, to reduce these
emissions, including idling time limitations for delivery vehicles, employee
commute reduction programs for large employers, and the use of electric
mowers. As stated in the EIR, however, even with the implementation of these
mitigation measures, NOx emissions will exceed SCAQMD thresholds of
significance, and impacts will be significant and unavoidable (EIR page 2.3-21).
As described in the CEQA Guidelines, Section 15002, the purpose of CEQA is to
“inform governmental officials and the public about the potential, significant
environmental effects of proposed activities.” The EIR has provided that
analysis, and demonstrated to the public and the City’s officials that NOx
emissions cannot be mitigated to a less than significant level. The EIR also
states that in order to approve the Project, the City will be required to adopt
Findings and a Statement of Overriding Considerations (EIR page 2.3-21). The
EIR correctly identifies the process, as provided in CEQA Guidelines 15093,
which the City is required to consider. When the Project is considered by the
City Council, it will have the opportunity to consider whether the adoption of
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
31
a Statement of Overriding Considerations is appropriate, based on applicable
“economic, legal, social, technological or other benefits” of the proposed
Project.
Comment E-10 The EIR needs to go farther in addressing the spike in greenhouse gas
emissions during the potentially multiple year construction period. Due to the
use of heavy construction equipment, unsafe levels of air pollutants would
have an impact on the surrounding community and wildlife during that time.
The presence of toxic air contaminants during construction is discussed in
relation the sensitive human receptors, but ignores construction pollutant
impact on wildlife and the ecosystem.
Response E-10 The EIR, Section 2.8.6, identifies that the project will generate a total of
2,491.23 metric tons of CO2e during Project construction (Table 2.8-1). The
EIR further breaks down these emissions on an annual basis, assuming a three
year construction period. As provided by SCAQMD in its standards and
requirements, the construction emissions are amortized over a 30 year period
to determine total annual GHG emissions associated with the Project. This
analysis, provided in Table 2.8-3, shows that the Project will result in significant
and unavoidable impacts associated with GHG emissions. As described in
Response E-9, the EIR correctly discloses the level of impact, and that in order
to approve the Project, the City will be required to determine whether the
benefits of the Project outweigh the impacts associated with GHGs.
As regards toxic air contaminants, the proposed Project does not occur within
proximity to a high volume roadway or railroad, and will not generate diesel
truck trips beyond the vehicle mix established for resort projects in the Valley.
The EIR does analyze both the health impacts associated with air pollutants
(EIR pages 2.3-17-2.3-18), and the impacts to sensitive receptors proximate to
the Project site during construction (EIR page 2.3-19). As correctly stated, in
the case of the former, on-site and off-site exposure to NOx generated by the
Project are expected to result in less than significant impacts associated with
health risks. The analysis also discusses the cumulative impacts associated
with the regional nature of air pollutants, and the lack of factual data relating
to health risks. In the case of localized emissions, the EIR includes a discussion
of proximate sensitive receptors, and quantifies those impacts in Table 2.3-8.
As shown in that Table, the impacts associated with criteria pollutants for
which the region is in non-attainment will be well below the thresholds of
significance established by the SCAQMD.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
32
The commenter offers no substantial evidence that construction pollutants
will impact wildlife or the ecosystem in a manner different or greater than that
analyzed for human beings. As stated in the EIR analysis of biological resources
(Section 2.4), the site is comprised of degraded habitat that has been impacted
by human activities associated with the golf course which surrounds the site.
No sensitive species were identified on the Project site, nor are sensitive
species expected to occur on the site (see Tables 2.4-1 through 2.4-3).
Common species occur on and surrounding the Project site, but there is no
evidence that air emissions from localized construction activities would be
greater than those to human beings, which would be less than significant as
established by the SCAQMD.
Comment E-11 Noise pollution, like air pollution, has significant health implications.
Construction and traffic noise are some of the largest producers of noise
pollution. Prolonged exposure to noise pollution can lead to hypertension and
heart disease, hearing loss and consequential sleep disturbances. The surf
lagoon is projected to stay open until midnight or 2 A.M., and the Project is
projected to host around 12 special events per year. All of these elements will
contribute heavily to noise pollution in the area. Noise pollution does not only
adversely effect (sic) human lives. Wildlife, especially birds, are heavily
impacted by increased noise pollution. Communication, mating behavior,
hunting and survival instincts of animals are altered by excessive noise.
Response E-11 The commenter provides no substantial evidence that specific noise levels will
impact wildlife at the Project site. Section 2.12-6 analyzed noise impacts
associated with the proposed Project. In that analysis, construction noise is
shown to reach up 68.4 dBA Leq at 90 feet. This noise level is typical of urban
environments, and well below the National Institute of Occupational Safety
and Health’s 85 dBA noise threshold of significance (EIR page 2.12-20).
The EIR also quantified operational noise levels, including noise levels during
special events. As shown in Table 2.12-15, noise levels during special events
will not exceed the City’s daytime or nighttime thresholds for either residential
or commercial land uses proximate to the Project. The EIR also depicted the
noise contours associated with the Project in Exhibit 2.12-3. As shown in that
Exhibit, noise levels of 60 dBA or less are expected to occur at the property
line. These noise levels are consistent with or less than the noise levels
acceptable by City standards, and consistent with the urban environment in
which the Project is proposed.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
33
As described in Response E-10, there are no sensitive wildlife species on the
Project site. Common species will be subject to the 68.4 dBA construction
noise levels, but given their life currently in an urban environment, they are
experiencing these noise levels. Because the proposed Project will not exceed
the City’s standards for urban community noise levels, the proposed Project
will not substantially change the noise environment for either the people or
the wildlife that occur in the Project area.
Comment E-12 As written, the EIR also glosses over the aggregate environmental impacts of
the Project and misleads the reader through words such as "may" and
"potentially." This Project cannot be viewed independently from other
planned developments in the region. The EIR needs to address the cumulative
effects of the Project in relation to other nearby projects and planned
developments.
The cumulative impact from several projects is the change in the
environment which results from the incremental impact of the project
when added to other closely related past, present, and reasonably
foreseeable probable future projects. Cumulative impacts can result from
individually minor but collectively significant projects taking place over a
period of time.
CEQA Guidelines § 15355(b). Water demand, greenhouse gas emissions, noise
and air pollution, and habitat fragmentation are aggregate and have
cumulative effects. It would be a cataclysmic oversight for the City to allow the
Project to move forward without fully analyzing this Project's impact in
relation to the overall impact of other projects in the region that are currently
in development or in the planning stages.
Response E-12 The EIR analyzes cumulative impacts for each and every environmental impact
area (see EIR Section 2 discussions, subsection .9 of each). In each impact area,
the scope of the cumulative analysis is defined, based on the impact area’s
influence. In most cases, the scope of the cumulative impact analysis relates
to General Plan build out of the City, which represents the worst-case potential
for future and existing projects, and provides a more conservative analysis
than studying only projects that are “in development or in the planning
stages.” In impact areas such as air quality, biological and cultural resources,
water resources and greenhouse gas emissions, which are regional in nature,
cumulative impacts are analyzed on that basis. As a result of that analysis, the
EIR correctly discloses that air quality and greenhouse gas emission impacts
will be significant and unavoidable.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
34
Comment E-13 For all of the reasons stated above, we oppose the project as currently
proposed. The Project's EIR must be rewritten to address all the environmental
impacts. The current EIR misleads the reader as to the true impact of the
Project. Only a rewritten and recirculated cumulative impacts analysis will
allow the public to understand the true impact of the Project.
Response E-13 As described in Responses E-2 through E-12, the EIR thoroughly analyzes the
Project’s direct, indirect and cumulative impacts. The EIR does not omit data
or analysis, nor does it inaccurately or incorrectly represent Project impacts.
The commenter has provided no substantial evidence to the contrary. There
is therefore no need to rewrite or recirculate the EIR.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
35
F. Liridona Leti
Comment F-1 You have to reconsider the wave pool that is happening at the golf course. This is
extremely anti environmentally friendly and it will not help the DESERT whatsoever.
Please notice that I emphasized DESERT, we live in the desert where what you are
allowing should not happen. CA has already had two major earthquakes in the last
week and if you think depleting the natural resources will help, think again. All that
you are allowing is more earthquakes and potholes to occur.
Do not let this go through, stop it before it gets worse.
Response F-1 The commenter’s opinion is noted. The commenter does not, however, provide any
substantial evidence that the proposed Project will result in either a greater number
of earthquakes or potholes. The proposed surf lagoon will be constructed to meet all
seismic standards of the Uniform Building Code in force at the time that building
permits are secured. These standards include the reinforcement of concrete to
prevent significant impacts associated with earthquakes. These impacts are analyzed
in Section 2.7, and include specific discussion of a number of seismic hazards and soils
hazards, including groundshaking, subsidence, lateral spreading, ground failure
(including liquefaction), soil erosion, unstable soils, and expansive soils. The EIR also
analyzed the potential hazards associated with seismically induced tsunami or seiche
in Section 2.10-6. This analysis, supported by a comprehensive analysis by a registered
geologist, resulted in a determination that impacts associated with geological hazards
will be mitigated to a less than significant level with the implementation of Mitigation
Measures GEO-1 through GEO-19. Impacts associated with earthquakes are correctly
determined in the EIR to be less than significant with the implementation of these
mitigation measures. No further analysis is required.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
36
3.0 CHANGES TO THE EIR
The following provides changes to the Draft EIR being made as a result of the Response to
Comments (Section 2) of this document. Typographical errors and other editorial modifications
are also provided below. Please note that deletions are indicated in strikethrough and additions
in underlined text.
CEQA Guidelines §15088.5 requires a Lead Agency to recirculate a revised EIR only if significant
new information is identified following the release of the Draft EIR. “Significant new information”
can include, changes in the project or environmental setting as well as additional data or other
information, for example, a new significant environmental impact or a substantial increase in the
severity of an environmental impact. New information is not considered significant unless the EIR
is changed in a way that deprives the public of a meaningful opportunity to comment upon a
substantial adverse environmental effect of the project or a feasible way to mitigate or avoid
such an effect that the proponent has declined to implement.
The City has evaluated the information contained in this Final EIR as well as all other information
in the record, and has determined that no significant new information has been added to the EIR
after public notice was given of the availability of the Draft EIR for public review. Therefore, CEQA
does not require recirculation of the Draft EIR.
Location Change
Page ES-26
Section 2.8 Greenhouse Gas Emissions
a) Generate greenhouse gas
emissions, either directly or
indirectly, that may have a
significant impact on the
environment.
No Impact
Potentially
Significant
No mitigation is
required.
No Impact
Significant
and
unavoidable
Page 2.3-14 “The proposed Project would result in approximately 17.69-acres of disturbance.
Construction would require the export of approximately 103,000 cubic yards5 of
surplus earthen material to the Classic Club, which has a designated fill site for
excess soils and is located approximately 3.5 miles northeast of the subject
property. Therefore, it is assumed that each haul round trip would be
approximately 7 miles. This represents a worse-case hauling distance, since the
City may also allow the off-loading of Project-related soil export within vacant
areas of the Desert Willow project, which are much closer than the 7 miles
associated with the Classic Club location.”
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
37
Page 2.3.14
Table 2.3-1
Construction Emissions Summary
Proposed Project
(lbs./day)
CO NOx ROG SOx PM10 PM2.5
Max. Daily Emissions 64.85 92.32 65.90 0.14 9.58 6.11
SCAQMD Threshold* 550.00 100.00 75.00 150.00 150.00 55.00
Exceeds Threshold No No No No No No
Source: CalEEMod Version 2016.3.2. See Appendix B of this EIR for detailed tables. Value shown represents the average
unmitigated emissions of summer and winter outputs.
* Source: “SCAQMD Air Quality Significance Thresholds” prepared by SCAQMD.
Note: PM10 and PM2.5 emissions are shown as “mitigated” in the CalEEMod output tables; however, the mitigation used is
standard dust control requirements, such as watering exposed onsite soil 3 times per day.
Page 2.3-19
Table 2.3-2
Localized Significance Thresholds
25 Meters, 5 Acres
(lbs per day)
CO NOx PM10 PM2.5
Construction 64.85 92.32 9.58 6.11
LST Threshold* 2,292.00 304.00 14.00 8.00
Exceed? No No No No
Source of Emission Data: CalEEMod Version 2016.3.2, see Appendix B of this DEIR.
Source of LST Threshold: LST Mass Rate Look-up Table, 25 meters, 5 acres, SCAQMD.
Page 2.3.20 AQ-1 Electric Vehicle Charging Stations
At least 6% of all vehicle parking spaces shall include EV charging stations
and 8% of all vehicle parking spaces shall include designated parking for
clean air vehicles.
Page 2.3-21 AQ-10 Off-Road Emission Standards
It shall be required that all off-road diesel-powered construction
equipment meets or exceeds the California Air Resources Board (CARB)
and U.S. Environmental Protection Agency (USEPA) Tier 4 off-road
emissions standards for equipment rated at 50 horsepower or greater
during Project construction.
Page 2.4-20 “Tables 2.4.1 through 2.4.3 summarize information on all special-status species
that have been reported in the Project vicinity, or that have the potential to occur
onsite based on geographic distribution and presence of potentially suitable
habitat. Given the level of existing disturbance onsite from parking lot
development, grading, installation of irrigation systems, development of
surrounding parcels, and daily disturbances of human activity on the adjacent
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
38
Desert Willow Golf Resort, there is a low potential for the proposed Project to
adversely impact sensitive biological species. Furthermore, the Surf Lagoon
component of the Project will operate daily from 6 AM to 12 AM, resulting in
constant motion on the surf lagoon. This water activity, combined with the human
activity associated with surfers, will prevent water fowl from taking up residence
in the Surf Lagoon.”
Page 2.8-7
Table 2.8-1
Construction GHG Emissions Summary
(Metric Tons)
CO2 CH4 N2O Total CO2e
2019 766.21 0.16 0.00 770.34
2020 1,404.68 0.17 0.00 1,408.87
2021 289.61 0.03 0.00 290.37
TOTAL 2,460.5 0.33 0.00 2,469.58
Source: CalEEMod Versions 2016.3.2. See Appendix B of this DEIR for detailed tables. Values
shown represent the total unmitigated GHG emission projections for construction of the
proposed Project. CO2e includes the remaining GHG pollutants, such as hydrofluorocarbons,
perfluorocarbons, and sulfur hexafluoride.
Page 2.8-9
Table 2.8-2
Operational GHG Emission Summary
(Metric Tons/Year)
CO2 CH4 N2O CO2e
Typical Operations 16,907.63 24.91 0.12 17,565.85
12 Special Events1 399.12 0.00 0.00 400.08
Amortized Construction2 82.01 0.01 0.00 83.02
Total Operational Emissions 18,048.95
Source: CalEEMod Version 2016.3.2. See Appendix B of this DEIR for detailed tables. Values shown represent the
total unmitigated GHG emission projections for operation of the proposed Project under two scenarios.
1. Emissions derived from multiplying daily metric ton emissions in Table 2.8-2 by 12.
2. Buildout construction GHG emissions were amortized over 30 years then added to buildout operational GHG
emissions. Emission numbers on “TOTAL” line in Table 2.8-1 were divided by 30, and are provided above.
Page 3.17-1 “Table 3.17-1 shows the level of impact associated with each alternative and the
proposed Project. As can be seen in that table, the level of significance associated
with the alternatives is consistent with the proposed Project’s impacts, with the
exception of Air Quality and Greenhouse Gas Emissions. Under the proposed
Project, vehicular emissions of NOx and CO2E would be significant and
unavoidable, due to the higher number of trips generated by the hotels, villas and
surf center. Under all alternatives, air quality impacts would not exceed SCAQMD
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
39
thresholds, and impacts would be less than significant. Alternatives B and C would
result in less than significant greenhouse gas emissions; however, Alternative A,
similar to the proposed Project, would also result in significant and unavoidable
impacts.”
Table 3.17-1
Environmentally Superior
Development Alternative Comparison
Level of Significance*
Environmental Issue
Proposed
Project
Alternative
A
Alternative
B
Alternative
C
Aesthetics LSM LS LS LS
Air Quality SU LS LS LS
Biological Resources LSM LSM LSM LSM
Cultural & Tribal Resources LSM LSM LSM LSM
Energy LS LS LS LS
Geology and Soils LSM LSM LSM LSM
Greenhouse Gas Emissions SU SU LS LS
Hazards and Hazardous Materials LSM LSM LSM LSM
Hydrology and Water Quality LSM LSM LSM LSM
Land Use and Planning LS LS LS LS
Noise LS LS LS LS
Population and Housing LS LS LS LS
Public Services LS LS LS LS
Transportation and Traffic LSM LSM LSM LSM
Utilities and Service Systems LS LS LS LS
SU= Significant and Unavoidable
LSM= Less than Significant with Mitigation
LS= Less than Significant
Page 4-1 “Introduction
Unavoidable significant impacts are those that cannot be reduced to acceptable
or insignificant levels by the implementation mitigation measures. Impacts
associated with development of the DSRT SURF Specific Plan are addressed in
detail in Section 2 of this EIR. Comprehensive mitigation measures, as well as
monitoring and reporting programs, have been developed to address potential
impacts. In most cases, the mitigation measures set forth in this Draft EIR will
demonstrably and effectively reduce all potentially significant impacts to levels of
insignificance. However, air quality impacts associated with NOx emissions during
the life of the project and greenhouse gas emissions, could not be mitigated to
less than significant levels and are considered an unavoidable significant impact.”
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
40
Page 4-2 “Greenhouse Gas Emissions
All components of construction, including equipment, fuels, materials, and
management practices, would be subject to current SCAQMD rules and
regulations related to greenhouse gases. Applicable SCAQMD rules include, but
are not limited to, source-specific standards that reduce the greenhouse gas
content in engines and limit equipment idling durations. The Project will also
adhere to the required state Low Carbon Fuel Standard for construction
equipment and heavy-duty vehicle efficiency standards.
Operational emissions will occur throughout the life of the Project. At buildout,
five emission source categories will contribute either directly or indirectly to
operational GHG emissions: energy/electricity usage, water usage, solid waste
disposal, area emissions (pavement and architectural coating off-gassing), and
mobile sources. The bulk of operational emissions are largely due to the number
of vehicle trips generated by the Project. As shown in Table 2.8-2, one special
event (33.34 MTCO2e/yr) will increase overall GHG emissions by a marginal 0.19
percent.
It was recommended by SCAQMD staff that a project’s greenhouse gas emissions
would be considered significant if it could not comply with at least one of the
“tiered” tests based upon an October 2008 staff report and draft interim guidance
document1, as described in Section 2.8.6 (p. 2.8-9).
Construction-related GHG emissions will not exceed GHG thresholds for
construction because no such thresholds have been established. However, the
Project would not comply with any of the tiered tests for overall operational
(annual) emissions, and will therefore have Significant and Unavoidable Impacts
associated with GHG emissions.
Because the Project would result in Significant and Unavoidable impacts, it can be
argued that operational impacts would conflict with GHG reduction goals because
operation of the Project would either exceed or not comply with SCAQMD’s
interim tiered thresholds. By exceeding such thresholds, the Project is
contributing to GHG emissions at a level that is not conducive to reducing state
and local GHG emissions. Although implementation of Mitigation Measure GHG-1
will assure the Project complies with the Palm Desert Environmental Sustainability
Plan, impacts are considered significant and unavoidable.”
1 Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, prepared by
SCAQMD, October 2008.
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
Appendix A
Comment Letters
...�~Sr9T
x�.
Gavin Newsom
Governor
July 8, 2019
g4��pF PU1,yi,4,�C
STATE OF CALIFORNIA
Governor's Office of Planning and Research
State Clearinghouse and Planning Unit'��
Kate Gordon
Director
Eric Ceja
Palm Desert. City of
73-510 Fred Waring Drive
Palm Desert, CA 92260
Subject: DSRT SURF Specific Plan, Precise Plan, TTM 37369 and ODA (SP18-0002 and PP18-0009)
SCH#: 2019011044
Dear Eric Ceja:
The State Clearinghouse submitted the above named EIR to selected state agencies for review. The review
period closed on 715(2019, and the continents from the responding agency (ies) is (are) available on the
CEQA database for your retrieval and use. If this continent package is not in order, please notify the State
Clearinghouse immediately. Please refer to the project's ten -digit State Clearinghouse number in f ftire
correspondence so that we may respond promptly.
Please note that Section 21104(c) of the California Public Resources Code states that:
"A responsible or other public agency shall only make substantive continents regarding those
activities involved in a project which are within an area of expertise of the agency or which are
required to be carried out or approved by the agency. Those comments shall be supported by
specific documentation."
Check the CEQA database for submitted comments for use in preparing your finial environmental
document: hftps.//ceqanet.opr.ca.gov/2019011044/2. Should you need more information or clarification
of the comments, we recommend that you contact the commenting agency directly.
This letter acknowledges that you have complied with the State Clearinghouse review requnements for
draft environmental documents. pursuant to the California Environmental Quality Act. Please contact the
State Clearinghouse at (916) 445-0613 if you have any questions regarding the environmental review
process.
Sincerely,
Scott Morgan
Director, State Clearinghouse
cc: Resources Agency
1400 TENTH STREET P.O. BOX 3044 SACRAMENTO, CALIFORNIA 96812-3044
TEL 1-916-445-0613 state.clearinghouse@opr.ca.gov www_opr.ca_gov
A-1
N.
Friday, July 5, 2019 at 11:11:41 AM Pacific Daylight Time
Subject: FW: DSRT Surf Specific Plan transmittal ALUC comments
Date: Friday, July 5, 2019 at 11:09:32 AM Pacific Daylight Time
From: eceja@cityofpalmdesert.org
To: Nicole Criste
Attachments: imageD02.jpg
Eric Cejc
Principal Planner
Ph:760.346.0611 Direct:760.776.6384
eceja Qcityofpa I mclesert_org
From: Rull, Paul [mailto:PRull@RIVCC.DRG]
Sent: Tuesday, May 21, 2019 12:49 PM
To: Ceja, Eric <eceja@cityofpalmdesert.org>
Subject: DSRT Surf Specific Plan transmittal ALUC comments
Hi Eric,
Thank you for transmitting the above project to ALUC for review. Please note that the project is B_1
located outside the airport influence area, and therefore ALUC has no official comment on the project.
However, I wanted to let you know that ALUC is currently reviewing a similar "surf lagoon" project
j2AP1046TH19j in the unincorporated County area of Jacqueline Cochran Airport that is tentatively
scheduled for a public hearing meeting on June 13, 2019. The staff report far this project can be
viewed on the ALUC website here http://www.rcaluc.org/Agendas/Meeting-Agendas about 1-2 weeks
before the meeting. In the report, ALUC staff analyzes a biological wildlife hazard study for the B-2
potential impact of the "surf lagoon" on aircraft via bird strikes. The study proposes several mitigations
measures to help minimize the occurrences of aircraft bird strikes.
The City may find this information useful when considering the DSRT Surf project.
If you have any questions, please feel free to contact me.
Paul Rull
ALUC Principal Planner
Riverside County Airport Land Use Commission
40W L F,mon Stfeet. 141` F Wi
R"mide Ca 92501
195,1955-6893
(9511 955 5177 i NX i
I ' PRVI_L.'�RIVCO.ORG
rwv:v, rr_I.i r2
-------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------
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State of California - Natural Resources Agency GAVIN NEWSOM, Governor
DEPARTMENT OF FISH AND WILDLIFE CHARLTON H. BONHAM, direcror
Inland Deserts Region
3602 Inland Empire Boulevard, Suite C-220
Ontario, CA 91764
www.wildlife.ca.gov
July 3, 2019
Eric Ceja
Principal Planner
City of Palm Desert
73-510 Fred Waring Drive
Palm ❑esert, CA 92260
Dear Mr. Ceja:
3ubjuc;L ❑SRT SURF Specific Plan, Precise Plant, Tentative Tract Map 37359 ana
Associated Disposition and Development Agreement (SP18-0002 and PP18-
0009)
DRAFT ENVIRONMENTAL IMPACT REPORT (DEIR)
SC H#: 2019011044
The California Department of Fish and Wildlife (CDFW) received a Notice of Availability of a
DEIR from the City of Palm Desert for the ❑SRT SURF Specific Plan, Precise Plan,
Tentative Tract Map 37359 and Associated Disposition and Development Agreement (SP
18-0002 and PP18-0009) Project (Project) pursuant the California Environmental Quality
Act (CEQA) and CEQA Guidelines.' C-1
Thank you for the opportunity to provide comments and recommendations regarding those
activities involved in the Project that may affect California fish and wildlife. Likewise, we
appreciate the opportunity to provide comments regarding those aspects of the Project that
CDFW, by law, may be required to carry out or approve through the exercise of its own
regulatory authority under the Fish and Game Cade.
CDFW ROLE
CDFW is California's Trustee Agency for fish and wildlife resources, and holds those
resources in trust by statute for all the people of the State. (Fish & G. Code, §§ 711.7, subd.
(a) & 1802; Pub. Resources Code, § 21070: CEQA Guidelines § 15386, subd. (a),) CDFW,
in its trustee capacity, has jurisdiction over the conservation, protection, and management C-2
of fish, wildlife, native plants, and habitat necessary for biologically sustainable populations
of those species. (ld., § 1802.) Similarly for purposes of CEQA, CDFW is charged by law to
provide, as available, biological expertise during public agency environmental review efforts,
focusing specifically on projects and related activities that have the potential to adversely
affect fish and wildlife resources.
' CEQA is codified in the California Public Resources Code in section 21300 et seq. The "CEQA
Guidelines" are found in Title 14 of the California Code! of Regulations, commencing with section 10000.
Conseming Ca.lifoi-nia's Wildlife Since 1870
Mr. Eric Ceja, Principal Planner
City of Palm Desert
July 3, 2019
Page 2
CDFW is also submitting comments as a Responsible Agency under CFQA. (Pub.
ReSources Code, § 21069; CEQA Guidelines, § 15331.) CDFVV expects that it may need to
exercise regulatory authority as provided by the Fish and Game Code. As proposed, for C-2
example, the Project may be subject to CDFW's lake and streambed alteration regulatory Cont.
authority. (Fish & G. Code, § 1500 et seq.) Likewise, to the extent implementation of the
Project as proposed may result in "take" as defined by State law of any species protected
under the California Endangered Species Act (CFSA) (Fish & G. Code, § 2050 et seq.), the
project proponent may seek related take authorization as provided by the Fish and Game
Code.
PROJECT LOCATION
The Project site is located within the Desert Willow Golf Resort south of Frank Sinatra Drive,
east of Monterey Avenue, and west of Desert Willow Drive within the City of Palm Desert in
Riverside County. The project site area is 17.69 acres in area. The Assessor's Parcel
Numbers (APN) are 620-420-023, 620-400-024, and 620-400-008.
PROJECT DESCRIPTION
The Project proposes the development of a surf lagoon of up to 6 acres in size with surf
center facilities to include restaurant, bar, retail and similar facilities, up to 350 hotel rooms,
and up to 88 resort residential villas, The Project will be implemented in two phases: The
Surf Lagoon Planning Area will include the development of the surf lagoon and associated
amenities on 11.85 acres. The surf lagoon will be a pie -shaped water pool. The Project
would include a wave machine located in the central pier of the lagoon and a mechanical
building at the southeastern portion of the site_ The Hotels and Villas Planning Area will
result in the construction of the hotel(s) and villas on approximately 5.84 acres. The Project
may provide water for the lagoon in one of three ways: a well may be dug of the
southeastern corner of the site; underground pipes may be constructed to connect from the
southeastern corner of the site to the existing Desert Willow well located south of the site
near Country Club Drive; or the lagoon may utilize potable water from existing Coachella
Valley Water District (CVWD) water lines in Desert Willow Drive. The surf lagoon will be
drained to Desert Willow Golf Course Lake, located south of the site between Willow Ridge
and Desert Willow Drive. Existing turf in the Desert Willow Golf Course will be removed and
replaced with desert landscaping in order to reduce the demand for water.
COMMENTS AND RECOMMENDATIONS
The CDFW has jurisdiction over the conservation, protection, and management of fish,
wildlife, native plants, and the habitat necessary for biologically sustainable populations of
those species (i.e., biological resources), and administers the Natural Community
Conservation Planning Program (NCCP Program). The CDFW offers the comments and C-3
recommendations presented below to assist the City of Palm Desert (City; the CEQA lead
agency) in adequately identifying and/or mitigating the project's significant, or potentially
significant, impacts on biological resources. The comments and recommendations are also
offered to enable the CDFW to adequately review and comment on the proposed project
Mr. Eric Ceja, Principal Planner
City of Palm Desert
July 3, 2919
Page 3
with respect to impacts on biological resources and the project's consistency with the
Coachella Valley Multiple Species Habitat Conservation Plan (CVMSHCP).
The CDF1N's comments and recommendations on the DER include:
Project Description C_3
Cont.
The Project Description on pp. 1-2 through 1-6 of the DER lacks a description of the timing
of operation of the wave machines. Artificial water bodies in desert climates often act as
attractants to waterfowl (e.g., Canada geese). If the surf lagoon wave machines are idle for
extended periods, waterfowl may establish residence at the surf lagoon, thereby creating a
potential human -wildlife conflict between waterfowl and surf lagoon customers. CDFW
recommends that the Project Description be revised to include a description of the
frequency, timing, and duration of the wave generating equipment operation. Though not
identified in the Project Description, GDFW assumes that the water in the surf lagoon will be
chlorinated. This information should be clarified, given that mosquito abatement may be
necessary if the water is not treated and is proposed to remain undisturbed for extended C"�
periods of time (for example, when the wave machines are idle). CDFW recommends that
the Project Description clearly identify any proposed mosquito abatement activities, or
describe why such activities will he unnecessary.
Environmental Setting, Impacts. and Mitigation, Biological Resources Section, Subsection
2.4.6 (Protect Impacts) and 2.4.7 (Mitigation Measures)
Subsection 2.4.6 (Impacts) on pp. 2.4-19 through 2.4-21 of the DER lacks a description of C_5
the possibility of waterfowl establishing residence at the surf lagoon during Project operation
when wave machines are idle for extended periods of time. CDFW recommends that a
Contingency Plan be developed and included as a Mitigation Measure in Subsection 2.4.7
to minimize human -wildlife conflicts if waterfowl are attracted to the surf lagoon.
Environmental _Setting, _Impacts, and Mitigation Hydrology and Water Quality Section.
Subsection 2.10.5 (Existing Conditions
It is stated on p. 2.19-8 of the DER that °If required, the surf lagoon water will be treated
before being sent to the evacuation line". The evacuation line carries discharge to the
existing golf course lake. CDFW was unable to locate a definition for "treated" within the C-6
DEIR. Given that the water will be discharged to a lake accessible by wildlife, CDFW
recommends that a definition of "treated" be included in the DER to provide public review
and comment for any potential impacts to fish and wildlife resources. CDFW recommends
that the definition clearly identify how the water may be treated, what would trigger
treatment, and the chemical constituents proposed to be used, if chemical treatment is
deemed necessary.
Environmental Setting,_ Impacts, and Mitigation, Hydrology and Water Quality Section,
Subsection 2.19.6 {Project Impacts]
Subsection 2.19_6 states on pp_ 2.19-18 and 2.14-19 of the DER states:
Mr. Eric Ceja, Principal Planner
City of Palm Desert
July 3, 2619
Page 4
"The Project will provide water for the lagoon in one of three ways_ installation of a
new groundwater well at the southeastem corner of the site; connection to the
existing Desert Willow groundwater well located south of the site near Country Club
Drive; or utilization of the potable water from C VUVD."
Table 2.10-1 (Total Project Water Demand) identifies that the total Project water demand
would be 165.21 acre-feet per year (AFY). However, water savings from a turf reduction
program at the golf course are projected to be 106.75 AFY. The net total water demand
after accounting for the water savings associated with turf reduction will be 58.46 AFY. C_7
CDFW recommends that no new groundwater extractions he implemented, either through a Cont
new well or increased extractions from an existing well. The Coachella Valley has been in
groundwater overdraft for many years and although groundwater levels have been
improving in some areas (due to ongoing groundwater replenishment activities), the
groundwater basin is still, nonetheless in overdraft. Page 42 of Appendix I to the DEIR
(Water Supply Assessment and dilater Supply Verification for the DSRT SURF Project)
states:
"The effectiveness of the Groundwater Replenishment Program has been
demonstrated by rising water levels in the Palm Springs area and by slowing water
level declines in the mid -Coachella Valley portion of Whifewater River (Indio)
Subbasin. According to the 2016 CViWMP [Coachella Valley Water Management
Plan] Status Report it is anticipated that long-term groundwater overdraft will be
eliminated by 2022 in the Coachella Valley with increased groundwater levels in the
Palm Springs area and the eastern Coachella valley... However, grourdwater levels
F.n the mid -Coachella Valley area will continue to decline until programs are
implemented in this area to reduce groundwater pumping."
The Project site is located in the middle section of the Coachella Valley. Although,
projections indicate that groundwater overdraft may be eliminated in the groundwater
subbasin as a whole by 2022, it is identified by the Water Supply Assessment that
groundwater declines are still occurring in the mid -valley area.
Given that the Coachella Valley is in groundwater overdraft, and the Project site is located
in an area where groundwater levels are still declining and/or have been declining in the
recent past, CDFW is concerned that if the Project chooses not to use potable water (i.e,,
water is instead sourced vla the installation of a new groundwater well at the southeastern
corner of the site, or connection to the existing Desert Willow groundwater well located
south of the site near Country Club Drive) reliance on groundwater for this Project would C_8
have impacts to biological resources not identified or analyzed in this DEIR. If the Lead
Agency wishes to pursue the use of groundwater for this Project CDFW recommends that
additional analyses be completed and presented in a revised and recirculated EIR for public
review and comment. As currently prepared the DEIR lacks sufficient information on the
potential impacts of additional groundwater extraction at this location.
Mr. Eric Ceja, Principal Planner
City of Palm Desert
July 3, 2019
Page 5
ENVIRONMENTAL DATA
CEQA requires that information developed in environmental impact reports and negative
declarations be incorporated into a database which may be used to make subsequent or
supplemental environmental determinations. (Pub. Resources Code, § 21003, subd. (e).)
Accordingly, please report any special status species and natural communities detected
during Project surveys to the California Natural Diversity Database (CNDDB). The CNDDB C-g
field survey form can be found at the following link:
http:llwww.dfq.ca.gov/biogeodata,'cnddblpdfs/CNDDB FieldSurveyForm.pdf, The
completed form can be mailed electronically to CNDDB at the following email address:
CNDDBCc_wiidlifexa.gov. The types of information reported to CNDDB can be found at the
following link: htt :Ilvvww.df .ca. ovlbia eodatalcnddlal lants and animals.as .
FILING FEES
The Project, as proposed, would have an impact on fish andlor wildlife, and assessment of
filing fees is necessary. Fees are payable upon filing of the Notice of Determination by the
Lead Agency and serve to help defray the cost of environmental review by CDFW. Payment
of the fee is required in order for tie underlying project approval to be operative, vested, C-10
and final. (Cal. Code Regs, tit. 14, § 753.5; Fish & G. Cade, § 711.4; Pub. Resources Cade,
§ 21089. )
CONCLUSION
CDFW appreciates the opportunity to comment on the DEIR to assist the City in identifying
and mitigating Project impacts an biological resources and we request that the City address
the Department's comments and concerns prior to adoption of the DEIR. In particular we C-11
request clarification regarding the ultimate water source to be used for this project. If you
should have any questions pertaining to the comments provided in this letter, please contact
Charles Land (760) 200-9418 or at Charles.Land@wildlife,ca.gov.
Sincerely,
�a
Scott Wilson
Environmental Program Manager
Inland Deserts Region
ec: Heather Pert, CDFW
Joanna Gibson, CDFW
State Clearinghouse
Ken Carey, US Fish and Wildlife Service
Jenness McBride, US Fish anc Wildlife Service
South Coast
Air Quality Management District
21865 Copley Drive, Diamond Bar, CA 91765-4179
" • (909) 396-2000 • www.agmd.;Sov
SENT VIA E-MAIL AND LISPS:
ECej aLrac ityo fpaltrtdescrt.org
Eric Ceja, Principal Planner
City of Palm Desert_ Planning Department
73-510 Bred Waging Drive
Palm Desert, CA 92760
.1uly 3, 2019
Draft Environmental Impact Report [Draft EIR) for the Proposed DSRT Surf Specific Plan,
Precise Plan, Tentative Tract Mal) 37369 and Associated Disposition and Development
Agreement Proiiect (SP 18-0002 & PP 18-0009) {SCH No. 2019011044)
South Coast Air Quality Management District (South Coast AQMD) staff` appreciates the opportunity to D-1
comment on the above-inentioned document. The following comments are meant as guidance for the
Lead Agency and should be incorporated into the Final EIR.
South Coast AQMD Staffs Summary of Project ❑escriptio
The Lead Agency is proposing the construction of a six -acre surf lagoon. 45.000 square feet of retail uses,
11,250 square reel orrestaurant uses, 150 hotel rooms, and 89 residential units on 17.69 acres (Proposed
Project). The Proposed Project is located on the northeast corner of Country Club Drive and Portola
Avenue. Construction of the Proposed Project is expected to occur in two phases over two yearfi, reaching
full huildout in 2021'_ Phase One of the construction includes the surf lagoon, retail uses, and restaurant
facilities. Phase Two of the construction includes the hotel roc}ins and residential units.
South Coast AQMD Staffs Summary of Air Quality Analysis
In the Air Qufelity Analysis section, the Lend Agency quantified the Proposed Project's construction and
operational emissions and compared those emissions to South Coast AQMD's recommended regional and
localized air quality CEQA significance thresholds. Based on the analysis, the Lead Agency found that D-2
the Proposed ProjecCs construction activities would result in 99.73 pounds per day (lbs/day) of NOx
ernissions', which is slightly below South Coast AQMD's air quality CEQA significance, threshold of 100
lbslday for Nax, after the implementation of Mitigation Measure (MM) AQ-9;. MM AQ-9 requires the
preparation of a dust control managerrteert }plan'. Additionally, the Lead Agency found that the Proposed
Project's operational air quality impacts would be significant and unavoidable for Nax at 116 lbsldayi
during regular operation and 152 lbsldayf during a special event, after the implementation of MM AQ-1
through MM AQ-8'. MM AQ-1 through MM AQ-8 require five percent or vehicle parking spaces to
include Cl.eetric vehicle (EV) charging stations, a five-minute idling restriction, enerLry V1'66Gn1
appliances, street sweepers, and landscaping, light colored raofm& and an employee commute reduction
program'.
South Coast AQMD Staffs Cieneral Comments
South Coast AQMD staff has comments on the Air [duality Analysis and the proposed mitigation D-3
measures. South Coast AQMD stab found that the haul routes identified in the Draft EIR, which were
Draft FIR, Section 2.3_ :IPr pjrulrre,. Pqe 2.3-13.
' Nd..4ppendfx B. DW Seal-.4n GHG Rcporr CrdEEAfod Sz nrorer Rzin. PDF Page 109.
' &d. Page _13-20.
Ibid.
` Mid. Psge 2.3- I h.
{ Ibid.
' Ihid. Page 2.3-20.
k Ibid. Pages 2.3-20 and 2.3-21.
Eric Ceja ? July 3, 2019
used to calculate emissions from haut truer trips during construction, appeared to be shorter than the
distance found in aerial imagery. To further incentivize the use of EVs by patrons visiting the Proposed
Project and to further reduce operational NGx emissions during regular operation and special events, D-3
South Coast A.QMD staff recornmends that the Lead Agency include six percent of vehicle parking Cont.
spaces to include EV charging stations instead of five percent and designate eight percent of vehicle
parking spaces Far clean airvehicles in the Final Ells. please see the attachment far snore information.
Conch>`eion
Pursuant to California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section
15088(b), South Coast AQMD staff requests that the Lead Agency provide South Coast AQN.M staff With
written responses to all comments contained -herein prior to the certification of the Final EIR. In addition,
issues raised in the comments should be addressed in detail giving reasons why specific comments and
suggestions are not accepted. There should be good faith, reasoned analysis in response. Conclusory
statements unsupported by factual iinforxttation will not suffice (CEQA Guidelines Section 15088(c)).
Conclusory statements do not facilitate the purpose and goal of CEQA on public disclosure and are not DA
meaningful, informative, or useful to decision makers and to the public who are interested in the Proposed
Project. Further, when the Lead Agency makCs the finding that the recommended mitigation treasures are
not feasible, the Lead Agency should describe the specific reasons for rejecting, them in the Final EIR
(CEQA Guidelines Section 15091).
South Coast AQMD staff .is available to work with the Lead Agency to address any air quality questions
that may arise from this comment letter. Please contact Robert Dalbeck, Assistant Air Quality Specialist,
at RiMbeckkagrnd.go or (909) 396-2139, should you have any questions.
Sincerely,
ZL S"
Lijin Sun, J.D.
.Program Supervisor, CEQA IGR
Planning, Rule Development & Area Sources
Attachment
L& Ra
RV C 1905 21-lW
Control Numbcr
D-5
Eric Ceja 4 July 3, 2019
Recommended Revisions to Existing Mitigation Measure AQ-1
? The Lead Agency has cotrtnutted to installing electric vehicle (EV) charging stations in five percent
of all vehicle parking spaces at the Proposed Project. To facilitate the implementation of the 2016
California Cir•een Building Standards Code, Part 1 I for nonresidential projects with 201. vehicle
parking spaces or more to include EV charging stations in at least six percent of all vehicle parking
spaces', South Coast AQMD staff recommends that the Lead Agency incorporate the following D_6
changes to MM. AQ-1 in the .Final EIR. Additionally, South Coast AQMD staff recommends that the
Lead Agency include designated parking for clean air vehicles in at least eight percent of all vehicle
parking spaces for nonresidential projects with 201 vehicle parking spaces or more13.
MM AQ-1: At least 56% of all vehicle parking spaces shall include EV charging stations and 8% of
all vehicle parking spaces shall include desi ated parking for clean air vehicles.
Additional Recommended Mitigation Measures
3. CEQA requires that all feasible mitigation measures that go beyond what is required by law be
utilized to minimize or eliminate any significant adverse impacts. South Coast AQMD staff
recommends that the lead Agency review the following recommended mitigation measures for
incorporation in the Final ElR to further reduce construction and operational emissions.
Construction -Related Air Q ziali4y Mitigations Measures
a. Require the use off -road diesel -powered construction equipment that meets or exceeds the
California Air Resources .Board (GARB) and U.S. Environmental Protection Agency (USEPA)
Tier 4 off road emssions standards for equipment rated at 50 horsepower or greater during
Project construction. Such equipment will be outfitted with Best Available Control Technology
(BACT) devices including a GARB certified Level 3 Diesel Particulate Filters (DPFs). Level 3
DPFs are capable of achieving at least 85 percent reduction in particulate matter emissions". A
list ofCARB verified DPFs are available on the CARB website15.
To ensure that Tier 4 construction egLdprrtcnt or better will be usod during the Proposed Project's
construction, South Coast AQMD staff' recommends that the Lead Agency include this
requirement in applicable bid documents, purchase- orders, and contracts. Successful contractors) D-7
must demonstrate the ability to supply the compliant construction equipment for use prior to any
ground disturbing and construction activities. A copy of each unit's certified tier specification or
model year specification and CARE or South Coast AQMD operating permit (if applicable) shall
be available upon request at the time of mobilization of each applicable unit of equipment.
Additionally, the Lead Agency should require periodic reporting and provision of written
construction documents by construction contractor(s) to ensure compliance, and conduct regular
inspections to the traxitnum extent feasible to ensure compliance.
In the event that construction equipment cannot meet the Tier 4 engine certification, the Project
representative or contractor must demonstrate through future study with written findings
supported by substantial evidence that is approved by the Lead Agency before using other
technologies/strategies. Alternative applicable strategies may include, but would not be limited to,
construction equipment with Tier 3 emissions standards, reduction in the number and/or
horsepower rating of construction equipment, limiting the number of daily construction haul truck
''- 2016 California Careen Building Standards Code, Part 11. Chapter 5, Nowesidendat Mandatory Adewvares. Table 5.1W5.3.3,
Page 35. Accessed at; i U7081.
31bid. 'Table 5.1065.2. Page 34. Accessed at: httusLflcodes. icesafe.org:conteyehater/107081.
' California Air Resources Board. Novembes 16-17. 2004. Diesel Qlt-'Road Etpnpnrenr hleasore - Workshop. Page 17. Accessed
at: htws .lwww.orb.ca.govliusprog/ordieseUt}resetttaticntslnov ] 6-U4_workshop.ptl
IS lhitL Page IS.
Eric Ceja 5 July 3, 2019
trips to and from the Proposed Project, using cleaner vehicle fuel, and/or limiting the number of
individual construction project phases occurring simultaneously.
b. Require the use of zero -emission or near -zero emission heavy-duty haul trucks during
construction, such as trucks with natural gas engines that meet CARB's adopted optional NOx
emissions standard of 0.02 grams per brake horsepower -hour (g/bhp-hr). At a minimum, require
that operators of heavy-duty haul. trucks visiting the Proposed Project during construction commit
to using 2010 model year" or newer engines that meet CARB's 2010 engine emission standards
of 0.01 g/bhp-hr for particulate matter (PM) and 0.20 glbhp-hr of NOx emissions or newer,
cleaner trucks. Include analyses to evaluate and identify sufficient power available for zero
emission trucks and supportive infrastructures in the Energy and Utilities and Service Systems
Sections of the Final EIR, where appropriate. Require that contractor(s) maintain records of all D-7
trucks visiting the Proposed Project and make these records available to the Lead Agency upon Conn
request. The records will serve as evidence to prove that each truck called to the Proposed Project
during construction meets the minimum 2010 model year engine emission standards_ The Lead
Agency should conduct regular inspections of the records to the maximum extent feasible and
practicable to ensure compliance with this mitigation measure.
c. Maintain vehicle and equipment maintenance records for the construction portion of the Proposed
Project. All construction vehicles must be maintained in compliance with the manufacturer's
recommended maintenance schedule. All maintenance records shall remain on -site for a period of
at least two years from completion of construction-
d. Encourage construction contractors to apply for South Coast AQMD "SOON" funds. The
"SOON" prograin provides funds to applicable fleets for the purchase of commercially -available
low -emission. heavy-duty engines to achieve near -term reduction of NOx emissions from in -use
off -road diesel vehicles. More information on this program can be found at South Coast AQMD's
website: http://www.agnid.voyliome/Drogiams/business/business-detail?title—off-road-diesel-
engines.
Operation -Relayed Air Qualih, Aftligation Measures
a. Provide incentives for vendors and material delivery trucks that would be visiting the
commercialfretail uses of the Proposed Project to encourage the use of ZE or NZE inicks during
operation, such as trucks with natural gas engines that meet CARB's adopted optional NOx
emissions standard of 0.02 grams per brake horsepower -hour (glbhp-fir). At a minimum,
incentivize the use of 2010 model year". Include analyses to evaluate and identify sufficient
power available for zero emission trucks and supportive infrastructures in the Energy and Utilities D-8
and Service Systems Sections of the Final E.IR, where appropriate.
b. Establish a shuttle bus system to accommodate special events, aimed at reducing vehicle miles
traveled and idling times associated with traffic congestion of visitors of the Proposed Project.
t. Maximize the use of solar energy including solar panels, Install the inaximutn possible number of
solar energy arrays on the building roofs and/or on the Proposed Project site to generate solar
energy for the facility and/or EV charging stations.
"CARS adapted the statewide Truck and Bus Regulation in 2010. The Regulation requires diesel tricks and buses that operate
in Calil'omia to be upgraded to reduce emissions. Newer heavier trucks and buses must meet particulate matter filter requirements
beginning January 1, 2012. Lighter and older heavier trucks must be replaced starting January 1, 2015. By January 1. 2023,
nearly ail trucks and buses will need to have 2010 model year engines or equivalent. More information on the CARS's Truck and
Bus Regulations is available aL ]tttps:llwww.arti,ca.gowr mslrroglynrdiesellpnrdiesel.Iltittl.
1' fhld.
Eric Ceja 6 July 3, 2019
d. Maximize the planting of trees in landscaping areas and parking lots.
D-8
Cont.
Responsible Agency and South Coast AQMD Permits
4. It is important to note that generally, operation of portable engines and portable equipment units of 50
horsepower (hp) or greater requires a permit from South Coast AQMD or registration under the
Portable Equipment Registration Program (PERP) through the California Air Resources .Board
(CARB)'s. In the event that using portable cement manufacturing, aggregate crushing, and screening
equipment of 50 hp or greater is expected at the Proposed Project, the Lead Agency should consult
with South Coast AQMD's Engineering and Permitting staff to detennine if a South Coast AQMD
permit will be required and if compliance with any South Coast AQMD rules anchor regulations ate
required. If a permit from South Coast AQMD is required, South Coast AQMD should be identified
as a Responsible Agency for the Proposed Project in the Final E1R. If the Proposed Project is required
to adliere to any South Coast AQMD rules and regulat1a31s, South Coast AQMD rules and regulations p_g
should be discussed in the Air Quality section of the Final EIR to demonstrate compliance. Any
assumptions used in the Air Quality Analysis in the Final ETR will be used as the basis for permit
conditions and limits for the Proposed Project. Should there be any questions on permits, please
contact South Coast AQMD's Engineering and Permitting staff at (909) 396-3395. For more general
information on permits, please visit South Coast AQMD's webpage at:
ltttp:I/www.agttrd.govJhomelpenmits. For more infor iatlon on the PERP Program, please contact
CARS at (916) 324-5869 or visit CARB's webpage at: httl3s://Wk%i2.arb.ca.gov/our-
worklprogramsJAorta}ale-equipMgDt-registra_t_i on-prograrat-peril,
South Coast Air Quality Manageinent Disirict. Poriable Equipojew Registralion Progra?n (PERP). Accessed at:
http_'h�«�.attmd.gnvli�oine.��+ermit5'c ui mCnt-rCbish-atioi��rerp
E
Law Offices of Jahn A. Belcher
ATTORNEYS At LAW
156 EAsTCOLDRAOQ BOUJLEVAR O, SUITE 215
PASAEMNA, CALWQRNiA 91105
TELEMIONZ (026) 577-5771
FAY. (626) 577-7769
July 3, 2019
Via Email
Eric Ceja
City of Palm Desert
73-510 Fred Waring Drive
Palm Desert, CA 92260
ecqJa@)cityofpahndesert.org
Re: Environmental Impact Report: DSRT SUlT
SCH4 2019011044
Dear Mr. Ceja.:
This law firin represents Save Our Mojave, a 501(c)(3) non-profit organization working
to raise public awareness about some of the most pressing issues facing California's deserts,
including unchecked damage to the environment and wildlife,
Save Our Mojave has reviewed the Enviroiunental hnpact Report ("EIR") for the
proposed DSR I' SUltli Project (the "Project"). 1-he project proposes the development of 6-acre
surf lagoon and surf center facilities (restaurant, bar, retail, and similar facilities) and up to 350
hotel rooms and 89 residential villas on 17,69 ;Acres in the City of Palm Desert, Riverside County,
As described in the DSRT Surf Specific Plan. E-1
The Project will be implemented in two phases. The Surf Lagoon Planning
Areawill include development of a 5.5-acre surf lagoon and surf center facilities
to include restaurant, bar, retail, alai similar facilities together totaling 11.85 acres,
The Hotels and Villas Planning Area wil l include the development of up to 350
hotel roams and up to 88 resort residential villas on approximately 5.84 acres.
Parking facilities throughout the Project will include surface parking, underground
parking, and improvement of an existing off -site parking lot southeast of the
Project site for overflow pa Icing dw•ing special events. Primary Project access
will be provided via two access drives on Dcscrt Willow Drive, and emergency
access will be provided at a third access point at the southwestern portion of the
Eric Ceja
City of Palm Deseil
.luly 3, 2019
Page 2
Project, into the adjacent developed Westin Desert Willow project. In addition to
daily operations, the surf lagoon and surf center will also be capable of E-1
accommodating special events that will attract additional surfers and ticketed Cont.
spectators. The a nber of special events is not currently known, However, for
purposes of this document, it has been assumed that up to one event per month
could occur, for a total of 12 special events per year.
The EIR describes the proposed Project and assesses the potential adverse impacts on the
sul-rounding physical environment, but concludes that the effects could be mitigated to "less-
than-signiticant" levels, or that they are "significant, but unavoidable." After investigation and
After review of publicly available documents, Save Our Mojave believes that the Project does not
adequately mitigate the impact of the Project on the environment and local wildlife, and neither
dues it adequately explore the cumulative impacts ❑f this Project relative to others in the area. E-2
"CEQA does not require tec:hnieal perfection in an EIR, but rather adequacy,
completeness, and a good -faith effort at fill disclosure." CEQA Guidelines § 15003(t). Absent
complete environmental impact analysis of th.e effect on the local environment and wildlife, the
EIR is not a "good faith effort at full disclosure."
Above all, we are extremely concenied about the level of water usage required for the
continuos operation of this Project, The EIR admits repeatedly that the Coachella Valley relies
on groundwater for its primary supply source, and that "the amount of water ua the aquifer has E-3
decreased over the years due to pumping to serve urban, rural and agricultural development in the
Coachella Valley, which has withdrawn water from the aquifer at a rate faster than its natural rate
of recharge," The solution has been to import the majority of die water supply, primarily from
the Colorado River.
C'oaohella Valley's water conservation plans rely heavily on source substitution with the
Colorado River, but the Colorado River is also experiencing historically low levels and drought
conditions. Countless other communities also rely on the Colorado River as a water source, so
this practice is not sustainable in the long term. In fact, the EIR only analyzes and accounts for EA
the water supply through 2040, which is relatively soon. With exponential population growth
expected, and the contuiuing effects of climate change, this analysis creeds to account for a much
longer period of time, The updated Coachella Valley Wuler Monagement Plan even. admits;
E,H0 Ceja
Cily o0alm Dcsert
July 3, 2019
Page 3
There are a number of uncertainties inherent in the dernAIId projections,
including:
Growth forecasts or rates of growth maybe too high or too low
• Impacts of economic booms and busts
• Reductions in fish farm operations E-4
• Rates of developmetlt.on Tribat lands Cont.
• Rate of agriculturallvaeant land conversion to urban use
• Future water demand factors for various land uses
+ Growth outside the Whitewater River subbasin
• Number of future golf courses developed in the East Valley
• Acceptance and effects of water conservation measures
It qukkly goes on to say that "climate change could affect the long terra supplies of both the
SWP and Colorado River and water dernands within the Valley" MWII, Coachella Falley Water
llf anagemew Plan tTpclare § ES-1 b (2012).
Tho Project (even with extensive mitigation) is projected to demand over 19 million
gallons of water per year, around 1,25 million of that lacing loss due to backurash and evaporation
from the pools, spas, and the surf lagoon. If not. for altifieial recharge from other declining
sources, the area would have nowhere near enough water supply for the demand and it is
therefore unsustainable to continue to grow the derna.nd by such great margins. Projects that E-5
allow for such a high degree of wasted resources, i.e. the amount of water lost due to
evaporation, should not be permitted to put pressure an already declining aquifers, This is
especially true when the climate crisis is creating an uncertain future where sustaitrxability and
demand on aquifers are getting harder and harder to predict.
We are also deeply concerned about the impact of the Project on the area's burrowing owl
pr7pulatiun, long-term studies need to be conducted on burrowing owls in the area. Previous
studies are minimal and preoGnstruction surveys, while protecting specific owls in the short-term,
would not accurately represent any long-term effects on local populations,
Western burrowing owls are at risk of going extinct in areas of California, and habitat E-6
degradaation and fragmentation are the most pressing issues facing the species. This project has a
potentially significant impact. As burrowing owls axe ground nesting, there are ahuost no
possible rneth«ds of mitigation, and any amount of disturbance in their direct habitat would
eliminate them. Attempts have been made to relocate burrowing owls in rrt.hel• areas of
California, but the success rates has been inconsistent. Attempts have also been made to create
imitation burrows to attract awls to a new area, but those have also been mostly unsuccessful.
EAL: Ceja
City of Palm Desext
July 3, 2019
Page 4
E-6
Sari Diego Zoo coI7sei•vationists affirm that current mitigation strategies have no provm record of Co nt
success and further research is required into the best methods of mitigation for this species.
Protection of the burrowing owls thcroselve$ is not tllc only relevant factor, as the owls
rely heavily on ground squirrels as a primary source of prey. The Project could also potentially
impact local ground squirrel populations, but this discussinn is absent f3•om the T;TR. l;urtber E-7
sutveys need to be done in order to better understand tkte permanoul direct and indireut inilmcts
on the area ground squirrel population.
The Project will also ivsult in significantly compromised air duality in the area
throughout the construction process, and potentially once the development is completed,
Removal of stabilized soils and biological soil crust creates a destructive cycle of airborne E-8
particulates and erosion; As snore stabilized soils are removed, hlowingparticulates frotn,
recently eroded areas act as abrasive catalysts that erode the remaining crusts thus resul ling in
more airborne particulates.
As stated in the current EIR, development -related NOx emissions would "violate State or
Federal air duality standards for NOx emissions, which subsequently, will substantially contribute
to tic existing ozone violation in the Salton Sea Air Basin." The EIR had already discussed the
cornproniised air quality in the area due to environmoutal and weather factors, admitting that
particulates are often held in the area, creating ongoing air quality issues. The EIR is fact, goes E-9
on to say that even with full implementation of the mitigation measures, the "impacts associated
with operations of the proposed Project at build out will tvmain significant and unavoidable" and
"operational impacts will continue to exceed NQx erniss-ions under the current analysis
methods," A development with this eifcct on emissions is unacceptable amidst the ciu7•cnt state
of'our climate crisis.
The ETR needs to go farther in addressing the spike in greenhouse gas emissions during
the potentially multiple year construction period. Due to the use of heavy construction
equipment, unsafe levels of air pollutants would have an impact on the surrounding community E_10
and wildlife during that time, The presence oftoxic air contaminants during construction is
discussed in relation the sensitive hurnatx receptors, but ignores construction pollutant impact on
wildlife and the ecosystem.
Noise pollution, Elce air pollution, has significant health implications. Construction and
traffic noise are some of the largest producers of noise pollution, Prolonged exposure to noise
pollution can lead to hypertension and heart disease, hearing loss and consequential sleep E-11
disturbances, The surf lagoon is projected to stay open until midnight or 2 AM., and the Project
Eric Ceja
City of Palm Desert
July 3, 2019
Page 5
is projected to hest around 12 special events per year. All of these elements will contribute
heavily to noise pollution in the area. Noise pollution does not only adversely effect human E-11
lives. Wildlife, especially birds, are heavily impacted by increased noise pollution. Cont.
Communication, mating behavior, hunting and survival instincts of animals are altered by
excessive noise,
As written, the EIR also glosses over the aggregate cavironmental impacts of the Project
and misleads the reader through words such as "may" and "potentially." This Project cannot be
viewed independently from other planned developments in the region, The EIR needs to address
the cumuulative effects of the Project in relation to other nearby projects and planned
developments.
The cumulative impact from several projects is the change in the
environment which results from the incremental impact of the project when added
to other closely related past, present, and reasonably foreseeable probable future E-12
projects, Cumulative impacts can result from individually minor but collectively
significant projects taking place over a period of time.
CEQA Guidelines § 15355(b). Water demand, greenhouse gas emissions, noise and air
pollution, and habitat fragmentation are aggregate and have cumulative effects. It would be a
cataclysmic oversight ["or the City to allow the Project to move forward without fully analyzing
this Project's impact in relation to the overall impact of other projects in the tegion t11at are
currently in development or in the planning stages.
For all of the reasons stated above, we oppose the project as currently proposed. The
Project's EIR muss be rewritten to address all the environmental impacts. The current BIR E- j3
misleads the reader as to the true impact of the Project. Only a rewritten and recirculated
cumulative impacts analysis will allow the public to understand the true impact of the Project,
Sincerely,
ohn A. Belcher
F
F-1
DSRT SURF Specific Plan
EIR (SCH # 2019011044)
Final EIR/Response to Comments
Appendix B
Revised CalEEMod Outputs
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9F PgWpa Project SP EvIcir t- 3yed See Ab Been, Summer
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DSFT SURF Processed Project SP Buddout -Satlon Sea Ar Basin, Suer
Pat Characteristics -
tandUse - Arm mature made due In SP over internal Bad AtMHG Word Sir apumaWn crucial
ConsWchon Pba a Auumesa2MarbutIdout
OM1mad EaulgWnt- Numbarnf equpment Increased.
OM1Wtl Bridal -Added Fall handling equipment for axpon Hours WOWed Sam B to ] par day to acmnm for waiter breal¢, retueiirg, malnlenence
am
Trip And VMF-Wpp<pe ewnam haul Mp is 325 miles sell tothe Clam Club ml dumping em
Carol Fugitive Dust - All reads in project area am ceased.
Border -Ewvatin mr the Mgoon will require Wpm. 103.00 CY of el
AWhIY[WMCoal DWo11ow VOCWamgsWSCADMD Rule 1113
VNiak Trys- Pn TrNk Report, All prgbd delytom=SAM. Assurance seme dolllars may a camirg Won greater Assumed, 25 coiled passage parblp
apunN.
Read WY -AI rpb pal
Energy Up- All eMcbHry will W Tqe 24Worried lepaan wave machire and Rolling wumgicrm acWunW br inWpianel Strapping Center'
Cm&meWn DIHpd Seminar Mioral- Standard requirements car SCADMD RUIe 403.1 Dust Caul.
gLroad Equ¢rentHouse per day WducammaWaunt arrwoAerbroads, scandal maintenance etc.
M mad Equipment
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OSRT SURF Proposed PmIM SP Buddout - Salon Sea Air Basin, Summer
2.1 Werell Conalmcllon(MWmum Dally Emission)
Ilnmmneled Conatmcdon
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in
Simon
62im
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is
CalEEMM Vanbn: CBIEEMOE.20183,2 Pi7WM OMe'.]r8201 B 2Q PM
OSFT SURF PropseE Pi SIP BuiIE001-$amen Sea Air Hawn, Summer
am
awic
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mat
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peas
Moore
Manuel
pms
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we
a
"M
caft
mar
i
CalEEMW Verson: CalEEMod2016.3.2 Pate 8M35 Oae: 7AA%M 2.0 PM
OBflT BUFF Proposal Frame SIP BullEout- Salton Sea Fm Hawn, Summer
22 Warall CperoUanal
UnmlBonrel Onentionel
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Pi
Par
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I
ow
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W
a�
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MAN 51
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CalEEMM Varebn: CWEEMM.2016.3.2 Page 9N35 Gate J7AV2DI9249 PM
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Ph ... naps
Shaheen, She Due,
lNenceee
Acres of GMOIrg (Sip PrypeR110n P6asa):0
Acres o1 Gracing )GrMing Plasmas): 17A
Acres of Paving: 4.51
Pesidenflal Indoor: 0: Residential OuMoq: O: XOnlWppnWl lnpWn WM; MOniINIdNW OubWr: MIN; SelpaC Passing As
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OMPnntl Foutoment
C EEMW Verson: CalEEMod.2016.3.2 Page 10 of 35 GMi 7AuNI92.0 PM
OSFT SURF Proposed PmIW SP Buddout -Satlon Sea Air Basin, Summer
Cali Vanbn: CBIEEMWS01832 Page 11 o135 OMr719201 B 2Q PM
DEBT SURF Prop ead Pi SP Baildoal- Seem Sea An BYin, Summer
3.1 MBlgatlon Meavu me Constructlan
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Use sou BtaSuner
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3.2 See Preparutlon.2019
UnmMnl Construction On -Sifts
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W
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ram
t
nArb•
CzdEEMW Vernon: CalEEMod201S.3.2 Page 12 o135 CMB: 7AAi 2.0 PM
CBOT BUFF Proposed Profed SP Bullaout- Salton Sea Air Hawn, Summer
3.2 SXe Preparal -MIS
anrumoeted Canstrunlon Off -She
Pan
Me
TbW
Pass
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.nesor
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CMEEMM Vernon: CelEEMod.2016.3.2 Page 13 o135 Dark, 'JAV2DI92Q PM
Us A,r Bailin,&mior
3.2 San Preparation.2019
MMOXe6 Connlruelon OXS6e
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ems
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we
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areem
CaIEEMW Vernon: CalEEMod2016.3.2 Page 14 o135 CMe0A20192.0 PM
CSRT SURF Proposed Project SP BUOEOW -Satlon Sea AS Basin, Summer
3.3 Grading- 2019
unmmaaled Canelmallan On -she
INN MID
TM]
Ness;
INN
mew
'mN
Mi,
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I'll,
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DSST WRF Pressed PmjM 6P BaiIE0a1-6eXOn Sea sir Brain, Summer
3.3 Grading -2019
NMOXed Cgrisig ign OXSXe
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Me
red
ve
Me
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less
ens,
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lem
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3.4 Paving -W19
UnmMeMed Cena1rve11nn Ori
all
Tld
ever
sley
CaIEEMod Verson: CalEEMod2016.3.2 Page 16 of 35 OaM: 7M20192.0 PM
OSRT SURF Proposed Project SP BUIIdout -Satlon Sea Air Basin, Sumner
3.4 Paving -2019
Unmmneled Canslmelnn On -she
WHO
NM
M
I &M
slaves I vessel
Fee Me
Me
TAW
names
Plus
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I
an
an
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else
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w
all
am
CMEEMon Vanbn: 0WEEMM.2018.3.2 Page 17 o135 Oi 7AM 11132AS PM
3aa Air Hawn, U rnmer
3.4 Paving -2019
MMor ed ConiUmen on OBSXe
Nar
pull New
Ted
mi
Paul
Traw
law
5102
3.4 Paving -2020
UnmMntleE Construction OwSlb
MWID
Two
pi
oilia,
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river
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wrown
new
22M.735122077331 WHO
1
CudEEMW Verson: CalEEMod2018.3.2 Page 18 or 35 OaMO92o192.0 PM
OBBT BUFF PmWwd Pmfect SP BullEout- Salton Sea Air Hawn, Summer
3.4 Paving - SON
Bnmmnneh Canetmnion On -She
.Verner
IV*
I i
'ame
,ere
,ae
,aw
ae,
'i
ivae
'al,
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ei
oir000�
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MAKWO Value
were
Cali Vanbn: CalEEMW.20183,2 Page 19 o135 OMr74120192Q PM
DSFT SURF PropoaBd Pri SP Boildool-3BXon 3Bo Air BYin, Sommer
3.4 Ruling -2020
NMOXed Conalnrel on OXSXe
pull pi
Inew
laws
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mene
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'ere
',we
: law,
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wee,
law
Me
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3.5 Building Construction - 2019
Unmanned Construction or.sln
Pi
Tim
arm
3
CaIEEModVerson: CalEEMod201S.3.2 Page 20 o135 Dean O920192.0 PM
SEAT BUFF Proposed Pme t SP Bulldout- Sallon Sea Fb Hawn, Summer
3.5 Building Construction- 2019
Unmmonnd Construction nnaXn
Fall
MID
TbW
IFIVA
Falls
'wee
raw,
'ma
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ew,
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we 'w"
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I
CMEEMM Version: CelEEMod.2016.3.2 Pe9e 21 o135 OM'JAW2Dl B 2Q PM
Us A,r Run, &mior
3.5 Building Construction - 2019
seemed Conciructon OXS6e
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less
Ties
me
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"wg
'em
'ene
sees
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ism
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ows
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3.5 Building Construction - 2020
Ilnmenmed Construction On61tl
Exhim
Pull
me
Tld
I
uses
LANY me
CWEEMWVeraon: CalEEMod2016.3.2 Page 22 o135 CMe: 7920192.0 PM
CSRT SURF Proposed Project SP Buddout -Satlon Sea iur Basin, Sumner
3.5 Building Construction- 2020
unrueemed dnnstruminn 0641hn
.esevy
my
me
PMII Russ
Tna
Real
Makes
Fm
Celli Inner: CeIEEllow 8.3.2 Pepe 33 o135 Dow, 78201 B 2AS PM
3Be Air CBein,&mior
3.5 Building Construction- 2020
NMwead Cgr igRact on OBSXe
are
lower
pull,
ors,
"we
Meaw
Men,
'we,
oxi
won More
warl
wrow
0�3M
warl orrow
wear
3.5 Building Construction - 2021
UnmMamw Censtmellon OnMtl
Mae
Tim
CaIEEMW Vernon: CalEEMod2016.3.2 Page 24 or 35 Cift7Al 1g 2.0 PM
oSBT SURF Propose! Protect SP Buildout- Salton Sea Air Hawn, Summer
3.5 Building Construction- 2021
Bnmldoatnd Cnnstmmnn OMane
wall ran
Tile
�A
new
'wee
raw,
Mw,,
'Min
'aw,
Mm, 'Maw
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ai
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CMEEMod Vassal: CelEEPRAM16.3.2 Page 25 o135 Oole oaten B 2Q PM
Us A,r Baein,&mior
3.5 Building Construction- 2021
MMage Conciructon OBS6e
pull
News
mared
Plus
Onat
awls
Islas
owls
l�l
mime
d wwwl
3.6 Arc0itectural Coating -=1
UnmMeMed Censor ctlnn OnBltl
when
MHO
EAAAM
Malawi
ma -cam
NSA awi�esai
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an
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win
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I
I
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CORSI Vernon: CalEEMod2016.3.2 Page 26 o135 Date:. 7920192.0 PM
CSRT SURF imposed Project SP BuiIEOW -Satan Sea ar Basin, Summer
3.6 Architectural Coating -2021
Unwanted Construction O64ide
IWO nine
law
New
new
I
.ween
ease
will
'wil
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nm
mw
loss
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wn,
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nwily
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Cali Vormi CalEEMW.20183,2 Page V of 35 Offi r7m201 B 2Q PM
0SRT SURF PropoaBE Pri So BuilEwl-3BXOn Sea Air BYin, Summer
3.6 Architectural Coating -M21
M Jaawd Conctmct on OBSXe
pull pi
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4.1 Mitigation Measures Mobile
CalEEMWVeraon: CalEEAW.2016.3.2 Page 23 of 35 Daft IWANH92.0 PM
DSRT BUFF Proposed Field SP Bullaout- Salton Sea Fb Hawn, Summer
0.2 Trip Summary Information
Iiii
Suellen
4.3 Trip Type Information
CalEEMoa Vanbn: CBIEEMM.20183,2
Page 29 of 35
Date7r8201 B 2Q PM
03FT SURF Pmpesid PmjsO SP BuiIE0u1-Seem
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5.1 MRIgMInn Means Energy
CalEEMW Vernon: CalEEMW.2016.3.2 Page 3o of 35 OMe:79 192:49 PM
OSRT SURF PmgamE Project SP BuIIEout - Seem Sea Nr Basin, Summm
CMEEMos Version: CWEEMM.2016.3.2 Pepe 31 o135 Deal 'J1129192Q PM
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same
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Me
m
NO
Use
aim
17
1
WEWod Vernon: CalEEMod2016.3.2 Pegs 32 o135 Case? o192.0 PM
OSRT SURF PmpaaaE Pmlac1 SP BuOEout -Satlon Sea Nr Basin, Summer
5.2 Enegy ey Land Use- WtunlG s
MW9Mffi
oom
oam
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Came
OWN
OWN
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Use
WON lives
Unix
Own
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I
11;=7
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6.1 MHIgHIon Measures Area
Ca EEMoo season: CBIEEMOE.20183,2 Page 33 of 35 Dole '.]r820192Q PM
DMT SURF Proposed PryjM SP BuiM0u1-gotten See Pir Bain, Summer
re" ftn'
Tee
014
she
Out
6.2 Am by SubGtegory
Lbm Scaled
Fees
NON
On
No
Rates Issues
PMe
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NM�=jTceJCQa
OR
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rein
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CWEEMWVersson: CalEEMod2016.3.2 Page 34 of 35 OMe: 7920192.0 PM
OSTIT SURF Prepared Project SP BuildoW -Saber Sea fer Basin, Summer
6.2 Area by SubGNgory
Finessed
Funa new
new
year
PM25
�Uruisapy
ease,
se
sa
we
ea
7.0 Water Detail
7.1 Mitigation Measures Water
8.0 Waste Detail
6.1 Mitigation Measures Waste
9.0 Operational 011roa0
10.0 Stationary Equipment
CalEEMM Vernon: CWEEMM.20183,2 Page M o135 OMe'. 7A20l B 2Q PM
OSRT SURF Preprad PmjM So Boill -SaXOn Sea an Brain, Summer
FPApmniyre FWTpe
Boilers
Fqupmmirye as FytYq WMespol
User MIrnE Eculement
Eqlassui wi
11.0 Vegetation
CaIEEMW Vernon: CalEEMod2016.3.2 Page l of US Bea: 9ry20192.0 PM
Di SURF Proposal PmjxISP Bull Salton Sea tur Basin Winter
DSRT SURF Proposed Final SP BuilUoul
Saeon Sam Me Bain, Winer
1.0 Project pleraclalatics
1.1 tare Usage
1.20Mer Project Chile whe Was
uwna.mn seen
were syxe li aA
liafteffil Free dpl m
unrvycempam sauamm cwmrsulem
7024
M o.oxa
owre
assa lnry
initia rl
I"iUry
1.3 User Entere l Comments & Non
-Default Data
GBIEEMM Vora n: CalEEMW.201832 Page 2N36 Dow 7412DI B 2AS PM
DSRT SURF Proposal PnUwSP Buil-Seltion Sea Air Deain, what
Project Cnarwmmnw-
Deal - Aesumpansmneenuaa SP Irval InlmmWon.SwaA=HGmponare mmancresmdwn.
Cdnstrpmananeae- Assumes a ayesr Without
CMroWEquipment Numbermesqupment iressaetl.
CMroWEquipment Added wernal handling equipment or mroel Hours school Irom 8 to) Far day to auarri he vwker arenas, refusal Maintenance
Nc.
Tale and VMT-sheen caw consumer haul Res is 325 mils mM to the Claetic Club answered dumping site.
Grvmtl FughM Dealt ' All cards In project area am paint.
GrWN-ErcavelM for the agenda will require approx. IStISS0 CY W whom.
Phantasmal COWrp - Law 0low VOC coatings per SCAAMD FUM 1113
Vehicle Thp. Px Traft Real IOIM project daily Mpe. 54%. bananas same riaWre may We Mirghpnp rdat % 25 miles avereae pxeje
Mutual
Road Oust All made paved.
Energy Ilse All electricity will se TMe 26 dowward. Lagoin wave machine and IightigauumryYMs eosunad be in 'Regional Canter.'
ConstrucWn Og-raWEquipment MXYytian Standen! requtremena Por 3CAGMD Rule 000.1 Died CdnMI.
Or roodEquipment- Hours per day reduced to account for rgker Mws, heWeling, malntenana etc.
gFmW Equipment.
Cinica Equipment. Hour per day reduced iFm 3 a] a account kewshor draw Wallin, maabrKnte aft
CadEEMWVerman: CalEEMW.2016.3.2 Page 3a135 DMe:J920192:46PM
DSRT SURF crowded Project SP bulkdN $elan Sef Nr Petln, Wlnta
CeIE Voisin: CWEEMM.2016.3.2 Pgei N36 Oab'.]r8 1 9 2 Q PM
DSRT SURF ProrywE P1ege1 SP BUiMM-Se6m6 Nr Bern, Wi"
dinner
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C EEMW Vermin: CalEEMW.2016.9.3 Pe9e5M35 DMe: 794M92.0 PM
DSRT SURF Pw;imen Pmnt SP 9 Wmt SeXm Sef Nr Betln, WIMer
CMEEMM Vornbn: CelEEMa1.2016.3.2 Page 6DIM DM, 7AID1132Q PM
CSPT SURF PrOryYE ftsO SP &IiUON-Sa6M 6NNrCyIq V inum
2.1 Overall Construction (Maximum Daily Emission)
Unmti ma construmon
a
Is
DIM
WHO,
main
DIM
Dome
�sims
14xM
I,wn
1�
2m"
WWW IxII&M.19IMM.
1,max[
WWWD
W.maD
CWEEMW Verson: CalEEMW.2016.3.2 PaSe 70135 Dula O920192.0 PM
D6R16URF Pragaea Pmleci 6P 9uldout 6Mm Sea Nr Eaeln.Wlmr
Cadi Vessel OWEEMa1.2016.3.2 Page 8 of Oeft 7 11192Q PM
OSRT SURF Preryad Prima SP BuiUON. Salim 6NFir B6eln. Winer
20 Overall Op ionel
unm6omw Operational
MID
MID
Towl
we
as
an
am
Ism
mar
Ism
mar
mi
sum.
Italian
low",
lia�4 Dwd w� o� 4 MID*
Tlwl
Iowa
wall
"(flaw:41i awl
:Wilmal
CalEEMod Version: CalEEMod.2016.3.2 Page 9of35 Oe1e: lugui 2.0 PM
OSRT SURF Pmpolced Pmp ASP SulNmt Salton Sea Air Basin Winter
IM
Pawl
Palo
MID
liked
low
Raw
I =
l�=INR�lT�=1
0.0 Construction Oeteil
Cons�tim
Phase
Wei
i wo, End DM
N. Was Press Deviation
Rorea W GMIN Ugh, Praparatlon Panama 0
4na o1 Gra0ing (Gra Ping PM1ges ITS
Amrds of Pawl": 4.61
RmiftnWl In600r: 0; Residential Outdoor: 0: No,-F!"Wenpal indoor: 834A75: NomRrolOential Outdoor: 2761251 Striped Parking Gres
16.400(Amh6 unl""ng—agf0
O and 5nuimmt
CalEEMM Version: CWEEMM.2016.3.2 Page 10 of 35 Enter 7AR2D19246PM
CSPT SURF Proposed ProsO SP BuiUout-Se6M Sea FirONIn, Wirier
--------------
CMEEM Verson: CalEEMod.2016.3.2 Pe9e IIW35 OMeO920192.0 PM
USAT SURF Pra{vetl Project SP SUIkoN $Mm Sea Nr Paeln, WIMa
3.1 MXIgamon Meaaurs Cnnstrucam
Use Cleaner Engine for CenstruNon Equlpmnt
Use SOII Sro611ker
Water apseW Area
3.2 Site Prepandon-2019
Cni
'"IV
beer
CnEEMM Venbn: OnEEMOJR018.3.2 Page 13 o135 DMe'Jr8 aD192Q PM
DSW SURF ProryaE PmIBn So Full -SaNm See Fir OUIn, Wiener
3.2 She ProRaretion.2019
UnnMonea Donelran on Gns9e
Nom
el
i
Pat,
wil,
Owes
oxam, move,
Visa,
—0�
�o� Visa,
mocce
MID
set
CEEMWVereon: OWEEMod2016.3.2 Page 13 or 35 Feet 741 192.0 PM
DSK SURF PropamE Prep13P SUINm1 Salton Sea Nr Basin Wli
3.2 See Prepantlon -2019
MMeMeE Conalrvnllnn OX3ne
make
I
oi
am
3.3 Grading -2019
Ca EEi Verson: CoWEEMM.2016.3.2 Page 10 o135 DMr719san 92Q PM
DSFT SURF ProryaE Project So Pulsed. Salim 6N Fir Ron, Wiener
3.3 Grading - 2019
MomMe l consln,n on 911-s6e
coalso
low
Milo
: 1 asse.
also
Os"l,
1 Mass:
seem
loans: im�:
seem,
low
alum
dreas
l�
Ism,
less,
Lou
I'm,
'im,
ell In sla asides
Im,
FII
Poll
Noe
GO
IM
F.
loss
so
da
one
To
Lt,5
TWO
loll
wily
asse,
sui
Ills,
",
+
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r
.
� Vim.
- . „�.
CWEEMW Vernon: C@IEEMod2016.3.2 Page 15 o135 Deb: 9ry20192.0 PM
DSRT SURF PmgamE Pmp ASP Bull Salton Sea tur Basin Winter
3.3 Gratling- 2019
MMeMtl Candruction0l
anness"Inseace"I
an
ass
sesses
are on
To
Role
MGM
To
I
I
.mrselly
low
0 mis camor
alow
0 wal
rose son
loss
low,
saw
�:amxxr
(LOGO loan
ease
an
we
cm
3.4 Paving 2019
Unmumnrm Construction
rise
CMEEMon Vanbn: CnEEMM.2016.3.2 Page 16 of 35 Deb'Jr82D192Q PM
DSW SURF ProryaE Pmlan SP BuiUON. Salim Sant Fir CUIn, Wimer
3.4 Paving -2019
O omMone6 Donalmn on Dn-96a
pull Palo
mwv,s
Palo
TV1
QdEEMW Verson: C@IEEMW.2016.3.2 Page 17of 35 Date:. 792o192.0 PM
DSW SURF Pmpaced PmIeN SP SuikoN $Nm Sea Nr Baeln. WIMa
3.4 Paving -2019
MMeMtl Ennalrvnllnn OX3Xe
3.4 Paving -2020
CMEEMM Version: COIEEMM.2016.3.2 Pae18 o135 Dow 7AIDI92Q PM
DSW SURF PrOryaE Pmlen SP CuiUoN. Salim 6N all CUIn, Wiener
3.4 Paving -2020
UnnMone6 Donstro n on Dg-s6e
pull wall
law]
Floa
nw,s
law]
flow
RAW
Tll
way
DWEEMW Verson: CalEEMod2016.3.2 Page 19 o135 DMa: 7920192.0 PM
DSW SURF Pra{ved PmIeN SP SuikoN $Nm Sea NrSssln. WIMa
3.4 Paving - SON
MMeMtl Ennalrvnllnn Cn3ne
Fall
RAW
Taft]
I Fall
I Paul
I
.wally
I
amay
wall
ow
all
we
3.5 Building Construction -2019
clWay
allay
CMEEMod Version: CWEEMM.2016.3.2 Pepe 30 o135 Done7A20I 92Q PM
DSW SURF Proposed Pmlen SP CuiUoN. Salim Slut Fir Coln, Wiener
3.5 Building Construction - 2019
unmMoned Donstmn on on -she
pull
RAW
Runs
Plus
Mull
Tlo
CWEEMW Verson: CalEEMW.2016.3.2 Page 21 o135 )Me: 790192.0 PM
DSIRT SURF Pra{ved Pmlen SP Suildout SNm Sea Nr Bash.WIMa
3.5 Building Construcgon- 2019
MMeMW Canstmnnnn Cn3Xe
3.5 Building Constnidion-2020
CIWI
CMEEMon Varel CBIEEMOE.201832 Page 22 o135 Dele'. 71120192Q PM
DSRT SURF Proposal PrpjM3P Buil-3e00n See Tir Seen, Wlnler
3.5 Building Construction . 2020
UnroMOMed DonstruM on Dd-Bge
pull
rare
1,u
Face
Pull
busy
CaIEEModVerson: CalEEMod2016.3.2 Page 23 o135 Oraw 7920192.0 PM
DSRT SURF Promoted Project SP BuikoN $Mm Sea NrSssln. WIMa
3.5 Building Construction- 2020
MMoMtl Construction OX3Xe
MWO
Mae
now
Pull
Paul
near
3.5 Building Construction - 2021
CMEEMon Varel CBIEEMOE.201832 Page 20 of 35 Dde'. 74120192Q PM
DSRT SURF PNpyM PmjM3P Buil-Salton Sea Tir Seen Wlnler
3.5 Building Construction. 2021
UnmMOMae Donstmaton Ql
pull MIN
lue
name
Im,
2110
lane;
Pull
0"19
Imm O�
out;
lows
ONIG
Imewl
anING:a1mom: &Ive,
%asm
OWN
T'w
blue
CalEEMWVereon: CalEEMod2016.3.2 Pate 25 of 35 Oate: 7920192.0 PM
DSW SURF Pn{vetl PmIect SP BuikoN $Nm Sea Nr Baeln. WIMa
3.5 Building Construction- 2021
Metal Construction Ol
Pull MID
Town
Met
Pull
WON
NORP
18 Architectural Coating -=1
Unmulnarm Construction
CMEEMM Voral CelEEMM.2016.3.2 Pepe M o135 Uses, JRrz11132Q PM
DSW SURF PmryaE Planet So Buil-Salim 6N Air Basin, Wiener
3.6 Arc6itecluml Coating - 2021
IInmMOMW Conga on OX Kss
pull Pass
new
i
i
"i
see,
'IN,
sees
emes) sew,
sees
O= �am
(NO, less, (NO
seen
agii�'
less
IN
^]
C
MIN
S
MIN
Axnsittai
m........
......E—.�
..�
sell
ON,—
_
� ..: �. �.IN
CMEEMW Poison: CalEEMW.2016.3.2 Page 27 o135 Ceb: I'Mull 2.0 PM
OSRT SURF PMgamE Prop 13P Bull Salton Sea tur Basin Winter
3.6 Architectural Coating -RMI
MMeMe l Ennstrvnllnn OX36e
Pass
MID
Tmj
�A
Miles
I
New
Oixem
seen
oess,
amess
Islas
sees
avess
00m, less
i
0.1 MHIgHIon Measures MOCM
CadEEl Vernon: DelEEPAW.2016.3.2 Page 39 of 35 Use'JAR2DI 92AS PM
DSW SURF PmryaE Protect SP Buill-Salim Sax Fir Base, Wiener
I'll Poll
see
pi
Tall
4.2 Trip Summary Information
ea TnpTyperldon Mon
C EEMW Vernon: CalEEMod2016.3.2
Page 29 of 35
Deb: 9ry20192.0 PM
DSFT
SURF PmIWWE small
Salton Sea tur Basin Winter
M
bm
UWy
Esti In
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IS.N
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WS
enxael Puwgnm sewer;
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Oreal oowaal
..
a.0418WO
lien tineauil%li dun
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swissesewn
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ocenam owl
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t �
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Hill Eneyy Use
5.1 Mitigation Memories Emryy
Ca EEMoa Version: CBIEEMM.20183.2 Pope 30 of 35 Oels,'. 7R201 B 2Q I'M
OSRT SURF Proposal Projeal BuiMWt-Salton See air Bass Winter
M"
Tee
CaIEEMWVoreon: CalEEMod2016.3.2 Page 31 of 35 Ceb: 7920192.0 PM
OSRT SURF Prop ea Propel Saki Salton Sea Nr Basin Winter
5.2 Energy by land Use- W WnlGess
LRmWaelm
OASCO
same
al
4161
sees
00=
small
Was
sees
wi
same,
assets
ease
seas
came,
asele sees
ease
'eso
',im,
Call Vorabn: CBIEEMM.201832 Pose 32 o135 Dom,71SW B 2Q PM
FIRST SURF PrOPyM P 000n SP Buil-SallOn Sea Air Basin , Winter
5.2 Energy 4 Und Use. Natural
g
MID MID
TM
mos
Me
.mdul
am,
Use
Done
som)
Defto
Dome
mlo�
DOW : Dome
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000))
81
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a 0000)
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(ow
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Dome
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me
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6.1 YNlgeu9n M606un6 Am
WEEMWVereon: C@IEEMod2016.3.2 Page 33 o135 CM:. 7A20192.0 PM
USAF SURF Proposal Prop ASP Boil Salton Sea liar Basin Winter
MID MID
MI
Ulm
DM,
62 MN 6y SAI(RdWil
11omIV�L
cams
Mmel
Diane
Imm,
aim
lam,
name,
men,
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mo,
"M "M 7,000"
Down
MID
CMEEMoa Vanbn: CBIEEMOE.20183.2 Page 30 of 35 Oele'. 718201 B 2Q VM
OSRT SURF Pmpuetl PnUa tSP Buil-Salton Sea Tir Seen Winter
6.2 Area by SubC togory
Mutated
Plan' Pull
new
Pan
zwx�espxn
asset
loss
7.0 Water Oelall
7.1 Mitigation Metal Wabr
8.1 faitiBatien Measures Waste
9.0 Operational Offroa0
mam Tyw I Hl I Iwmoq I Il 77-1
CaIEEMW Verson: CalEEMod2016.3.2 Page 35 of 35 Deal 7920192.0 PM
CSRT SURF Proposed Pmlect SP Suil SMm Sea Nr been. Winter
ewFnenrypeml xenwsy bmtFachm Ful
Boners
wama..9. Al H,mm,,l I..reaay.a BaiTyw
veer owaaa Eastman!
w.w rtTW N.
11.0 Vegetation