Mammoth Lakes City Council
July 6, 2022

Resolution TC 22-_____

source reduction programs; storage areas for collected recyclable materials, and disposal of hazardous waste materials used on-site.

CULTURAL RESOURCES

5.11-1e: In the event that a material or potential cultural significance is uncovered during grading activities on the project site, all grading in the area of the uncovered material shall cease and the project operator shall retain a professional archaeologist to evaluate the quality and significance of the material. Grading shall not continue in the area where a material of potential cultural significance is uncovered until resources have been completely removed by the archaeologist and recorded as appropriate.

5.11-2: If human remains are discovered, work shall cease, and an appropriate representative of Native American Indian Groups and the County Coroner shall both be informed and consulted.
(END)

ADDENDUM TO THE NORTH VILLAGE SPECIFIC PLAN

ENVIRONMENTAL IMPACT REPORT
Limelight Hotel
June 21, 2022
Lead Agency:

Town of Mammoth Lakes
437 Old Mammoth Road
Mammoth Lakes, CA 93546
Contact: Ms. Kimberly Cooke
Senior Planner
Phone: (760) 965-3638
Email: [email protected]

This document is designed for double-sided printing to conserve natural resources.

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
i June 2022

TABLE OF CONTENTS

1.0 Introduction ...................................................................................................................1

1.1 Project Location and Environmnetal Setting.........................................................1

1.2 Previous Environmental Documents ....................................................................4

1.3 Project Entitlement History...................................................................................5

2.0 Description of Project Modifications............................................................................9

2.1 Addendum’s Purpose and Need ..........................................................................9

2.2 Location of Project Modifications........................................................................10

2.3 Components of Project Modifications.................................................................10

3.0 Environmental Assessment........................................................................................15

3.1 Land Use ...........................................................................................................15

3.2 Population and Housing.....................................................................................16

3.3 Aesthetics/Light and Glare.................................................................................16

3.4 Traffic and Circulation ........................................................................................17

3.5 Air Quality ..........................................................................................................19

3.6 Noise .................................................................................................................22

3.7 Geology, Soils, and Seismicity...........................................................................24

3.8 Hydrology and Drainage ....................................................................................26

3.9 Biological Resources .........................................................................................29

3.10 Public Services/Utilities......................................................................................31

3.11 Cultural Resources ............................................................................................31

3.12 Energy ...............................................................................................................32

3.13 Wildfire...............................................................................................................33

3.14 Hazards/Hazardous Materials ............................................................................33

4.0 Determination/Addendum Conclusion.......................................................................35

5.0 Addendum Preparation Sources/References............................................................36

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
ii June 2022

LIST OF EXHIBITS
Exhibit 1-1 Regional Vicinity ..................................................................................................2 Exhibit 1-2 Site Vicinity ..........................................................................................................3

LIST OF APPENDICES
A – CEQA Limelight Conformance Checklist
B – Mammoth Hillside Mitigation Monitoring and Reporting Program

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
1 June 2022

1.0 INTRODUCTION
Limelight Mammoth LLC (the Applicant) has requested approval of a Tentative Tract Map, Use Permit, and Design Review application to develop a 185,754 square foot, 166-unit condominium hotel (herein referenced as “Limelight Hotel”) at the Mammoth Hillside site within the North Village Specific Plan (NVSP) area. The Mammoth Hillside site has current entitlements for a 193-unit condominium hotel (considered as Phase 1). As part of the entitlement process for Phase 1, the Town of Mammoth Lakes (Town) approved an Addendum to the North Village Specific Plan (Mammoth Hillside Addendum) for the purpose of the California Environmental Quality Act (CEQA).

The Town of Mammoth Lakes has determined that the Limelight Hotel Application is consistent with the Mammoth Hillside Project considered as part of the Mammoth Hillside Addendum (refer to Appendix A, CEQA Limelight Hotel Conformance Checklist), with the exception of a proposed renewable direct use geothermal system to offset use of other fuels for building systems (such as heating/cooling, water heating, de-icing, etc.). As such, the new geothermal well system (Modified Project) is the subject of this Addendum.

1.1 PROJECT LOCATION AND ENVIRONMENTAL SETTING
The Limelight Hotel is located in the Town of Mammoth Lakes, which is situated within the eastern portion of the Sierra Nevada Range, in southwestern Mono County, California. Regional access to the town is provided via U.S. Highway 395, which is approximately three miles east of the town.

The town is served primarily by State Route 203, which acts as a connector to U.S. Highway 395; refer to Exhibit 1-1, Regional Vicinity. The site is also located within the northwestern portion of the town, at the northwest corner of Canyon Boulevard and Lake Mary Road; refer to Exhibit 1-2, Site Vicinity.

The project site is currently vacant and vegetated. The site is designated by the Town of Mammoth Lakes General Plan (General Plan) as a Specific Plan (NVSP) and zoned by the Town of Mammoth Lakes Municipal Code (Municipal Code) as North Village Specific Plan (NVSP). To the east of the site, across Canyon Boulevard, is lodging and condominiums (8050 Residence Club and Mammoth Fireside), as well as commercial uses (Mammoth Mountain Ski Area gondola building, retail, and Mammoth Brewing Company), all zoned NVSP. To the south are townhomes and condominiums (Mammoth View Villas and the Canyon Ski and Racquet Club), zoned Residential Multi-Family 2. To the west, across Lakeview Boulevard, are condominiums (Mammoth Estates). To the north is the Westin Monache Resort, zoned NVSP.

LAKE
TAHOE
MONO
LAKE

STANISLAUS
COUNTY
SAN

JOAQUIN
COUNTY

CALAVERAS
COUNTY

SACRAMENTO
COUNTY
BUTTE
COUNTY
LASSEN
COUNTY
PLUMAS
COUNTY
NEVADA
SIERRA
COUNTY
NEVADA
COUNTY
PLACER
COUNTY

EL DORADO
COUNTY

AMADOR COUNTY
ALPINE
COUNTY
YUBA
COUNTY

TUOLUMNE
COUNTY
MONO
COUNTY
INYO
COUNTY
MERCED
COUNTY

MARIPOSA
COUNTY
MADERA
COUNTY
FRESNO
COUNTY
5 5
80 80
132
108
104
124
120 120
120
167
270
168
182
120
108
267
193
140
140 165
49 49
41 49
88 16
65 26 4
49 49
49 49
88 88
4 26
12 36
20 20
59 99
99 70
70 89
89 89
28 89
89 33
50 395
395
50 395
Modesto 6
Turlock
Manteca
Lodi
Twain
Harte Angels
Camp
Sonora
Oakdale
Merced
Mariposa
Atwater
Grass
Valley
Roseville

SACRAMENTO
Auburn
Galt
Elk Grove
San
Andreas
Sutter
Creek
Placerville
South
Lake
Tahoe
Coleville
Bridgeport
June
Lake
Mammoth
Lakes
Bishop
Lee
Vining
Minden
Tahoe
City
Nevada Truckee City
Folsum
Reno Sparks
Carson
City
Downeyville
Greenville
Quincy
Mohawk
Chester
Portola
Loyalton
Colfax
Ione Jackson
Ceres
Gardnerville
Project
Site
Exhibit 1-1
Regional Vicinity

NOT TO SCALE
03/2022 JN 188835

LIMELIGHT HOTEL ADDENDUM TO THE NORTH VILLAGE SPECIFIC PLAN

Exhibit 1-2
Site Vicinity

NOT TO SCALE
03/2022 JN 188835
Source: Goolge Earth, 2017.
- Project Site

LIMELIGHT HOTEL ADDENDUM TO THE NORTH VILLAGE SPECIFIC PLAN

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
4 June 2022

1.2 PREVIOUS ENVIRONMENTAL DOCUMENTS
North Village Specific Plan and EIR
The objective of the NVSP is to “create a set of land use designations and development standards which will facilitate the development of “North Village” as a concentrated, pedestrian-oriented activity center with limited vehicular access…development will be oriented toward year-round uses and visitor activity.” The Town of Mammoth Lakes (Town), as the Lead Agency under the California Environmental Quality Act (CEQA), determined that an Environmental Impact Report (EIR) was required for the NVSP prior to its adoption. The Town certified the NVSP Final EIR in 1991.

The NVSP was adopted by the Town in 1991, and has been amended several times, most recently in 2014 for the Inn at the Village project and in 2017 for the Mammoth Hillside project. The NVSP establishes development regulations for approximately 64 acres located around Minaret Road, Main Street/Lake Mary Road, and Canyon Boulevard. The intent of the NVSP is to develop a cohesive, pedestrian-oriented resort activity node, and to provide a year-round focus for visitor activity within the town. The Town, as the Lead Agency under the CEQA, determined that an EIR was required for the NVSP prior to adoption. The EIR was prepared in conformance with CEQA (California Public Resources Code [PRC] Section 21000 et seq.); CEQA Guidelines (California Code of Regulations [CCR], Title 14, Section 15000 et seq.); and the rules, regulations, and procedures for implementation of CEQA, as adopted by the Town. The purpose of the EIR was to review the existing conditions, analyze potential environmental impacts, and identify feasible mitigation measures to reduce potentially significant effects of the NVSP.

The Final Environmental Impact Report North Village Specific Plan (1991 PEIR), dated February 1991, was certified along with the adoption of the NVSP in 1991. In 1994, the North Village Specific Plan Environmental Impact Report Addendum, dated May 1994, was prepared for an amendment to the NVSP, and in 2000, the Subsequent Program Environmental Impact Report for the North Village 1999 Specific Plan Amendment (1999 SPEIR), dated October 13, 2000, was certified for an update to the NVSP.

The Mammoth Hillside Project has had multiple Amendments to the 1999 SPEIR, which include the following:
• Environmental analysis was completed for the Approved TTM project as a part of original entitlements approved in 2006 (TTM 36-235 and UPA 2005-09). At that time, the project was reviewed and considered to be in conformance with the 1999 SPEIR (State Clearinghouse No. 99-092082).
• An Addendum to the 1999 SPEIR was prepared in 2014 in association with UPA 2007-

14. • An Addendum to the 1999 SPEIR was prepared in association with a General Plan Amendment (GPA) and North Village Specific Plan (NVSP) Amendment for a density increase and lot coverage increase on April 12, 2017.

The current certified mitigation measures that are applicable to the Mammoth Hillside project site are provided in Appendix B, Mammoth Hillside Mitigation Monitoring and Reporting Program.

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
5 June 2022

1.3 PROJECT ENTITLEMENT HISTORY
Density and Lot Coverage Transfer from Mammoth Hillside to East Village/South Hotel Site (2004) - In 2004, when both the Mammoth Hillside project site and the East Village/South Hotel site (east of Minaret Road and south of Forest Trail, also in the NVSP) were owned by Intrawest California Holdings, a density and lot coverage transfer was recorded. Through the density transfer, a total of 87.04 rooms were transferred to the East Village/South Hotel site. Through the lot coverage transfer, 14,881.9 square feet of lot coverage was transferred to the East Village/South Hotel site. The density and lot coverage were transferred from 15, 17, and 49 Canyon Boulevard, all of which are in the Plaza Resort zone of the NVSP. The transfer covenants were signed by both Intrawest and the Town of Mammoth Lakes and there were no fees or payments recorded in association with the transfers. The NVSP allows density and lot coverage transfers to be executed though a deed restriction recorded against the properties with the Town as a signatory (NVSP, 2.e.ii, page 37 and 3.a, page 38).

Tentative Tract Map 36-235 and Use Permit 2005-09 (Resolution No. PC 2006-01) - The Town’s Planning and Economic Development Commission (PEDC) approved TTM 36-235 and UPA 2005- 09 on January 12, 2006, which authorized the two-phase Mammoth Hillside project. Phase I was approved for a 193-unit (325 bedrooms) condominium hotel with understructure parking for 259 vehicles and three check-in surface parking spaces with full-time valet parking services, spa, pool and patio facilities, meeting facilities, restaurant/bar, and associated landscape improvements on five parcels of land consisting of approximately seven acres. Phase II was proposed as a townhome development with 41 units (107 bedrooms). Phase II was not entitled by Resolution No. PC 2006- 11 and requires a separate tentative tract map and use permit application.

An additional 36 bedrooms of affordable housing were approved, 27 of which were required for affordable housing mitigation. The additional nine units qualified the project for a 35 percent state density bonus. The affordable housing rooms required for mitigation were exempted from the overall density calculations, pursuant to the NVSP’s Housing Element.

After the project was approved, it was discovered that the property was 0.07 acres smaller than originally calculated. The result was a reduction in the overall property density of five bedrooms.

Thus, the total allowable density of the Mammoth Hillside project as entitled in 2006, for Phase I and II, was 427 rooms (previously 432 rooms). The affordable housing mitigation required for the 35 percent state density bonus was also reduced to 35 bedrooms. An appeal of the PEDC’s decision to approve TTM 36-235 and UPA 2005-09 was reviewed by the Town Council on February 15, 2006. The Council voted to uphold the approval.

Use Permit 2007-11 (Resolution No. PC 2007-22) - On February 13, 2007, UPA 2007-11 was approved by the PEDC. The Use Permit allowed tandem parking and mechanical parking lifts to be included in the underground parking garage design. At the time of the original project approval, the garage layout included parking spaces and drive aisles that did not meet Town standards. However, pursuant to Ordinance 2006-11, approved in December 2006, tandem parking and mechanical parking lifts were allowed through a Use Permit process.

As a part of this Use Permit application, the proposed parking structure was redesigned to meet the requirements of Ordinance 2006-11. A revised mix of units was also included that reduced the number of parking spaces required and accommodated the 50 parking spaces for the 8050 Residence Club (required by a private agreement) within the parking garage design. The number of units for Phase I was reduced to 127 units (291 rooms), a reduction of 34 rooms. Condition of

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
6 June 2022
Approval #1 in Resolution 2007-22 notes that the final number of units permitted to be constructed under the original approval (Resolution No. PC 2006-01) may be limited by the available parking in the Mammoth Hillside garage.

Use Permit 2007-14 (Resolution No. PC 2008-02) - Later in 2007, a Use Permit application for an alternative housing mitigation plan was approved. The alternative housing mitigation plan allowed for the payment of an in-lieu fee for the 35 bedrooms of affordable housing instead of constructing the affordable housing on-site. The findings provided in Resolution 2008-02 described that an additional 30 percent on top of the established in-lieu fee would be paid. The total in-lieu mitigation fee agreed upon was $5,586,000. It was determined that the mitigation plan resulted in a greater community benefit and that 35 percent state density bonus would remain.

UPA 2007-14 was approved by the PEDC on February 13, 2008. An appeal of the approval was heard by the Town Council on April 2, 2008. The Town Council voted to affirm the PEDC’s approval with the condition that Mammoth Lakes Housing, Inc. complete the units required for mitigation in the low- or moderate-income range within five years of payment of the in-lieu fee. This condition was amended in 2015 (see Amendment to TTM 36-235, UPA 2005-09, UPA 2007-11, and UPA 2007-14, and associated Time Extension Request (TER 15-003), Fees, below).

Concept Review 15-002 - A Concept Review (CR) application, was submitted on June 29, 2015, to review the conditions of approval of the existing entitlements for the Mammoth Hillside project. In the application, it was noted that several of the conditions were “barriers to development and financing”, and that if those were amended or removed, where appropriate, it might facilitate progress on the project.

CR 15-002 was discussed and routed to applicable Town staff and agencies at the Development Review Committee on July 7, 2015. There was consensus among staff that some of the conditions were either no longer relevant or should be changed to reflect the most current conditions as standardized by the Town. It was also recommended that if the three resolutions for the Mammoth Hillside project were to be amended, that they be combined into one resolution to simplify and clarify the conditions.

On September 9, 2015, the PEDC reviewed the proposed amendments at a public workshop and there was consensus from the PEDC that the amendments to the entitlement conditions were reasonable.

Amendment to TTM 36-235, UPA 2005-09, UPA 2007-11, and UPA 2007-14 and associated Time Extension Request (TER 15-003) (Resolution No. PC 2015-09) - In accordance with CR 15-002, the PEDC reviewed amendments to the approved Tentative Tract Map and Use Permits at a public hearing on December 9, 2015. The PEDC voted unanimously to approve the amendments and the associated Time Extension Request (TER 15-003). The existing project entitlements expire on July 12, 2022.

The following amendments to the entitlement conditions of approval were made:
• Four- or Five-Star Hotel Operator - Condition 2 of Resolution No. PC 2006-01, requiring that the project have a contract with a four- or five-star hotel operator prior to the issuance of a Certificate of Occupancy, was deleted because any product yielding Transient Occupancy Tax at this location may meet the anticipated objective.

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
7 June 2022
• Pedestrian Bridge - Condition 10 of Resolution No. PC 2006-01, referencing a pedestrian bridge over Canyon Boulevard to connect the project site to the Gondola Building and the Village Plaza, was deleted because the pedestrian bridge is not required by the Town or by the NVSP.
• 8050 Residence Club 50 Parking Spaces - Resolution No. PC 2007-22 referenced a private parking agreement with the owners of the 8050 Residence Club (Mammoth 8050, LLC), which requires that the Mammoth Hillside project provide 50 parking spaces within the underground parking garage. The resolution was amended to indicate acknowledgement, but not requirement, of the private parking agreement.
• Fees - There were references throughout the resolutions to required affordable housing mitigation fees and development impacts fees. In the resolutions, these conditions referenced specific fee amounts (e.g., $5,586,000 for in-lieu housing mitigation fees). The related conditions were amended to require payment of affordable housing mitigation fees and development impact fees in place at the time of building permit submittal or issuance, as applicable, in accordance with conditions applied to current development projects.

Payment of the standard affordable housing mitigation fees resulted in the loss of the 35 percent state density bonus, as the previous fee amount of $5,586,000 was considered to be a significant community benefit comparable to that of the provision of on-site, inclusionary housing.
• Pedestrian Area or Transit Shelter - A revised Condition 23 of Resolution No. PC 2006-01 was incorporated to require participation in the creation of a pedestrian area of interest or transit shelter located at the north easterly portion of the property along Canyon Boulevard. • Current Standards - Conditions were updated as necessary to reflect current standards and best practices in the Planning and Engineering Divisions. For example, conditions regarding landscaping were revised to reference the Water Efficient Landscape Ordinance.

Concept Review 16-001 - A Concept Review (CR) application was submitted in 2016 to obtain feedback on a request to increase the density of the Mammoth Hillside site from 317 rooms to 403 rooms to facilitate the development of a future hotel project. The request was reviewed and discussed at a joint workshop of the PEDC and Town Council on September 21, 2016.

General Plan Amendment (GPA) 16-001 and District Zoning Amendment (DZA) 16-002 - On May 10, 2017, the PEDC approved the Mammoth Hillside Addendum Project. The project added modifications to the 1999 SPEIR with respect to the 6.9-acre Mammoth Hillside project site. These modifications included the following:
• Density Increase - The Mammoth Hillside site is located in the Plaza Resort (PR) and Specialty Lodging (SL) zones of the NVSP. The allowed density in the PR Zone is 80 rooms/acre, and the allowed density in the SL Zone is 48 rooms/acre. This results in a maximum density of 404 rooms for the Mammoth Hillside site. However, as previously noted in 2004, 87 rooms of density were transferred from the Mammoth Hillside site to the South Hotel site, located in the PR Zone. This density transfer did not increase the overall density allowed in the PR Zone, thereby reducing the allowed density on the Mammoth Hillside site to 317 rooms (404 - 87 = 317). The covenant documenting this density transfer explicitly states that it does not impair the Mammoth Hillside site from increasing density on the site by any legal means.

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
8 June 2022
The addendum increased density in the PR Zone of the NVSP by 87 rooms to restore the Mammoth Hillside site to its maximum allowable density of 404 rooms. This increased the overall allowed NVSP density by 2.6 percent or to 3,404 rooms (3,317 + 87 = 3,404). • Lot Coverage Increase - The allowed lot coverage in the PR Zone is 75 percent, and the allowed lot coverage in the SL Zone is 60 percent. This results in a maximum lot coverage of approximately 195,171 square feet for the Mammoth Hillside site. However, in 2004, 14,881.9 square feet of lot coverage was transferred from the Mammoth Hillside site to the South Hotel site, located in the PR Zone. This lot coverage transfer did not increase the overall lot coverage allowed in the PR Zone, thereby reducing the allowed lot coverage on the Mammoth Hillside site to 180,289.1 square feet (195,171 - 14,881.9 = 180,289.1).

The covenant documenting this lot coverage transfer explicitly states that it does not impair the Mammoth Hillside site from increasing lot coverage on the site by any legal means.

The addendum increased lot coverage in the PR Zone of the NVSP by 14,881.9 square feet to restore the Mammoth Hillside site to its maximum allowable lot coverage of approximately 195,171 square feet. This would increase the overall PR Zone lot coverage by 2.3 percent (14,881.9 square feet / 645,233 square feet = 2.3 percent).

The following amendments to the entitlement conditions of approval were made:
• Town of Mammoth Lakes General Plan Amendment – A General Plan Amendment was required for the increase in density proposed as part of the Mammoth Hillside Addendum Project. The General Plan specifies the maximum overall number of rooms allowed in the NVSP. The General Plan Amendment increased the maximum overall number of rooms allowed in the NVSP from 3,317 to 3,404, which is an increase of 87 rooms. Additionally, the buildout table of the NVSP described in the Town of Mammoth Lakes General plan would be amended to include corrected calculations regarding the maximum allowable rooms and units within the NVSP.
• North Village Specific Plan Amendment – Pursuant to the Administrative Procedures in the NVSP and Zoning Code Chapter 17.116, Specific Plans, an amendment to the NVSP was required for the increase in in density and lot coverage proposed.

Limelight Hotel TTM 22-002, UPA 22-001, DR 22-001 - An entitlement application was submitted for the development of a 185,754-square foot condominium hotel (Limelight Hotel) within the NVSP area. The Limelight Hotel would have a mix of hotel and residential uses consisting of 151 room hotels and 15 residential units. Additional amenities would include a town dining hall, meeting space, lobby, ski club lounge, and a fitness center. The Applicant has also conducted a feasibility study for drilling renewable direct use geothermal energy system on-site. This system requires drilling and operating two geothermal wells, one producer to bring hot fluid to the surface and one injector located within the Limelight Hotel property. The heat from the fluid passing through the system would be used for the building systems requiring heat, replacing gas or electric use. The wells would be drilled and operated under the geothermal permitting authority of California Department of Conservation Geologic Energy Management Division (CalGEM), reporting production and injection, who is the responsible agency for ensuring the lawful and safe drilling and operation of the wells. This renewable energy system could be used to provide heat, electricity, hot water, de-icing, and other beneficial uses within the Limelight property.

As currently proposed, the Town of Mammoth Lakes has determined that the Limelight Hotel buildout assumptions and project features are consistent with that considered as part of the

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
9 June 2022
Mammoth Hillside Addendum, with the exception of the proposed geothermal well system, which is the subject of this addendum.

2.0 DESCRIPTION OF PROJECT MODIFICATIONS

2.1 ADDENDUM’S PURPOSE AND NEED
When an EIR has been certified or a negative declaration adopted for a project, no subsequent or supplemental environmental review documentation shall be required unless one or more of the following events occurs:
1) Substantial changes are proposed in the project, which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects;
2) Substantial changes occur with respect to the circumstances under which the project is undertaken, which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects; or 3) New information of substantial importance, which was not known and could not have been known with the exercise of reasonable diligence at the time the previous EIR was certified as complete or the negative declaration was adopted, shows any of the following:

A. The project will have one or more significant effects not discussed in the previous EIR or negative declaration;
B. Significant effects previously examined will be substantially more severe than shown in the previous EIR;
C. Mitigation measures or alternatives previously found not to be feasible would in fact be feasible, and would substantially reduce one or more significant effects of the project, but the project proponents decline to adopt the mitigation measure or alternative; or
D. Mitigation measures or alternatives which are considerably different from those analyzed in the previous EIR would substantially reduce one or more significant effects on the environment, but the project proponents decline to adopt the mitigation measure or alternative.

When none of the above events has occurred, yet minor technical changes or additions to the previously adopted EIR or negative declaration are necessary, an addendum may be prepared (State CEQA Guidelines Section 15164[b]).

As discussed below, none of the conditions described in State CEQA Guidelines Section 15162 calling for preparation of subsequent environmental review has occurred. This Addendum supports the conclusion that the proposed project modifications do not result in any new significant environmental effects or a substantial increase in the severity of previously identified significant effects. In addition, as discussed below, the proposed project modifications would not

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
10 June 2022
result in any new or substantially increased significant environmental impacts, new mitigation measures, or new alternatives that would substantially reduce significant impacts. As a result, an addendum is an appropriate CEQA document for analysis and consideration of the proposed project modifications.

Circulation of an addendum for public review is not necessary (State CEQA Guidelines Section 15164, subdivision (c)); however, the addendum must be considered in conjunction with the adopted 1999 SPEIR (State Clearinghouse No. 99-092082) and 2017 Mammoth Hillside Addendum to the 1999 SPEIR by the decision-making body (State CEQA Guidelines Section 15164, subdivision (d)).

2.2 LOCATION OF PROJECT MODIFICATIONS
The proposed modifications would apply to the same approximately 6.9-acre project site identified in the NVSP. The project site is comprised of seven parcels located at the northwest corner of Canyon Boulevard and Lake Mary Road, in Mammoth Lakes, California.

2.3 COMPONENTS OF PROJECT MODIFICATIONS
The proposed modifications to the NVSP would include drilling and operating a geothermal well system on-site for the purpose of providing renewable heat energy solely for use within the property. It is acknowledged that the following subsections are consistent with the California Department of Conservation Geologic Energy Management’s (CalGEM’s) CEQA Guidance for Operators Project Descriptions, revised April 7, 2021.

Operator Name: Limelight Mammoth LLC
Environmental Settings
The NVSP area varies in topography, between 8,040 mean sea level (msl) and 8,070 msl. The project site is currently vacant and vegetated. The site is designated by the General Plan as a Specific Plan (NVSP) and zoned by the Municipal Code as NVSP. To the east of the site, across Canyon Boulevard, is lodging and condominiums (8050 Residence Club and Mammoth Fireside), as well as commercial uses (Mammoth Mountain Ski Area gondola building and retail and Mammoth Brewing Company), all zoned NVSP. To the south are townhomes and condominiums (Mammoth View Villas and the Canyon Ski and Racquet Club), zoned Residential Multi-Family 2.

To the west, across Lakeview Boulevard, are condominiums (Mammoth Estates). To the north is the Westin Monache Resort (zoned NVSP).

Currently, the project site is vacant and vegetated. Existing vegetation includes the Jeffrey Pine and Lodgepole Pine. According to the 1991 PEIR, there are approximately five species of concern that could potentially occur on-site, including the hoary draba (Draba cana), bog sedge (Kobresia sp.), Mono Milk Vetch (Astragalus monoensis), Mono Lake lupine (Lupinus duranii), and Mono County lupine (Lupinus sublanatus). The existing Jeffrey Pine would provide suitable habitat for multiple special-status bird species, including pygmy nuthatch (Sitta pygmaea), brown creeper (Certhia americana), white-headed woodpecker (Dryobates albolarvatus), and Clarks’ nutcracker (Nucifraga columbiana).

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
11 June 2022
Existing Geology
Mammoth Valley sits in the larger Mammoth Basin watershed and straddles the southwestern boundary of the Long Valley Caldera, which sits at the head of the Owens Valley. The towns of Old Mammoth and Mammoth Lakes lie within the upper reaches of Mammoth Valley, at the eastern base of Mammoth Mountain. The valley is surrounded to the south, west, and north by mountains, topping 12,500 feet above msl at Bloody Mountain to the south, and dropping to about 6,900 feet above msl at the eastern end of the valley where it empties into the Owens Valley. The eastern half of the valley is downdropped into the Long Valley Caldera, while the western portion, the Upper Mammoth Valley, lies outside the caldera ring. Long Valley Caldera is a geologically active area with several active magmatic/volcanic centers (Mammoth Mountain, Inyo Craters, and the rhyolite domes north of Mammoth Lakes), which provide the heat sources for geothermal systems in the area, the largest being the Basalt Canyon/Casa Diablo geothermal system.

The mountains directly to the north and west of Mammoth Valley are composed of Quaternary rhyolite and dacite domes (erupted between 150 and 50 thousand years ago), while the mountains to the south are composed of Pre-Tertiary (older than 66 million years) igneous intrusive and metamorphic rocks. Mammoth Valley itself forms a central glacial trough, which shallows to the east and is filled with Quaternary age (≤767 thousand years ago) volcanic, glacial, and alluvial deposits. Few surface faults have been mapped through the valley, due to the young cover deposits of glacial and alluvial fill; however, the project site sits above the region interpreted to be the location of the caldera ring fractures, which are a series of nested normal faults that extend several kilometers in depth.

Geothermal System Structure
The main geothermal system in the area, which has been the focus of development efforts for decades, is the Basalt Canyon/Casa Diablo system, which feeds the Casa Diablo power plants to the east and exists in a larger hydrologic system that is fed from the mountains surrounding the Mammoth Basin and flows eastward, down Mammoth Valley and into the Owens Valley.

The source of the Basalt Canyon/Casa Diablo geothermal system is structurally controlled, and the upwelling geothermal fluids (>390°F) ascend along the caldera ring fractures and range front faults under West Moat Coulee, directly to the north of Mammoth Domes. Upon ascending into the Early Rhyolite, the bulk of the geothermal fluids flow out to the east, following the prevailing eastward groundwater gradient along a stratigraphically controlled path through the Early Rhyolites down Basalt Canyon and 2.5 miles out through the Casa Diablo geothermal field where they are produced to generate electricity.

However, some smaller portion of the geothermal fluids appear to leak out to the southwest from the rhyolite dome to partially underlie the Town of Mammoth Lakes and form smaller peripheral geothermal reservoirs. Temperature profiles and hot water produced in nearby wells indicate the presence of geothermal reservoirs underlying the area directly east of the Limelight property (less than 1,000 feet from the center of the project site).

Existing Geothermal Reservoirs
The geothermal system which underlies the Town appears to consist of two reservoirs, as evidenced by temperature rollovers in nearby wells as well as hot water produced in the vicinity:

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• A shallow geothermal reservoir of approximately 120-125°F from 400 to 800 feet below ground surface (bgs), which is also the reservoir that the Mammoth Community Water District wells produce from; and
• A deeper geothermal reservoir with maximum temperatures of approximate 170°F, at approximately 1,400 feet bgs. This reservoir appears to be within the Early Rhyolite rock units. The Early Rhyolite also appears to be the principal pathway for hydrothermal fluids flowing to Casa Diablo.

Existing Watershed Conditions
The Town is located within the Mammoth Groundwater Basin’s sphere of influence. Locally, existing groundwater traverses through the project site and travels eastward toward and through the non-geothermal aquifer. This shallow aquifer responds rapidly to precipitation and houses a few wells for domestic water. A geothermal well(s) would drill through and seal off any interaction with groundwater aquifers, therefore not affecting such, to access the deeper geothermal reservoir.

Project Proposal
As discussed previously, the Limelight Hotel proposes a new hotel and residential condominium units within the NVSP area. The proposed Modified Project would install two geothermal wells, a production well and an injection well, at the Limelight Hotel project site to serve as a source of renewable energy to solely serve on-site development. The proposed geothermal system would be used to provide heat and electricity for the use of the Limelight Hotel development. The project would install two graded pads at the surface for initial well drilling operations (ranging in size, depending on the rig, from approximately 100 by 200 feet to as large as 200 by 250 feet). The two drilled geothermal wells would connect to the existing underground geothermal reservoir. The production well would extract geothermal fluids to the surface, while the injection well would pump cooled geothermal fluid back into the reservoir to maintain the reservoir pressure. The geothermal wells would have cemented casing through the shallow warm aquifer and any other shallow potable aquifers to eliminate the possibility of interaction with the aquifer that is used for municipal water. The project phases include site preparation, geothermal well drilling, geothermal well testing, and ongoing geothermal well operations, which are regulated by CalGEM, to maintain the geothermal heat system for the Limelight hotel facilities.

Construction Activities
Approximately two acres of the development site would be disturbed by the proposed geothermal wells. The two graded pads (up to approximately 200 feet by 250 feet) are within the disturbed area for the hotel. They would be constructed and then reclaimed or put to use within the hotel build out. The remaining wellheads and surface connections would become part of the hotel facilities. Each well would be drilled at different depths. Although the geothermal reservoir is expected to be encountered at an estimated depth of 1,400 feet bgs, the proposed geothermal wells are planned to a maximum depth of 2,000 feet to ensure encounter with the geothermal reservoirs and feed/injections zones. Final depth of each well would be determined based on drilling results. Each wellhead and the required surface equipment for operations would be sited in an area of 75 feet by 75 feet. The proposed injection well would pump cycled/geothermal water into the geothermal reservoir at a flow rate of 85 to 250 gallons per minute (gpm) to maintain temperatures within the reservoir between 140 to 175°F. In order to avoid well interference and

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to sweep the largest possible volume of rock to extract the heat, the proposed geothermal wells would be located as far apart from each other as feasibly possible on the hotel site. Accordingly, the proposed interference well would be constructed on site where no building improvements would be constructed on or over the geothermal wells and where such geothermal wells may be easily accessed. More specifically, the proposed geocoordinates are:
• Well Number 1 approximate location: 37°38'52.6"N 118°59'05.8"W • Well Number 2 approximate location: 37°38'54.8"N 118°59'08.1"W The proposed construction activities for the geothermal system/wells would require planning/permitting, site preparation, drilling and rig testing of the first well, drilling and rig testing of the second well, and well testing. These activities would occur over a period of approximately 89 calendar days. The Planning and Permitting stage begin once well permits are submitted and is expected to occur for two weeks, and are anticipated to require the following State, regional, and local permits and approvals: CalGEM and Town of Mammoth Lakes (surface disturbance).

The site preparation would occur for a duration of four weeks to grade the drilling pads and road access. Once site preparation is complete, the drilling and rig test of the first well would commence and occur over a duration of 19 days. Rig testing and all excavation and drillings for the first geothermal well would occur during this stage. The drilling and rig test of the second well would occur over a duration of 15 days and would involve the same activities that occurred for the first well. Well testing would be the final stage of the proposed Modified Project and would occur over a duration of 38 days. The flow of both the production well and an injection well would be tested during this stage. Note, each well drilled for the project would be permitted as a geothermal well under CalGEM with a process to convert wells to an injection status based on the drilling and testing results and project needs. The drilling time and casing depths would be similar for both wells, with the same target formation.

Construction activities for the initial drilling and construction of the wells would require a drilling rig (mast approximately 100 feet in height) and drilling services including, mud logging (collection of drilling and geologic information), drilling fluids, cementing services for casings, solids control and containment for sumpless drilling, site services (trash, water, restrooms, lights), drilling water and fuel delivery, and consumable materials (drilling mud, cement, casings, wellhead). Waterbased drilling fluids would be utilized. Approximately 126,000 to 210,000 gallons of fresh water would be required per well and two 500-barrel tanks would be installed as storage on-site. Other construction-related equipment would include a trailer for a drilling supervisor to live on-site with office space, water storage bins for drilling water, and a laydown area for casings and equipment not in use. Drilling crews would live off-site with 12-hour shifts and five-man crews. Total personnel on-site during the drilling period would be approximately 10 workers per shift.

Drilling activities are anticipated to occur 24 hours per day, seven days a week until complete, which would be contained to the graded pads (approximately 200 feet by 250 feet). Drilling and completion of each well (24-hour operations) is anticipated to occur for a duration of 15 days for each well, with several rig move days between wells (daylight only) if the drilling is successful.

After the well drilling is complete, rig-on testing would require an air compressor package and services and pressure/temperature downhole survey services. Drilling residues such as cuttings, fluids, and solid waste would be contained and disposed of according to California waste guidelines (tested and transported to appropriate waste facility). Transportation and delivery of waste would be limited to daylight hours.

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During well testing, reinjection of fluids into the second well would occur for a period of 24 to 48 hours after both geothermal well tests are complete. In case the well is flowing during the 24- to 48-hour testing, alternative disposal such as the Town’s stormwater system would be utilized if feasible. If this is required, the fluids are expected to be low total dissolved solids (TDS) and contain no organic material. It will be field chemistry tested and filtered prior to disposal. The volume of the fluid is expected to be between 7,000- and 14,400-gallons total.

Operational Activities
During operations, the geothermal wells would be incorporated into the hotel facilities. Connection points from the wells to the hotel would be dependent on the final layout of the hotel. However, the goal is to utilize underground connections. The wellheads would be at ground level or several feet above ground level and be connected by pipelines (expected less than six inches in diameter). The wellheads and pump controls are expected to be contained in an area of approximately 10 square feet. Periodic maintenance would be required through the life of the geothermal wells and would require a small drilling rig within a working area of approximately 100 feet by 150 feet. Maintenance activities may include downhole pump replacements approximately every five years, though geothermal wells are designed to last 30 years or longer in operation with regular maintenance.

Best Management Practices
The proposed Modified Project would be required to comply with existing State and local laws and regulations, including implementation of required best management practices (BMPs). The proposed drilling, operation, and permanent sealing and closure (plugged and abandonment) of geothermal wells are required to comply with CalGEM’s Statues & Regulations, dated January 2020, or as amended at the time of future permits. BMPs would include an adequate drilling fluid program, casing program, spill contingency plan, appropriate well identification signage, installation of well safety devices, keeping of well records, ongoing testing activities during construction and operations, and appropriate plugging and abandonment at closure. Further, as part of the Town of Mammoth Lakes Municipal Code (Municipal Code) Section 8.24.050(F)(10), geothermal drilling waste and cuttings shall be disposed of in a manner approved by the Lahontan Regional Water Quality Board. Additionally, during 24-hour construction activities, construction noise would be minimized with sound barriers to the extent feasible.

Local Agency Requirements
The Modified Project would be subject to local permits/approvals including but not limited to:
• Permits for the drilling, operation, and permanent sealing and closure at the end of the well useful life under State requirements and procedures (CalGEM); • Well Permit (Mono County)
• Tentative Tract Map (Town of Mammoth Lakes);
• Use Permit (Town of Mammoth Lakes);
• Design Review (Town of Mammoth Lakes); and
• Construction of Well Permit (Mammoth Community Water District). 1 1 The Applicant will consult with the Mammoth Community Water District (MCWD) to determine if a permit will be required. Should a permit be required, the Applicant will obtain a well permit from the MCWD and provide any information needed for the District to make the required findings for approval as specified in the MCWD Code Book.

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3.0 ENVIRONMENTAL ASSESSMENT
As discussed in Section 1.2, Previous Environmental Documents, for the purposes of this analysis, the proposed project modifications are compared to the certified 1999 SPEIR development scenario and/or the approved Mammoth Hillside Addendum development scenario. Potential environmental impacts resulting from the proposed project modifications, as compared to the development scenario presented in the certified 1999 SPEIR and Mammoth Hillside Addendum, are presented below for each environmental topic area considered in the 1999 SPEIR. Additional environmental topic areas were analyzed under the proposed project modifications, including Energy, Hazards and Hazardous Materials, and Wildfire. Implementation of the proposed project would not require any new mitigation measures compared to those recommended in the 1999 SPEIR and the Mammoth Hillside Addendum. Mitigation measures recommended within this analysis are the same as those presented in the 1999 SPEIR and only include those applicable to the proposed project modifications.

3.1 LAND USE
The 1999 SPEIR analyzed potential changes in the existing physical land use patterns and demand, both within the area and throughout the commercial areas of the town, as well as development of a more intensive use than the previous zoning and land uses within the vicinity of the NVSP area. The 1999 SPEIR concluded that the implementation of Mitigation Measures recommended in the 1994 PEIR Addendum (Mitigation Measures 4.4-1(a)-4.4-1 (c), 4.4-2, 4.4-3) would reduce impacts within the vicinity to a less than significant level. The Mammoth Hillside Addendum is consistent with what was analyzed in the SPEIR in that the Mammoth Hillside project site is approximately 6.9 acres within the Specific Plan area and is zoned Specialty Lodging (SL) and Plaza Resort (PR). Under the Mammoth Hillside Addendum, the Mammoth Hillside project site was modified through two components: 1) 87 room density increase to the NVSP, and 2) 14,881.9-square foot lot coverage increase in the PR Zone of the NVSP. Implementation of the density and lot coverage increases would result in a 2.6 percent increase in overall density in the NVSP and a 2.3 percent lot coverage increase in the PR Zone of the NVSP. The amendment restored the density and lot coverage allowed on the Mammoth Hillside site under the current NVSP zoning, which was reduced after a density and lot coverage transfer to the South Hotel site in 2004. The Mammoth Hillside Addendum determined that this nominal increase would not increase impacts related to land use beyond what was analyzed in the 1999 SPEIR.

The proposed project modifications involve drilling a closed-looped geothermal energy well system at the Mammoth Hillside project site. The proposed geothermal energy well system would be consistent with General Plan Policy M.9.C, which supports development of geothermal and solar heating opportunities for snow removal. Further, the proposed project modifications would comply with Municipal Code Section 8.24.050(F)(10), pertaining to construction permit requirements for the purposes of minimizing water quality impacts during installation of wells. As such, the proposed project modifications would not result in any new significant land use impacts that were not analyzed in the 1999 SPEIR or the Mammoth Hillside Addendum.

Mitigation Program
No mitigation measures were found to be feasible in the 1999 SPEIR for this topic area, and no new measures are feasible.

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3.2 POPULATION AND HOUSING
Potential impacts to population and housing were fully analyzed within the 1999 SPEIR. The 1999 SPEIR concluded that with implementation of relevant housing policies and programs, there would be no significant impacts related to employment, population, and housing. The proposed modifications analyzed in the Mammoth Hillside Addendum were also determined development would not increase population and housing impacts beyond what was analyzed in the 1999 SPEIR.

The proposed Modified Project would construct, operate, and maintain a geothermal well system that would provide electricity and power solely to the project site. The proposed geothermal well system would not result in an increase in population growth or the need for new housing in the Town of Mammoth Lakes. The proposed Modified Project would not lead to an increase in population growth in the Town beyond what was analyzed in the 1999 SPEIR and the Mammoth Hillside Addendum.

Mitigation Program
No mitigation measures are applicable.

3.3 AESTHETICS/LIGHT AND GLARE
The potential impacts to visual character, scenic vistas and resources, and light and glare were fully analyzed in the 1999 SPEIR. The 1999 SPEIR analyzed design features such as building material and color palette, architectural design, frontage, building height, bulk and mass, landscape, as well as shade and shadow and surrounding views. The 1999 SPEIR concluded that implementation of recommended Mitigation Measure5.3-1a through 5.3-1f and 5.3-1j, 5.3-1k, and 5.3-1m, which mitigate impacts on visual character, Mitigation Measures 5.3-2a and b, which mitigate impacts on scenic vistas and resources, and Mitigation Measures 5.3-3a through 5.3-3d, which mitigate impacts on light and glare, would reduce impacts to a less than significant level.

The proposed Modified Project would construct two graded pads and a geothermal well system.

Initial drilling and construction would require a drilling rig (mast approximately 100 feet high). The proposed well heads that would be part of the geothermal well-system would be located in an enclosed area within the Limelight Hotel development site, and would be screened from public view. Construction activities would require nighttime construction for the drilling of the wells, which would occur 24 hours per day, seven days a week for 15 consecutive days per well. Proposed project modifications would also be required to comply with 1999 SPEIR Mitigation Measure 5.3- 1c through 5.3-1f and 5.3-1j, which mitigate impacts on visual character (including implementation of screening techniques).

Operational exterior lighting (for security purposes) would be constructed as part of the Modified Project. Additional lighting would be needed at night for the drilling mast and the graded pads.

However, these lighting features would be consistent with future on-site lighting considered as part of the 1999 SPEIR and the Mammoth Hillside Addendum. The Modified Project would be required to comply with 1999 SPEIR Mitigation Measures 5.3-3a, 5.3-3b, and 5.3-3d, which require shielding/screening techniques to minimize light spillover. As such, the Modified Project would not result in any new or potentially adverse aesthetic/visual impacts not previously considered and addressed.

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Mitigation Program
The following measures from the certified 1999 SPEIR would also be applicable to the proposed Project Modifications. Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

Applicable Mitigation Measures
1999 SPEIR

5.3-1c Contour grading shall be used to blend manufactured slopes into the natural terrain.

Grading shall be minimized to preserve existing landform and vegetation to the greatest extent possible.

5.3-1d The landscape design for the site shall maximize the use of existing vegetation, and where new plants are introduced, they shall include, and/or blend with, plants native to the Mammoth Lakes environment. Landscape plans for the site shall be completed by a certified landscape architect.

5.3-1e To the maximum extent practical, native trees and landscaping shall be concentrated around all structures located on the project site.

5.3-1f Grading techniques shall be used which minimize the area of disturbance and shall incorporate such methods as decorative retaining walls rather than slopes to minimize the area of disturbance.

5.3-1j Staging locations shall be indicated on project Building Permit and Grading Plans and shall be subject to review by the Town of Mammoth Lakes Community Development Director in accordance with Municipal Code requirements.

5.3-3a The Design Guidelines shall require that all exterior lighting be designed and located so as to avoid intrusive effects on adjacent residential properties and undeveloped areas adjacent to the project site. Low-intensity street lighting and low-intensity exterior lighting shall be used throughout the development to the degree feasible.

Lighting fixtures shall use shielding, if necessary, to prevent spill lighting on adjacent off-site uses.

5.3-3b Lighting used for various components of the development plan be reviewed under North Village Specific Plan design guidelines which shall include review of light intensity levels, fixture height, fixture location, and design.

5.3-3d Vegetative buffers shall be used to reduce light intrusion on residential development and on forested areas located adjacent to the project site.

3.4 TRAFFIC AND CIRCULATION
The 1999 SPEIR determined that after implementation of recommended mitigation measures, the previously analyzed project would result in less than significant impacts. It should be noted that the NVSP and the 1999 SPEIR utilized auto delay, LOS, and similar measurements for vehicular

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roadway capacity and traffic congestion as the basis for determining significant impacts. In September 2013, the Governor’s Office of Planning and Research (OPR) signed Senate Bill (SB) 743 into law, starting a process that would eliminate the LOS metric and identify Vehicle Miles Traveled (VMT) as the most appropriate CEQA transportation metric, along with the elimination of auto delay and LOS for CEQA purposes. The justification for this paradigm shift is that auto delay/LOS impacts lead to improvements that increase roadway capacity and therefore induce more traffic and greenhouse gas emissions. For the purposes of this analysis, transportation impacts for the Modified Project would be analyzed under the VMT transportation metric.

Transportation Policy Consistency Analysis
The 1999 SPEIR summarized the regional and local transportation plans that affect the NVSP, including the Regional Transportation Plan (dated December 1992), the Mammoth Lakes Trail System Plan (dated May 1991), the Transit Design Study (dated June 1993), and the Main Street Promenade and Transportation Forecasting Model/Multi-Modal Transportation Plan and determined that each form of transportation supports the Town’s overarching goal to concentrate efforts for non-vehicular transportation modes to facilitate increased person trips. The 1999 SPEIR concluded that the future buildout of the NVSP would result in adverse impacts to this goal of the Town. Mitigation Measure 5.4-6 would require future development to participate on a fair share basis in the development and operation of a community-wide winter transit system.

Similarly, the proposed modifications analyzed in the Mammoth Hillside Addendum also determined similar impacts, and proposed Mitigation Measures from the 1999 SPEIR.

Goal M.8 and Policy M.8.1 of the Mobility Element of the General Plan both aim to create a linked year-round recreational and commuter pedestrian system by identifying and implementing pedestrian improvements that meet the Town’s standards. Policy M.12.1 in the of the General Plan aims to expand and increase the reliability of transit service to meet community needs.

As a geothermal well system, the Modified Project would not generate additional pedestrians, bicyclists, or vehicles within the Limelight Hotel development site. The proposed geothermal wells would be located in an area of the Limelight Hotel development site that is secluded from the rest of the hotel, with restricted public access. These proposed modifications would not result in an increase in population or the development of new pedestrian, bicycle, or transit facilities. As such, these proposed modifications would not result in an increase in pedestrians, bicyclists, and transit rides that would be beyond what was analyzed in the 1999 SPEIR. Accordingly, the Modified Project would not conflict with the Town’s goal of promoting non-vehicular transportation modes, nor would it conflict with pedestrian, bicycle, and transit goals and policies that are outlined in the General Plan. Less than significant impacts would result in this regard.

Design Safety Hazard Analysis
The 1999 SPEIR analyzed the NVSP regarding design safety hazards, and determined that, overall, the buildout of the NVSP would not substantially increase hazards to vehicles, pedestrians, and bicyclists associated with proposed design features (i.e., roundabout) or increased pedestrian activity.

The proposed Modified Project would be located in an enclosed area within the Limelight Hotel development site. The proposed Modified Project would not introduce new roadway, bicycle, or pedestrian facilities, and would not alter the existing and planned roadway, pedestrian, or bicycle facilities that were analyzed in the 1999 SPEIR. Lastly, the proposed Modified Project would not introduce new designs or modifications to any of these transit facilities. Therefore, the Modified

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Project would not introduce new transportation-related safety hazards that would be beyond what was analyzed in the 1999 SPEIR. Less than significant impacts would occur in this regard.

Vehicle Miles Traveled (VMT) Screening Analysis
The 1999 SPEIR established 106,600 VMT as the threshold for projects within the Town. The 1999 SPEIR also determined that the buildout of the 1999 NVSP would result in an additional 2,800 VMT, resulting in a total of 109,400.

As discussed, the Modified Project would not result in unplanned population growth in the Town beyond what was analyzed in previous environmental documents. While the geothermal well system would require routine maintenance that would result in additional vehicle trips, the increase would be nominal. Therefore, the Modified Project would not conflict or be inconsistent with CEQA Guidelines section 15064.3, subdivision (b). Less than significant impacts would result in this regard.

Conclusion
The proposed Modified Project would not result in any increase in development intensity than that considered for full buildout of the NVSP, nor any changes to the transit system. The proposed modifications would not result in any conflicts with existing plans, ordinances, or policies addressing transit, roadway, bicycle and pedestrian facilities. Lastly, the Modified Project would not result in a substantial increase in VMT. Therefore, less than significant impacts related to transportation would occur in this regard.

Mitigation Program
No mitigation measures were found to be feasible in the 1999 SPEIR for this topic area, and no new measures are feasible.

3.5 AIR QUALITY
Air Quality
The 1999 SPEIR determined that short-term air quality impacts associated with particulate emissions (fugitive dust) from construction activities would be mitigated to a less than significant level with implementation of standard dust control measures required by the Great Basin Unified Air Pollution Control District (Great Basin APCD). The 1999 SPEIR added that implementation of recommended Mitigation Measures 5.5-1a and 5.5-1b would further reduce short-term air quality impacts in this regard. In regard to long-term operational impacts, the 1999 SPEIR concluded that long-term air quality impacts from localized 8-hour carbon monoxide (CO) emissions would be reduced to a less significant impacts with implementation of Mitigation Measures 5.5-3a and 5.5- 3b. The 1999 SPEIR concluded that implementation and buildout of the NVSP would exceed State and federal particulate matter less than 10 microns in diameter (PM10) thresholds thereby creating a significant and unavoidable air quality impact, even with implementation of Mitigation Measures 5.5-2a through 5.5-2c. On a cumulative level, the project would contribute to a current violation of the State and federal PM10 standards. The proposed modifications analyzed in the Mammoth Hillside Addendum were determined to result in no new impacts that were not analyzed in the 1999 SPEIR.

The proposed Modified Project would involve the installation of a geothermal energy well system.

Construction activities would require site preparation, excavation, and drilling, which could result

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in temporary construction-related air quality impacts from air pollutants emissions, some of which are criteria air pollutants. Typical emissions from well construction activities include CO, carbon dioxide (CO2), total organic compounds (as methane) (CH4), nitrogen oxides (NOx), PM10, and sulfur oxides (SOx). However, it is acknowledged that the anticipated project construction activities for the geothermal system would be temporary and small in magnitude compared to the future buildout of the Limelight Hotel and NVSP. As discussed above, the Modified Project would also result require additional construction vehicles to haul and dispose excavated soils. However, these vehicle trips would be nominal compared to those required to buildout the Limelight Hotel and NVSP and thus, would not result in a significant increase in emissions compared to what was previously analyzed in the 1999 SPEIR. Nevertheless, Mitigation Measures 5.5-1a and 5.5-1b would be applicable to the Modified Project. As part of Mitigation Measure 5.5-1a, the project would be required to implement measures during construction activities to reduce fugitive dust emissions and ensure compliance with applicable Town and Great Basin APCD requirements.

Implementation of Mitigation Measure 5.5-1b would ensure potential spot violations of CO standards and potential odor impacts are minimized during construction. Additionally, as a BMP, the project Applicant would prepare and submit to CalGEM an Equipment Emissions Mitigation Plan (EEMP) for managing diesel exhaust. The EEMP would identify actions to reduce diesel particulate, CO, hydrocarbons, and NOx associated with construction activities. Additionally, the EEMP would require that all drilling related engines are appropriately tuned, do not idle for more than five minutes, and include control devices to reduce air emissions (i.e., particulate traps an oxidation catalysts). Thus, the implementation of Mitigation Measures 5.5-1a and 5.5-1b and applicable BMPs would reduce construction impacts to less than significant levels.

Operations could result in long-term operational air quality impacts from mobile sources. As a geothermal well system, routine maintenance would be infrequent and would not significantly increase anticipated mobile sources emissions beyond what was analyzed in the 1999 SPEIR, nor would it result in significant cumulative air quality impacts. As discussed in Section 3.4, Transportation, the proposed project modifications involve the construction and operation of a geothermal energy well system and would not result in substantial changes to generated VMT as quantified and analyzed in the 1999 SPEIR. As such, long-term operational air quality impacts from mobile sources would be less than significant.

Implementation of the Modified Project could result in a minor increase in stationary source emissions. A typical stationary pollutant emission that is associated with geothermal power production include hydrogen sulfide (H2S).2 Nonetheless, H2S emissions are considered generally well-maintained for geothermal energy projects through on-site abatement. Additionally, the proposed geothermal wells would be secluded and screened from the public and implementation of Mitigation Measure 5.2-2a would require adherence to the applicable regulations pertaining to stationary criteria pollutants.

Further, since the certification of the 1999 SPEIR, the Air Quality Management Plan for the Town of Mammoth Lakes (1990 AQMP) has since been updated to the 2014 Update to the Air Quality Maintenance Plan and Redesignation Request for the Town of Mammoth Lakes (2014 AQMP) prepared by the Great Basin APCD (dated May 2014). The 2014 AQMP was approved by the EPA and Mammoth Lakes was redesignated a maintenance area in attainment of the PM10 National Standard on November 2, 2015. As such, the Modified Project would not result in a substantial increase in criteria pollutants, including hydrogen sulfide and PM10, that would exceed 2 United States Department of the Interior Bureau of Land Management, Final Programmatic Environmental Impact Statement for Geothermal Leasing in the Western United States, October 2008.

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Great Basin APCD significance thresholds for criteria pollutant emissions during project operations.

With implementation of identified Mitigation Measures 5.5-1a and 5.5-1b, which mitigate shortterm air quality impacts, and Mitigation Measure 5.2-2a, which would mitigate long-term PM10 air quality impacts, the proposed Modified Project would not result in any new substantial adverse air quality impacts not previously considered and addressed in the 1999 SPEIR.

Greenhouse Gas Emissions
Although the 1999 SPEIR did not include a greenhouse gas (GHG) analysis, a supplemental environmental analysis of GHG impacts cannot be required absent new information on that front.3 Information on the effect of GHG emissions on climate was known long before the Town certified the 1999 SPEIR. Thus, the effect of GHG emissions on climate could have been raised when the Town considered the previous environmental documentation including the 1999 SPEIR. A challenge to an EIR must be brought within 30 days of the lead agency’s notice of approval and no challenges were brought forward regarding the EIR and GHG emissions. (Pub. Resources Code, § 21167(b).) Under Public Resources Code section 21166(c), an agency may not require a supplemental environmental review unless new information, which was not known and could not have been known at the time the EIR was approved, becomes available. After a project has been subjected to environmental review, the statutory presumption flips in favor of the project proponent and against further review.4“‘[S]ection 21166 comes into play precisely because indepth review has already occurred [and] the time for challenging the sufficiency of the original EIR has long since expired ...’” (Id., 1050.) There is no competent evidence of new information of severe impact, and thus the Town may rely on an addendum. Accordingly, the Town finds that GHG impacts and climate change are not “new information” under Public Resources Code Section 21166.

Given the magnitude of the construction and operation of the proposed geothermal wells (as compared to full buildout of the Limelight Hotel and NVSP), GHG emissions associated with development of the Modified Project would be minimal. Additionally, as a renewable energy project, the proposed geothermal wells would result in a beneficial impact in contributing to Statemandated GHG reduction targets. As such, the proposed Modified Project would not result in any new substantial adverse GHG impacts not previously considered and addressed in the 1999 SPEIR.

Mitigation Program
The following measures from the certified 1999 SPEIR would also be applicable to the proposed project. Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.
3 Citizens for Responsible Equitable Environmental Development (CREED) v. City of San Diego, (2011) 196 Cal.App.4th 515, 531.
4 Moss v. County of Humboldt (2008) 162 Cal.App.4th 1041, 1049-1050.

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Applicable Mitigation Measures
1999 SPEIR

5.5-1a In order to reduce fugitive dust emissions, each development project shall obtain permits, as needed, from the Town and the State APCD and shall implement measures during grading and/or construction of the individual development sites to ensure compliance with permit conditions and applicable Town and APCD requirements.
a) The individual development projects shall comply with State, APCD, and Town, and Uniform Building Code dust control regulations, so as to prevent the soil from being eroded by wind, creating dust, or blowing onto a public road or roads or other public or private property.
b) Adequate watering techniques shall be employed on a daily basis to partially mitigate the impact of construction-generated dust particulates. c) Clean-up on construction-related dirt on approach routes to individual development sites/improvements shall be ensured by the application of water and/or chemical dust retardants that solidify loose soils. These measures shall be implemented for construction vehicle access, as directed by the Town Engineer. Measures shall also include covering, watering or otherwise stabilizing all inactive soil piles (left more than 10 days) and inactive graded areas (left more than 10 days).
d) Any vegetative ground cover to be utilized on the individual development sites/improvements shall be planted as soon as possible to reduce the amount of open space subject to wind erosion. Irrigation shall be installed as soon as possible to maintain the ground cover.
e) All trucks hauling dirt, soil or other loose dirt material shall be covered.

5.5-1b To reduce the potential of spot violations of the CO standards and odors from construction equipment exhaust, unnecessary idling of construction equipment shall be avoided.

3.6 NOISE
The 1999 SPEIR determined that buildout of the NVSP would generate noise from construction activities (i.e., truck hauling, excavation, grading) that may exceed the acceptable levels of noise exposure for the land uses surrounding the NVSP area, specifically the surrounding sensitive land uses. Additionally, operational activities (mobile source and stationary source) associated with buildout of the NVSP were determined to generate localized noise that could potentially exceed the acceptable levels of noise exposure for the land uses surrounding the NVSP area. As such, the 1999 SPEIR determined that upon implementation of Mitigation Measures 5.6-1a through 5.6- 1c, development of the NVSP would not result in significant noise impacts during project construction. The 1999 SPEIR also determined that upon implementation of Mitigation Measures

5.6-2a through 5.6-3e, development of the NVSP would not result in significant noise impacts during operations. The proposed modifications analyzed in the Mammoth Hillside Addendum were determined to result in no new impacts that were not previously analyzed in the 1999 SPEIR.

The Modified Project would involve the construction of a geothermal well system. The proposed construction activities for the Modified Project would require planning/permitting, site preparation, drilling and rig testing of the first well, drilling and rig testing of the second well, and well testing.

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Initial drilling and construction of the wells would require a drilling rig (mast approximately 100 feet high), and drilling services including, mud logging (collection of drilling and geologic information), drilling fluids, cementing services for casings, solids control and containment for sumpless drilling, site services (trash, water, restrooms, lights), drilling water and fuel delivery, consumable materials include drilling mud, cement, casings, wellhead. Drilling and completion of each well (24-hour operations) is anticipated to be 15 days each, with several rig move days between wells (daylight only). At the end of drilling the well, rig-on testing would require an air compressor package and services and pressure/temperature downhole survey company.

Blowout protection equipment would not be required for this well, based on the predicted temperature.

The Modified Project would be required to comply with Mitigation Measure 5.6-1a, which requires adherence to the Town’s construction hour limits with the exception of the drilling operations. The construction hour limits (7:00 a.m. and 10:00 p.m. from Monday through Saturday) have been modified below to be consistent with Town’s current construction hour requirements, as outlined in Chapter 8.16.090, Noise Prohibited Acts, of the Municipal Code. Mitigation Measures 5.6-1b and 5.6-1c would also be applicable for the Modified Project. Mitigation Measure 5.6-1b would require all construction equipment used on-site to be muffled. Mitigation Measure 5.6-1c would require the construction contractor to provide temporary sound barriers around the drilling rig. The project would also be required to comply with CalGEM requirements, such as ensuring that all temporary sound barriers are at least a minimum height of 16 feet. Upon implementation of Mitigation Measures 5.6-1a through 5.6-1c and applicable noise reduction BMPs, the Modified Project would not result in any new or potentially adverse construction noise impacts not previously considered and addressed in the 1999 SPEIR.

In operation, the geothermal wells are incorporated into the hotel facilities and noise levels would be contained within the enclosure. Operational activities associated with the proposed Modified Project would be required to comply with Chapter 8.16.070, Exterior Noise Limits, of the Municipal Code, which limits noise levels to 55 dBA between 7:00 a.m. and 10:00 p.m. and 50 dBA between 10:00 p.m. and 7:00 a.m. for the multi-family residential properties adjacent to the site to the east, south, and west classified as “Suburban Multiple Dwelling Residential” per the Municipal Code.

As stated in Section 3.4, Transportation, the number of vehicle trips or VMT as a result of the Modified Project implementation would not be substantial or greater than what was previously analyzed in the Mammoth Hillside Addendum or the 1999 SPEIR. Thus, the Modified Project would result in minimal to no increase in noise levels from mobile sources. The Modified Project would not result in any new or potentially adverse stationary source noise impacts not previously considered and addressed in the 1999 SPEIR.

Mitigation Program
The following measures from the certified 1999 SPEIR would also be applicable to the proposed project. Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

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Applicable Mitigation Measures
1999 SPEIR

5.6-1a Pursuant to Chapter 8.16.090.B.6 of the Town's Noise Ordinance Municipal Code, construction activities shall be limited to the hours of 7:00 a.m. to 8:00 p.m. Monday through Saturday and prohibited on Sunday or holidays, or as otherwise permitted by Chapter 8.16.090 with the exception of the well drilling activities as approved by the Town Public Works Department.

5.6-1b Construction equipment shall be muffled or controlled, if required, to meet Chapter

8.16 requirements for maximum noise generated by construction equipment.

Contracts shall specify that engine-driven equipment be fitted with appropriate noise mufflers.

5.6-1c The construction contractor shall provide temporary sound barriers around pile driving and well drilling sites to the satisfaction of the Town Engineer should such activities take place in areas within 400 feet of existing residential units, if required to meet Chapter 8.16 requirements.

3.7 GEOLOGY, SOILS, AND SEISMICITY
The 1999 SPEIR concluded that impacts regarding geology, soils, and seismicity would be less than significant with implementation of recommended mitigation measures. A preliminary geotechnical report was prepared based on conceptual plans by Sierra Geotechnical Services, Inc. in March 2004. The report indicated that project engineering is feasible; however, final grading and foundation plans should be reviewed to determine whether the conclusions of the report warrant reconsideration.

Seismic Hazards
According to the 1999 SPEIR while the project site is not located within a designated AlquistPriolo Fault Zone, the project site is located within an approximate 10-mile distance from the Mono Lake, June Lake, and Hilton Creek fault zones, as well as a 2.5-mile distance from the South Boundary fault zone. Each of these historically active fault zones are Alquist-Priolo Fault Zones.

Nevertheless, the project site is located within a highly seismically active region, and strong seismic ground shaking is likely to occur on-site. Implementation of Mitigation Measure 5.7-6 would require the completion of a geotechnical study, and would require recommendations to be included in the project design.

The Modified Project would include the drilling and installation of a new on-site closed-loop geothermal well system that would serve as a source of power solely for the property. The 1999 SPEIR determined that the risk of surface rupture, liquefaction, and landslides occurring on-site would be low. However, the project site is susceptible to ground shaking. The Modified Project must comply with 1999 SPEIR Mitigation Measure 5.7-6, which requires completion of a geotechnical investigation and implementation of any recommendations in the final design. All structures must be designed and built to at least the standards of the current Building Code Seismic Zone 4. With the implementation of 1999 SPEIR Mitigation Measure 5.7-6, impacts related to seismic hazards would be reduced to less than significant levels.

Unstable/Expansive Soils

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Regarding soil hazards at the project site, the 1999 SPEIR determined that slopes within the NVSP area are generally less than five percent and therefore severe natural slope instabilities are absent. However, on-site collapsible/loose sandy soils could potentially affect the structural integrity of development in the NVSP area. Nevertheless, implementation of recommended mitigation measures, which include removal and recompaction of collapsible/loose sandy soil, would reduce impacts in this regard to less than significant levels.

The proposed Modified Project would also be subject to 1999 SPEIR Mitigation Measure 5.7-6, which requires completion of a geotechnical investigation and implementation of any recommendations in the final design. With compliance with the 1999 SPEIR Mitigation Measure

5.7-6, the project would be required to comply with any recommendations included for the purpose of soil stability. Thus, the proposed Modified Project would not increase impacts beyond those anticipated in the 1999 SPEIR.

Soil Erosion
According to the 1999 SPEIR, existing slopes on-site are very dense and manufactured. However due to natural process and human activities (i.e., excavation and drilling) impacts, soil could result into slope failure, and are therefore considered unstable. This soil instability would make the project site more prone to soil erosion. Additionally, these manufactured slopes would increase the likelihood for a landslide hazard. The 1999 SPEIR determined that with incorporation of an Erosion and Sediment Control Plan (Mitigation Measure 5.7-7), future development would employ erosion/sediment control measures, particularly during construction activities.

The Modified Project would include soil disturbing activities similar in character to the Mammoth Hillside Project. The Modified Project would be required to comply with Mitigation Measures 5.7- 2a through 5.7-2c (which mitigate impacts on slopes and stability), Mitigation Measure 5.7-4 (which mitigates impacts related to erosion hazards), and Mitigation Measure 5.7-7 (which requires erosion/sediment control measures such as mulch, silt fencing, waddles, hay bales, and other erosion control devices). Thus, the Modified Project would not increase impacts beyond those anticipated in the 1999 SPEIR.

Mitigation Program
The following measures from the certified 1999 SPEIR would also be applicable to the proposed project. Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

Applicable Mitigation Measures
1999 SPEIR

5.7-1 Prior to issuance of grading or building permits, geotechnical studies shall be completed and their recommendations shall be incorporated in the project design, as stipulated in the Town’s Safety Policy #26.

5.7-2a Soils and foundation analyses shall be approved by Town staff prior to final project design approval, as stipulated in the Town's Safety Policy #18. All measures required by the Town shall be incorporated into final grading and building plans.

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5.7-2b The project applicant operator shall provide grading plans and receive approval from the Town Engineer. Said plans shall also show that new slopes within the project area are designed pursuant to slope requirements set forth within the Specific Plan and the standards of the Town's Municipal Code.

5.7-2c All work shall be overseen by a licensed Civil Engineer (CE), Certified Engineering Geologist (CEG), or similar appropriately qualified professional, who shall report to the Town Engineer in order to ensure the standards of the applicable Codes are met.

5.7-4 A comprehensive Erosion and Sediment Transport Control Plan shall be prepared by the project applicant operator and approved by the Town Engineer prior to the issuance of any grading or building permits. The Plan shall be included in the project design, as stipulated in the Town's Safety Policy #18. The Plan shall also meet the requirements of the Regional Water Quality Control Board and the Town Municipal Code.

5.7-6 The project applicant operator shall complete the geotechnical studies and incorporate their recommendations in the project design, as stipulated in the Town's Safety Policy #26. All structures shall be designed and built to at least the standards of UBC Seismic Zone 4.

5.7-7 Each The project operator shall cooperate with the Town in designing and disseminating information to assist citizens and visitors in responding to emergency situations that are likely to arise (Safety Policy #31). All structures shall be designed and built to at least the standards of UBCthe Current Building Code Seismic Zone 4.

3.8 HYROLOGY AND DRAINAGE
The 1999 SPEIR concluded that impacts regarding hydrology and drainage would be less than significant with implementation of recommended mitigation measures. A preliminary drainage study was prepared by CFA, Inc., in November 2005 for the Mammoth Hillside Project. According to the drainage study, the drainage system would utilize drop inlets, swales, and grading to direct flows from the proposed structures. Erosion control and storm water treatment measures would be placed in areas of possible erosion.

The proposed Modified Project would not have the potential to result in substantial changes to drainage and runoff on- or off-site, compared to that considered as part of the Mammoth Hillside Project. The proposed Modified Project would be required to comply with Mitigation measures

5.8-2b and 5.8-3 pertaining to water quality best management practices (BMPs). As such, impacts pertaining to drainage and runoff would be less than significant.

Proposed drilling activities for installation of the wells could impact water quality during construction. However, the proposed Modified Project would be subject to the Municipal Code Section 8.24.050(F)(10). As such, the proposed Modified Project would be subject to construction permit requirements, including proper dispose all drilling waste and cuttings in a manner approved by the Lahontan Regional Water Quality Board. As such, impacts in this regard would be less than significant.

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Groundwater Supplies
The 1999 SPEIR determined that, although the buildout of the NVSP would result in a decrease in the recharge area of the Mammoth Groundwater Basin, the buildout would not deplete groundwater resources. The proposed Modified Project would involve a closed-looped system in that cool freshwater would be injected back into the geothermal reservoir after extraction, via the proposed injection well. As such, the proposed geothermal well system would be balanced such that the geothermal reservoir would not be depleted. Geothermal is considered a renewable energy source, especially when maintained in this manner. Furthermore, the geothermal wells would not impact the groundwater. The proposed Modified Project geothermal system wells would produce fluids from 1,400 feet or greater and be sealed off from the upper aquifer. The geothermal well system is maintained through production from and offset by reinjection into the geothermal reservoir (not the groundwater supplies), which maintains a balance to the reservoir pressure.

The upper aquifer is the aquifer referenced in the Groundwater Management Plan for the Mammoth Basin Watershed (dated July 2005), and the proposed Modified Project does not utilize or impact such groundwater supplies. Therefore, the Modified Project would not conflict with such groundwater management plan and any potential impacts pertaining to groundwater supplies would be less than significant.

Mitigation Program
The following measures from the certified 1999 SPEIR would also be applicable to the proposed project. Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

Applicable Mitigation Measures

5.8-1b A more complete hydrology analysis for design purposes shall be required to be completed to estimate the amounts of runoff which will be required to be retained onsite for each development. The analysis shall be approved prior to issuance of a grading permit.

5.8-1c The following water conservation procedures shall be incorporated into project elements where feasible:
• Landscape with low water-using plants;
• Install efficient irrigation systems that minimize runoff and evaporation and maximize the water that will reach the plant roots, such as drip irrigation, soil moisture sensors, and automatic irrigation systems; and • Use pervious paving material whenever feasible.

5.8-2a An Erosion and Sediment Control Plan shall be prepared by the project proponents of individual development projects prior to issuance of grading permits. The Plan shall be reviewed and approved by the Town of Mammoth Lakes and the Lahontan Regional Water Quality Control Board and be in accordance with the erosion control guidelines as contained in the Mammoth Lakes SDMP and be in compliance with the Water Quality Control Plan (for the Lahontan Region [Basin Plan]). General grading

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activities, including those related to demolition and construction, would be regulated by the Uniform Current Building Code and Town of Mammoth Lakes Grading Ordinance. The required Erosion and Sediment Control Plan shall outline methods that will be implemented to control erosion and sediment transport from graded or cleared portions of the individual redevelopment/ improvement sites.

5.8-2d The Report of Waste Discharge shall contain a description of, and time schedule for implementation, for both the interim erosion control measures to be applied during project construction, and short- and long-term erosion control measures to be employed after the construction phase of the project. The descriptions shall include appropriate engineering drawings, criteria, and design calculations. The report guidelines are as follows:
• Drainage collection, retention, and infiltration facilities shall be constructed and maintained to prevent transport of the runoff from a 20-year, 1-hour design storm from the project site. A 20-year, 1-hour design storm for the Mammoth Lakes area is equal to 1.0 inch (2.5 cm) of rainfall in 1 hour. • Surplus or waste materials shall not be placed in drainage ways or within the 100-year flood plain of surface waters.
• All loose piles of soil, silt, clay, sand, debris, or earthen materials shall be protected in a reasonable manner to prevent any discharge to waters of the State.
• Dewatering shall be done in a manner so as to prevent the discharge of earthen materials from the site.
• All disturbed areas shall be stabilized by appropriate soil stabilization measures by October 15 of each year.
• All work performed between October 15th and May 1st of each year shall be conducted in such a manner that the project can be winterized within 48 hours. • Where possible, existing drainage patterns shall not be significantly modified. • After completion of a construction project, all surplus or waste earthen material shall be removed from the site and deposited at a legal point of disposal. • Drainage swales disturbed by construction activities shall be stabilized by the addition of crushed rock or riprap, as necessary, or other appropriate stabilization methods.
• All nonconstruction areas shall be protected by fencing or other means to prevent unnecessary disturbances.
• During construction, temporary erosion control facilities (e.g., impermeable dikes, filter fences, hay bales, etc.) shall be used as necessary to prevent discharge of earthen materials from the site during periods of precipitation or runoff.

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• Revegetated areas shall be regularly and continually maintained in order to assure adequate growth and root development. Physical erosion control facilities shall be placed on a routine maintenance and inspection program to provide continued erosion control integrity.
• Where construction activities involve the crossing and/or alteration of a stream channel, such activities shall be timed to occur during the period in which streamflow is expected to be lowest for the year.

3.9 BIOLOGICAL RESOURCES
The 1999 SPEIR determined that after implementation of recommended mitigation measures, development of the Approved TTM project would result in less than significant impacts. Potential impacts to species of concern, sensitive natural communities, wildlife corridors, and cumulative conditions were analyzed in the 1999 SPEIR. Mature trees removal and replacement was also addressed where tree removal is required to accommodate structures, access, and street frontage improvements.

The proposed Modified Project would not increase impacts beyond those anticipated in the 1999 SPEIR. Mitigation Measures 5.9-2a through 5.9-2j would still be applicable and would mitigate impacts relating to sensitive natural communities. With the implementation of these mitigation measures, as well as compliance with the Town’s current regulations related to biological resources, potential impacts in this regard would not increase, compared to that analyzed in the Mammoth Hillside Addendum and the 1999 SPEIR.

Mitigation Program
The following measures from the certified 1999 SPEIR would also be applicable to the proposed project. Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

Applicable Mitigation Measures
1999 SPEIR

5.9-2a The project shall preserve existing native vegetation to the maximum extent feasible.

Landscaping shall emphasize the use of native plants indigenous to the Jeffrey PineFir Forest plant community. Whenever possible, native plants used on-site shall be selected for their replacement habitat value. Site designs shall be subject to the Design Review procedure of the Town.

5.9-2b Landscape materials shall be used that allow for the protection and preservation of existing trees. Native plant species, preferably from seed or cuttings from local plants, shall be used where possible. The Landscape Plan shall be approved by the Planning Director prior to issuance of any construction permits.

5.9-2c Irrigation, fertilization, and other landscape management practices shall be designed to minimize effects on existing trees and other vegetation.

5.9-2d To the extent possible, native vegetation shall be retained and protected during construction. A Revegetation Plan, prepared by a qualified Landscape Architect and

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approved by the Town of Mammoth Lakes, shall be completed prior to the commencement of the project which will describe in detail the species of trees and shrubs which will be used, where they will be planted, and in what numbers, and the methods of planting and maintenance which will ensure successful growth. It shall include a monitoring program to follow the progress of new plantings and ensure replacement of unsuccessful plants. Landscaping with native species of trees and shrubs shall be undertaken to enhance wildlife use of cleared areas.

5.9-2e Under AB3180, once mitigation plans designed to off-set habitat losses are approved and the specific areas where they will be located are identified, the proponent must provide a program to monitor their progress for a period of time (usually three to five years) deemed sufficient by the Planning Director to assure their successful development. Adequate security shall be deposited with the Town to ensure successful implementation of this measure.

5.9-2f All construction activities, including movement and storage of vehicles and the storage of building and other materials, shall be confined to areas slated for development. Care shall be taken during construction to avoid damage to vegetation and habitats not directly involved in project construction. Any vegetation inadvertently damaged outside of the area slated for development shall be replaced on a one-to-one basis on- or offsite. Off-site replacement shall require the approval of the Town Planning Director.

5.9-2g To prevent erosion and siltation into intermittent creeks, areas cleared of vegetation, fill or other materials shall be stabilized after clearing and grading. Hay bales, silt screens or similar devices shall be used to prevent siltation. To further protect the drainage system and prevent erosion, all grading and construction shall be completed during the summer months, or after October 15 of each year be in a condition to be stabilized within 48 hours should inclement weather threaten.

5.9-2h A Forest Condition Survey shall be conducted by a professional forester and approved by the Town of Mammoth Lakes, prior to the commencement of each individual development project. All trees greater than 12-inches DBH (Diameter breast height (54 inches above ground)) and significant stands on each project site shall be mapped prior to issuance of grading permits or clearing. A registered forester or arborist shall then determine the age and condition of these trees and whether they should be retained or removed based upon health and visual significance of the trees, except for removal required by approved improvements. Once this determination is made, those trees shall be retained and integrated into the design of each project. A program of specific protection measures shall be prepared by the developer and approved by the Town prior to issuance of any construction permits (e.g., construction fencing, grading controls, grading design, etc.). Any trees removed unavoidably by each final project approval shall be in accordance with Town policies. Off-site replacement shall require approval by the Town’s Planning Director.

5.9-2i Slash generated from construction or thinning operations shall be hauled from the site concurrently with the operation to prevent a breeding site for IPS (bark beetle). Logs shall be removed from the site as soon as possible.

5.9-2j Construction and site development, such as grading and trenching, shall be prohibited within the dripline of retained trees. Equipment shall not be stored or driven under

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trees. Grading shall not cover the ground surface within the dripline of existing trees.

Grading limits shall be clearly defined and protected.

3.10 PUBLIC SERVICES/UTILITIES
The 1999 SPEIR analyzed potential impacts to public services including fire, police, schools, parks, and other public facilities as well as potential impacts to utilities including wastewater, stormwater drainage facilities, water supply, and solid waste. The 1999 SPEIR concluded that development of the Mammoth Hillside Project would create increased demand on utilities and service systems serving the area; however, impacts would be less than significant with incorporation of Mitigation Measures 5.10 1a though 5.10-1c, 5.10-3, 5.10-4a, 5.10-7, 5.10-8, and

5.10-9.

As discussed above, the Modified Project would not result in an increase in population. As a result, the Modified Project is not anticipated to result in an increase in demand for public services. As a geothermal well system, the propose Modified Project is not anticipated to result in an increase in the need for water or stormwater infrastructure or the generation of wastewater, compared to that analyzed in the 1999 SPEIR. Further, the proposed Modified Project would result in a reduction in the need for energy services, compared to that analyzed in the 1999 SPEIR.

As a geothermal well system, the project would not impact existing wastewater, stormwater drainage facilities, and electric/telecommunication facilities compared to that analyzed in the 1999 SPEIR. Freshwater would be extracted from the deeper geothermal reservoir, which is not connected to the aquifer used by the Mammoth Community Water District (MCWD). As such, the proposed Modified Project would result in a reduction in utility services and supply, compared to that analyzed in the 1999 SPEIR.

Mitigation Program
No mitigation measures were found to be feasible in the 1999 SPEIR for this topic area, and no new measures are feasible.

3.11 CULTURAL RESOURCES
The 1999 SPEIR analyzed potential impacts to historical, archaeological, and paleontological resources, as well as the disturbance of human remains. The 1999 SPEIR determined that future development may disturb the cultural and archaeological resources as well as any human remains. Specifically, ground-disturbing activities and an increase in population would result in direct and indirect impacts, respectively. The 1999 SPEIR concluded that, impacts regarding cultural resources would be less than significant with implementation of Mitigation Measures 5.11- 1a through 5.11-1e and 5.11-2. Similarly, the proposed modifications analyzed in the Mammoth Hillside Addendum were also determined to result in similar impacts.

It should be noted that the 1999 SPEIR did not analyze impacts to tribal cultural resources, as it was not required in the CEQA Guidelines at the time the EIR was prepared. It should be noted that the Town initiated the tribal consultant process for the purposes of SB 18 for the Mammoth Hillside Project January 17, 2017. Tribes listed on the California Tribal Consultation List prepared by Native American Heritage Commission (NAHC) for the Town were notified for the purposes of SB 18. As part of this process, each of the listed tribes were provided notification by the Town and the opportunity to consult with the Town regarding the Mammoth Hillside Project. The Walker

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River Reservation and Bridgeport Indian Colony have expressed no interest in consultation for the project. The Bishop Tribal Council requested a current Cultural Resources Report for the proposed project, and the Town provided the most recent Archaeological Survey for the North Village in response. No other responses have been received.

The proposed Modified Project would construct a geothermal well system on-site. Site disturbance activities that may disturb archaeological, historical, and cultural resources would be similar to that identified in the 1999 SPEIR. Mitigation Measure 5.11-1e relating to archaeological/historical resources discoveries, and Mitigation Measure 5.11-2 pertaining to potential burial sites, would be applicable to the Modified Project. With the implementation of Mitigation Measures 5.11-1e and 5.11-2, potential impacts pertaining to cultural and tribal cultural resources in this regard would not increase, compared to that analyzed in the 1999 SPEIR. Thus, no new impacts are identified for the Modified Project and no new mitigation measures are required.

Mitigation Program
The following measures from the certified 1999 SPEIR would also be applicable to the proposed project. Any modifications to the original measures are shown in strikethrough for deleted text and new, inserted text is underlined.

Applicable Mitigation Measures
1999 SPEIR

5.11-1e In the event that a material of potential cultural significance is uncovered during grading activities on the project site, all grading in the area of the uncovered material shall cease and the project applicant operator shall retain a professional archaeologist to evaluate the quality and significance of the material. Grading shall not continue in the area where a material of potential cultural significance is uncovered until resources have been completely removed by the archaeologist and recorded as appropriate.

5.11-2 If human remains are discovered, work shall cease and an appropriate representative of Native American Indian groups and the County Coroner shall both be informed and consulted, as required by State law.

3.12 ENERGY
The 1999 SPEIR did not evaluate energy resources as it was not required in the CEQA Guidelines at the time the EIR was prepared. However, Public Resources Code Section 21100(b)(3) and CEQA Guidelines Section 15126.4 require EIRs to describe, where relevant, the wasteful, inefficient, and unnecessary consumption of energy caused by a project. Therefore, energy consumption impacts associated with buildout of the NVSP was previously analyzed in the 1999 SPEIR. Accordingly, the Town finds that energy is not “new information” under Public Resources Code Section 21166.

The proposed Modified Project would construct a closed-looped geothermal well system that would solely support the property as a source of renewable on-site energy. This renewable energy would be used to provide heat, electricity, hot water, de-icing, and other beneficial uses within the Limelight property. Thus, given the nature of the Modified Project, the proposed geothermal system would not result in substantial consumption of energy resources, but would rather promote

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renewable energy generation. Although there would be electricity needed to power the proposed geothermal well system, this electricity used would be nominal and would be outweighed by the electricity generated during project operations. Therefore, the proposed Modified Project would not result in any new, different, or potentially adverse impacts to energy resources that were not previously considered and addressed in the 1999 SPEIR.

Mitigation Program
No mitigation measures were found to be feasible in the 1999 SPEIR for this topic area, and no new measures are feasible.

3.13 WILDFIRE
The 1999 SPEIR did not evaluate wildfire impacts, as it was not required in the CEQA Guidelines at the time the EIR was prepared. Therefore, the proposed Modified Project’s impacts, as currently proposed, is discussed below.

According to the California Department of Forestry and Fire Protection Mono County Fire Hazard Severity Zones in LRA Map, the project site is not located within a State Responsibility Area (SRA) nor is it classified as a very high fire hazard severity zone.5 However, it is acknowledged that the site is situated within a “Locally Responsible Area Moderate” fire hazard zone. 6 The proposed
Modified Project would not result in an adverse effect which could impede emergency evacuation routes serving the Town. Additionally, project modifications would be subject to review by CalGEM to ensure the project complies with fire safety requirements. The Modified Project, along with the Limelight Hotel development, would also be subject to payment fees that are currently imposed by the Town and used to fund required fire suppression equipment. Further, the Modified Project would be consistent with the design and safety standards set forth in the permits for the drilling, operation, and permanent sealing and closure that would be submitted to CalGEM. Compliance with fire requirements, emergency vehicle access, and payment of required fees would reduce potential impacts associated with the Modified Project to less than significant levels. As such, impacts regarding wildfire would be less than significant.

Mitigation Program
No mitigation measures were found to be feasible in the 1999 SPEIR for this topic area, and no new measures are feasible.

3.14 HAZARDS/HAZARDOUS MATERIALS
The 1999 SPEIR determined the future buildout of the NVSP would result in less that significant impacts associated with potential accidental releases of hazardous materials that may be present in on-site soils, and accidental conditions involving the use, transport, or disposal of hazardous materials. The 1999 SPEIR also determined that the future buildout of the NVSP would not result in hazardous impacts pertaining to an airport land use plan or a nearby private airstrip, nearby school, and wildland fires. Similarly, the proposed modifications analyzed in the Mammoth Hillside Addendum were also determined to result in no new impacts. 5 California Department of Forestry and Fire Protection, Mono County Fire Hazard Severity Zones in LRA Map, https://osfm.fire.ca.gov/media/6724/fhszl06_1_map26.pdf, September 21, 2007, accessed April 4, 2022. 6 Ibid.

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The proposed modifications would result in similar grading and construction activities to what was previously analyzed in the 1999 SPEIR and the Mammoth Hillside Addendum. However, the proposed Modified Project would involve drilling and operations of a geothermal well system onsite. The proposed Modified Project would be required to comply with existing State and local laws and regulations, including implementation of required BMPs. The proposed drilling, operation, and permanent sealing and closure (plugged and abandonment) of geothermal wells are required to comply with CalGEM’s Statues & Regulations, dated January 2020, or as amended at the time of future permits. BMPs would include an adequate drilling fluid program, casing program, spill contingency plan, appropriate well identification signage, installation of well safety devices, keeping of well records, ongoing testing activities during construction and operations, and appropriate plugging and abandonment at closure. Further, as part of Municipal Code Section 8.24.050(F)(10), geothermal drilling waste and cuttings shall be disposed of in a manner approved by the Lahontan Regional Water Quality Board. With the implementation of these BMPs and compliance to stated and regional regulations, potential impacts pertaining to the use, transport, or disposal of hazardous materials and/or the risk of upset or accidental conditions would be less than significant. As such, hazards and hazardous materials impacts associated with the proposed Modified Project would not increase, compared to that analyzed in the Mammoth Hillside Addendum and the 1999 SPEIR.

Mitigation Program
No mitigation measures were found to be feasible in the 1999 SPEIR for this topic area, and no new measures are feasible.

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4.0 DETERMINATION/ADDENDUM CONCLUSION
As detailed in the analysis presented above, this Addendum supports the conclusion that the proposed addition of the geothermal well system to the approved Limelight Hotel development would not result in any new significant environmental effects or a substantial increase in the severity of previously identified significant effects. No new information has become available and no substantial changes to the circumstances (under which the project was being undertaken) since the certification of the 1999 SPEIR and the Mammoth Hillside Addendum has occurred.

There are no new measures required and no new alternatives available that would substantially reduce the environmental effects beyond those previously described in the certified 1999 SPEIR and the Mammoth Hillside Addendum.

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
36 June 2022

5.0 ADDENDUM PREPARATION SOURCES/REFERENCES
California Environmental Quality Act, 1970, as amended, Public Resources Code Sections 21000-21189.

California Department of Conservation, Geologic Energy Management, Statues and Regulations, January 2020.

California Department of Forestry and Fire Protection, Mono County Fire Hazard Severity Zones in LRA Map, https://osfm.fire.ca.gov/media/6724/fhszl06_1_map26.pdf, September 21, 2007, accessed on April 4, 2022.

Geothermal Resource Group, Limelight Hotel Geothermal Drilling Study, June 2021.

Google Earth Maps, http://maps.google.com, accessed April 2022.

Netro Online, Historical Aerials, https://www.historicaerials.com/viewer, accessed April 5, 2022.

Town of Mammoth Lakes, Final Environmental Impact Report North Village Specific Plan, February 1991.

Town of Mammoth Lakes, North Village Specific Plan, 2000 (amended January 19, 2005, May 21, 2008, October 7, 2009, September 17, 2014, and December 3, 2014).

Town of Mammoth Lakes, North Village Specific Plan Environmental Impact Report Addendum, May 1994.

Town of Mammoth Lakes, Subsequent Program Environmental Impact Report for the North Village 1999 Specific Plan Amendment, October 13, 2000.

Town of Mammoth Lakes, Town of Mammoth Lakes Municipal Code, codified through Ordinance No.21-07, passed June 2, 2021.

Town of Mammoth Lakes, Town of Mammoth Lakes General Plan 2007, dated May 2007.

United States Department of the Interior Bureau of Land Management, Final Programmatic Environmental Impact Statement for Geothermal Leasing in the Western United States, October 2008.

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
37 June 2022

APPENDIX A
CEQA Limelight Hotel Conformance Checklist

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
A-1 June 2022
CEQA Limelight Hotel Conformance Checklist
Unit Mammoth Hillside
Addendum Project Limelight Hotel1
Total Site Area

6.9 acres
(4.0 acres for Phase 1)
(2.9 acres for Phase 2)

4.0 acres for Phase 1
Maximum Allowable Density 404 rooms
(320 rooms for Phase 1) 236 rooms
Maximum Site Coverage PR
Zone and SL zone combined
Maximum site coverage
119,678 sq.ft. 110,450 sq.ft. = 63.2%
Maximum Building Floor Area
601,170 square feet
(excluding structure
parking)
(348,000 square feet for
Phase 1)
185,754 feet (excluding
structure parking)1
Maximum Permitted Building
Height2,3,4,5 75 feet2
75 feet, 8 inches (roof
plane)2
8,150 elevation3
Maximum Projected Height2,3 90 feet3
8,135 elevation3
109 feet, 8 inches (highest
point of roof)3
8,150 elevation3
Parking Garage Height Maximum 20 feet above
natural grade 20 feet6
Setbacks7
Lake Mary Road/Main Street
0-24 feet 10 feet 60 feet
25-34 feet 20 feet 100 feet
35-54 feet 30 feet 100 feet
55 feet + 40 feet 100 feet
Canyon Boulevard Realignment
0-24 feet 10 feet 10 feet
25-34 feet 20 feet 40 feet
35-54 feet 30 feet 40 feet
55 feet + 40 feet 40 feet

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
A-2 June 2022
Unit Mammoth Hillside
Addendum Project Limelight Hotel1
Specific Plan Boundaries
0-24 feet 10 feet 50 feet
25-34 feet 20 feet 100 feet
35-54 feet 30 feet 100 feet
55 feet + 40 feet 100 feet
Notes:
1 Limelight Hotel Project consists of Phase I development only. 2 80 feet max subject to additional review and approval per NVSP Table 4. 3 No building improvements constructed within the restricted area described on exhibits b and b-i (the "north restricted area") shall exceed an elevation of 8,130 feet above sea level. For purposes of the recorded covenant, "sea level" shall be determined based on the current datum used by the town of mammoth lakes as of the effective date of the covenant. Notwithstanding the foregoing, (i) for any building, an area of roof length up to but not more than twenty (20) percent of the length of the building, when measured in a straight line along the building's longestaxis at the buildings' first level above grade, may be constricted between 8,130 feet and 8,135 feet above sea Level. If a building has two or more levels which could be considered the "first level above grade", the first level above grade with the longest axis shall be the level to be measured; and (ii) antennae, chimneys, turrets, cupolas and similar roof appurtenances may have a maximum elevation between 8,130 feet and 8,135 feet above sea level.
4 NVSP Section 5.c, For buildings that cross a land use district boundary after merging parcels, the highest permitted and projected heights shall apply to the entire building, providing the majority of building area is within the most liberal district, subject to design review considerations as applied through the design review process. 5 NVSP Section 5.d, …When all or a portion of a building sits above a parking garage, or when buildings front on the plaza in the PR district, building height shall be measured from the garage roof elevation or plaza elevation at the perimeter of the building.
6 NVSP Section 5.e, The plaza and parking garages shall be no more than 20 feet above natural grade at any point and shall be stepped, faced with storefronts or similarly treated to diminish the exposed height. 7 No setbacks required on internal side and rear lot lines of PR District.

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
38 June 2022

APPENDIX B
Mammoth Hillside
Mitigation Monitoring and Reporting Program

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
1 June 2022

MITIGATION MONITORING AND REPORTING CHECKLIST
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks

AETHETICS/LIGHT AND GLARE

5.3-1(c) Contour grading shall be used to blend
manufactured slopes into the natural terrain.

Grading shall be minimized to preserve existing
landform and vegetation to the greatest extent
possible.

Operator/ Civil
Engineer
Prior to Issuance
of a Grading
Permit
Community and
Economic
Development
Department Planning
Manager

5.3-1(d) The landscape design for the site shall maximize the use of existing vegetation, and where new plants
are introduced, they shall include, and/or blend with,
plants native to the Mammoth Lakes environment.

Landscape plans for the site shall be completed by
a certified landscape architect.

Operator/
Certified
Landscape
Architect
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.3-1(e) To the maximum extent practical, native trees and landscape shall be concentrated around all
structures located on the project site.

Operator/ Certified
Landscape
Architect
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.3-1(f) Grading techniques shall be used which minimize the areas of disturbance and shall incorporate such
methods as decorative retaining walls rather than
slopes to minimize the area of disturbance.

Operator/ Civil
Engineer
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.3-1(j) Staging locations shall be indicated on project Building Permit and Grading Plans and shall be
subject to review by the Town of Mammoth Lakes
Community Development Director in accordance
with Municipal Code requirements.

Operator Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.3-3(a) The Design Guidelines shall require that all exterior lighting be designed and located so as to avoid
intrusive effects on adjacent residential properties
Operator Prior to Issuance
of a Building
Permit
Community and
Economic
Development

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
2 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
and undeveloped areas adjacent to the project site.

Low-intensity street lighting and low-intensity
exterior lighting shall be used throughout the
development to the degree feasible. Lighting
fixtures shall use shielding, if necessary, to prevent
spill lighting on adjacent off-site uses.

Department Planning
Manager

5.3-3(b) Lighting used for various components of the
development plan be reviewed under North Village
Specific Plan design guidelines which shall include
review of light intensity levels, fixture height, fixture location, and design.

Operator Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.3-3(d) Vegetative buffers shall be used to reduce light intrusion on residential development and on
forested areas located adjacent to the project site.

Operator/
Certified
Landscape
Architect
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

AIR QUALITY

5.5-1(a) In order to reduce fugitive dust emissions, each development project shall obtain permits, as needed,
from the Town and the State APCD and shall
implement measures during grading and/or
construction of the individual development sites to
ensure compliance with permit conditions and
applicable Town and APCD requirements.
a) The individual development projects shall
comply with State, APCD, and Town, and
Uniform Building Code dust control
regulations, so as to prevent the soil from
being eroded by wind, creating dust, or
blowing onto a public road or roads or other
public or private property.
b) Adequate watering techniques shall be
employed on a daily basis to partially
Operator/
Construction
Contractor
Prior to Issuance
of Grading or
Building Permit/
During
Construction
Public Works
Director/ Designee

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
3 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
mitigate the impact of constructiongenerated dust particulates. c) Clean-up on construction-related dirt on
approach routes to individual development
sites/improvements shall be ensured by the
application of water and/or chemical dust
retardants that solidify loose soils. These
measures shall be implemented for
construction vehicle access, as directed by
the Town Engineer. Measures shall also
include covering, watering or otherwise
stabilizing all inactive soil piles (left more
than 10 days) and inactive graded areas
(left more than 10 days).
d) Any vegetative ground cover to be utilized
on the individual development
sites/improvements shall be planted as
soon as possible to reduce the amount of
open space subject to wind erosion.

Irrigation shall be installed as soon as
possible to maintain the ground cover.
e) All trucks hauling dirt, soil or other loose dirt
material shall be covered.

5.5-1(b) To reduce the potential of spot violations of the CO standards and odors from construction equipment
exhaust, unnecessary idling of construction
equipment shall be avoided
Operator/
Construction
Contractor
Prior to Issuance
of a Grading or
Building Permit/
During
Construction
Public Works
Director/ Community
and Economic
Development
Department Planning
Manager
NOISE

5.6-1(a) Pursuant to Chapter 8.16.090.B.6 of the Town's Noise Ordinance Municipal Code, construction
activities shall be limited to the hours of 7:00 a.m. to 8:00 p.m. Monday through Saturday and prohibited
Operator/
Construction
Contractor
Prior to Issuance
of a Grading
Permit and
Building Permit
Public Works
Director/ Building
Official

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
4 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
on Sunday or holidays, or as otherwise permitted by
Chapter 8.16.090 with the exception of the well
drilling activities as approved by the Town Public
Works Department.

5.6-1(b) Construction equipment shall be muffled or
controlled, if required, to meet Chapter 8.16
requirements for maximum noise generated by
construction equipment. Contracts shall specify that
engine-driven equipment be fitted with appropriate
noise mufflers.

Operator/
Construction
Contractor
Prior to Issuance
of a Grading
Permit or any
Construction
Permit
Public Works Director

5.6-1(c) The construction contractor shall provide temporary sound barriers around pile driving and well drilling
sites to the satisfaction of the Town Engineer should
such activities take place in areas within 400 feet of
existing residential units, if required to meet Chapter

8.16 requirements.

Operator/
Construction
Contractor
Prior to Issuance
of a Grading
Permit or any
Construction
Permit
Public Works Director

GEOLOGY, SOILS, AND SEISMICITY

5.7-1 Prior to issuance of grading or building permits, geotechnical studies shall be completed and their
recommendations shall be incorporated in the
project design, as stipulated in the Town’s Safety
Policy #26.

Operator/
Construction
Contractor
Prior to Issuance
of a Grading
Permit or
Building Permit
Public Works Director

5.7-2(a) Soils and foundation analyses shall be approved by Town staff prior to final project design approval, as
stipulated in the Town's Safety Policy #18. All
measures required by the Town shall be
incorporated into final grading and building plans.

Operator/
Construction
Contractor
Prior to Issuance
of a Grading
Permit or
Building Permit
Public Works Director

5.7-2(b) The project applicant operator shall provide grading plans and receive approval from the Town Engineer.

Said plans shall also show that new slopes within
the project area are designed pursuant to slope
requirements set forth within the Specific Plan and
the standards of the Town's Municipal Code.

Operator/
Construction
Contractor
Prior to Issuance
of a Grading
Permit
Public Works Director

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
5 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks

5.7-2(c) All work shall be overseen by a licensed Civil Engineer (CE), Certified Engineering Geologist
(CEG), or similar appropriately qualified
professional, who shall report to the Town Engineer
in order to ensure the standards of the applicable
Codes are met.

Operator/
Construction
Contractor/ Civil
Engineer/
Certified
Engineering
Geologist
Prior to Issuance
of a Grading
Permit or
Building Permit
Public Works Director

5.7-4 A comprehensive Erosion and Sediment Transport
Control Plan shall be prepared by the project
applicant operator and approved by the Town
Engineer prior to the issuance of any grading or
building permits. The Plan shall be included in the
project design, as stipulated in the Town's Safety
Policy #18. The Plan shall also meet the
requirements of the Regional Water Quality Control
Board and the Town Municipal Code.

Operator/
Construction
Contractor/ Civil
Engineer
Prior to Issuance
of a Grading
Permit or
Building Permit
Public Works Director

5.7-6 The project applicant operator shall complete the geotechnical studies and incorporate their
recommendations in the project design, as
stipulated in the Town's Safety Policy #26. All
structures shall be designed and built to at least the
standards of UBC the Current Building Code
Seismic Zone 4.

Operator/
Construction
Contractor/ Civil
Engineer/
Certified
Engineering
Geologist
Prior to Issuance
of a Grading
Permit or
Building Permit
Public Works Director

5.7-7 Each The project operator shall cooperate with the Town in designing and disseminating information to
assist citizens and visitors in responding to
emergency situations that are likely to arise (Safety
Policy #31). All structures shall be designed and
built to at least the standards of UBC Seismic Zone

4. Operator Prior to Issuance
of a Grading
Permit or
Building Permit/
During
Construction/
During
Operations
Community and
Economic
Development
Department Planning
Manager

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
6 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks

HYDROLOGY AND DRAINAGE

5.8-1(b) A more complete hydrology analysis for design
purposes shall be required to be completed to
estimate the amounts of runoff which will be required
to be retained on-site for each development. The
analysis shall be approved prior to issuance of a
grading permit.

Operator/ Civil
Engineer
Prior to Issuance
of a Grading
Permit
Public Works Director

5.8-1(c) The following water conservation procedures shall be incorporated into project elements where
feasible:
• Landscape with low water-using plants;
• Install efficient irrigation systems that
minimize runoff and evaporation and
maximize the water that will reach the
plant roots, such as drip irrigation, soil
moisture sensors, and automatic irrigation
systems; and
• Use pervious paving material whenever
feasible.

Operator/ Certified
Landscape
Architect
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.8-2(a) An Erosion and Sediment Control Plan shall be
prepared by the project proponents of individual
development projects prior to issuance of grading
permits. The Plan shall be reviewed and approved
by the Town of Mammoth Lakes and the Lahontan
Regional Water Quality Control Board and be in
accordance with the erosion control guidelines as
contained in the Mammoth Lakes SDMP and be in
compliance with the Water Quality Control Plan (for
the Lahontan Region [Basin Plan]). General grading
activities, including those related to demolition and
construction, would be regulated by the Uniform
Current Building Code and Town of Mammoth Lakes
Grading Ordinance. The required Erosion and
Sediment Control Plan shall outline methods that will
Operator/ Civil
Engineer
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager/ Lahontan
RWQCB

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
7 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
be implemented to control erosion and sediment
transport from graded or cleared portions of the
individual redevelopment/ improvement sites.

5.8-2(d) The Report of Waste Discharge shall contain a
description of, and time schedule for
implementation, for both the interim erosion control
measures to be applied during project construction,
and short- and long-term erosion control measures
to be employed after the construction phase of the
project. The descriptions shall include appropriate
engineering drawings, criteria, and design
calculations. The report guidelines are as follows:
• Drainage collection, retention, and
infiltration facilities shall be constructed
and maintained to prevent transport of the
runoff from a 20-year, 1-hour design storm
from the project site. A 20-year, 1-hour
design storm for the Mammoth Lakes area
is equal to 1.0 inch (2.5 cm) of rainfall in 1
hour.
• Surplus or waste materials shall not be
placed in drainage ways or within the 100-
year flood plain of surface waters.
• All loose piles of soil, silt, clay, sand,
debris, or earthen materials shall be
protected in a reasonable manner to
prevent any discharge to waters of the
State.
• Dewatering shall be done in a manner so
as to prevent the discharge of earthen
materials from the site.
• All disturbed areas shall be stabilized by
appropriate soil stabilization measures by
October 15 of each year.

Operator/ Civil
Engineer
Prior to Issuance
of a Building
Permit/
Operations
Community and
Economic
Development
Department Planning
Manager/ Lahontan
RWQCB

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
8 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
• All work performed between October 15th
and May 1st of each year shall be
conducted in such a manner that the
project can be winterized within 48 hours.
• Where possible, existing drainage
patterns shall not be significantly
modified.
• After completion of a construction project,
all surplus or waste earthen material shall
be removed from the site and deposited at
a legal point of disposal.
• Drainage swales disturbed by
construction activities shall be stabilized
by the addition of crushed rock or riprap,
as necessary, or other appropriate
stabilization methods.
• All nonconstruction areas shall be
protected by fencing or other means to
prevent unnecessary disturbances.
• During construction, temporary erosion
control facilities (e.g., impermeable dikes,
filter fences, hay bales, etc.) shall be used
as necessary to prevent discharge of
earthen materials from the site during
periods of precipitation or runoff.
• Revegetated areas shall be regularly and
continually maintained in order to assure
adequate growth and root development.

Physical erosion control facilities shall be
placed on a routine maintenance and
inspection program to provide continued
erosion control integrity.
• Where construction activities involve the
crossing and/or alteration of a stream

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
9 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
channel, such activities shall be timed to
occur during the period in which
streamflow is expected to be lowest for the
year.

BIOLOGICAL RESOURCES

5.9-2(a) The project shall preserve existing native vegetation to the maximum extent feasible. Landscaping shall
emphasize the use of native plants indigenous to the
Jeffrey Pine-Fir Forest plant community. Whenever
possible, native plants used on-site shall be selected
for their replacement habitat value. Site designs
shall be subject to the Design Review procedure of
the Town
Operator/ Certified
Landscape
Architect
Prior to Issuance
of a Grading
Permit or any
Construction
Permit that would
impact existing
vegetation
Community and
Economic
Development
Department Planning
Manager

5.9-2(b) Landscape materials shall be used that allow for the protection and preservation of existing trees. Native
plant species, preferably from seed or cuttings from
local plants, shall be used where possible. The
Landscape Plan shall be approved by the Planning
Director prior to issuance of any construction
permits.

Operator/ Certified
Landscape
Architect
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.9.2(c) Irrigation, fertilization, and other landscape management practices shall be designed to
minimize effects on existing trees and other
vegetation.

Operator/ Certified
Landscape
Architect
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

5.9.2(d) To the extent possible, native vegetation shall be retained and protected during construction. A
Revegetation Plan, prepared by a qualified
Landscape Architect and approved by the Town of
Mammoth Lakes, shall be completed prior to the
commencement of the project which will describe in
detail the species of trees and shrubs which will be
used, where they will be planted, and in what
numbers, and the methods of planting and
Operator/ Certified
Landscape
Architect
Prior to Issuance
of a Building
Permit
Community and
Economic
Development
Department Planning
Manager

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
10 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
maintenance which will ensure successful growth. It
shall include a monitoring program to follow the
progress of new plantings and ensure replacement
of unsuccessful plants. Landscaping with native
species of trees and shrubs shall be undertaken to
enhance wildlife use of cleared areas.

5.9.2(e) Under AB3180, once mitigation plans designed to off-set habitat losses are approved and the specific
areas where they will be located are identified, the
proponent must provide a program to monitor their
progress for a period of time (usually three to five
years) deemed sufficient by the Planning Director to
assure their successful development. Adequate
security shall be deposited with the Town to ensure
successful implementation of this measure.

Operator/ Monitor Operations (3-5
years)
Community and
Economic
Development
Department Planning
Manager

5.9.2(f) All construction activities, including movement and storage of vehicles and the storage of building and
other materials, shall be confined to areas slated for
development. Care shall be taken during
construction to avoid damage to vegetation and
habitats not directly involved in project construction.

Any vegetation inadvertently damaged outside of
the area slated for development shall be replaced on
a one-to-one basis on- or off-site. Off-site
replacement shall require the approval of the Town
Planning Director.

Operator/
Construction
Contractor
Prior to Issuance
of a Building or
Grading Permit/
During
Construction
Public Works
Director/ Community
and Economic
Development
Department Planning
Manager

5.9.2(g) To prevent erosion and siltation into intermittent creeks, areas cleared of vegetation, fill or other
materials shall be stabilized after clearing and
grading. Hay bales, silt screens or similar devices
shall be used to prevent siltation. To further protect
the drainage system and prevent erosion, all grading
and construction shall be completed during the
summer months, or after October 15 of each year be
Operator/
Construction
Contractor
During
Construction
Public Works
Director/ Community
and Economic
Development
Department Planning
Manager

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
11 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
in a condition to be stabilized within 48 hours should
inclement weather threaten.

5.9.2(h) A Forest Condition Survey shall be conducted by a professional forester and approved by the Town of
Mammoth Lakes, prior to the commencement of
each individual development project. All trees
greater than 12-inches DBH (Diameter breast height
(54 inches above ground)) and significant stands on
each project site shall be mapped prior to issuance
of grading permits or clearing. A registered forester
or arborist shall then determine the age and
condition of these trees and whether they should be
retained or removed based upon health and visual
significance of the trees, except for removal required
by approved improvements. Once this
determination is made, those trees shall be retained
and integrated into the design of each project. A
program of specific protection measures shall be
prepared by the developer and approved by the
Town prior to issuance of any construction permits
(e.g., construction fencing, grading controls, grading
design, etc.). Any trees removed unavoidably by
each final project approval shall be in accordance
with Town policies. Off-site replacement shall
require approval by the Town’s Planning Director.

Operator/
Construction
Contractor/
Professional
Forester or
Arborist
Prior to Issuance
of Grading
Permit or
Clearing/ Prior to
Issuance of any
Construction
Permits
Public Works
Director/ Community
and Economic
Development
Department Planning
Manager

5.9.2(i) Slash generated from construction or thinning
operations shall be hauled from the site concurrently
with the operation to prevent a breeding site for IPS
(bark beetle). Logs shall be removed from the site
as soon as possible.

Operator/
Construction
Contractor
Prior to Issuance
of a Building
Permit/ During
Construction
Public Works
Director/ Community
and Economic
Development
Department Planning
Manager

5.9.2(j) Construction and site development, such as grading and trenching, shall be prohibited within the dripline
of retained trees. Equipment shall not be stored or
Operator/
Construction
Contractor
Prior to Issuance
of a Building
Public Works
Director/ Community
and Economic

Limelight Hotel
Addendum to the North Village Specific Plan
Environmental Impact Report
12 June 2022
1999 SPEIR
Mitigation
Number
Mitigation Measure Implementation
Responsibly Timing Monitoring Responsibility

VERIFICATION OF COMPLIANCE
Initials Date Remarks
driven under trees. Grading shall not cover the
ground surface within the dripline of existing trees.

Grading limits shall be clearly defined and protected.

Permit/ During
Construction
Development
Department Planning
Manager

CULTURAL RESOURCES

5.11-1(e) In the event that a material of potential cultural significance is uncovered during grading activities
on the project site, all grading in the area of the
uncovered material shall cease and the project
applicant operator shall retain a professional
archaeologist to evaluate the quality and
significance of the material. Grading shall not
continue in the area where a material of potential
cultural significance is uncovered until resources
have been completely removed by the archaeologist
and recorded as appropriate.

Operator/
Construction
Contractor/
Professional
Archaeologist
During
Construction
Community and
Economic
Development
Department Planning
Manager

5.11-2 If human remains are discovered, work shall cease and an appropriate representative of Native
American Indian groups and the County Coroner
shall both be informed and consulted, as required by
State law.

Operator/
Construction
Contractor/
Professional
Archaeologist
During
Construction
Community and
Economic
Development
Department Planning
Manager

Appeal 1
Ms. Jo Bacon Appeal

Appeal 2
Mammoth Community Water District

{00275039.1} Attachment A- Page 1 of 8

ATTACHMENT A
TO MAMMOTH COMMUNITY WATER DISTRICT’S APPEAL OF PEDC
APPLICATION NO. TTM 22-002, ET AL.

What Is Being Appealed?
The Mammoth Community Water District (“MCWD” or “District”) appeals the decision of the Town of Mammoth Lakes Planning and Economic Development Commission’s (“PEDC” or “Commission”) action to approve the addition of two geothermal wells to the Limelight Hotel project (“Project”). These two geothermal wells would provide heating and other power requirements to the Project (the “Geothermal Component”). This approval was based on the use of a CEQA addendum and was part of the PEDC’s approval at its May 11, 2022 meeting of the staff recommendation under Agenda Item 4.2 to adopt Resolution 22-12 to make CEQA and Municipal Code findings and approving Tentative Tract Map #TTM 22- 002, Use Permit #UPA 22-001, and Major Design Review #DR 22-001 with conditions.

MCWD appeals only the approval of the addition of the Geothermal Component to the Project as an illegal action in violation of CEQA. MCWD does not object to or appeal from any other portion of the approvals made by the PEDC at its May 11, 2022 meeting.

Rationale For Appeal:

I. The addendum to the 1999 EIR violates CEQA because neither the Addendum nor the Drilling Report on which it relies includes any analysis of potentially significant environmental effects or any substantial evidence to support a noeffect finding permitting the preparation of the Addendum.

The substantive part of MCWD’s appeal is simple -- PEDC staff engaged in undue haste to bring the Geothermal Component to the Commission for approval and in complete disregard of known and identified potentially significant environmental impacts that might result from drilling geothermal wells in the heart of the Town of Mammoth Lakes and directly through the community’s main water supply. PEDC staff also misrepresented the character of the Geothermal Component, thus making it appear less impactful than it would be in reality. In fact, any reasonably diligent and lawful analysis would have identified the possibility for the Geothermal Component to cause significant environmental impacts. Most notably, the construction and operation of the Geothermal Component has the potential to reduce and/or contaminate the Town’s water supply, perhaps severely enough that there is a significant possibility no remediation could effectively treat the contamination to safe drinking water levels. If such an impact occurred, the Mammoth Lakes community would not have a safe, reliable drinking water supply.

Sadly, this appeal was entirely avoidable if the PEDC had granted MCWD’s request and stayed any action to approve the Geothermal Component pending consultation with MCWD, CalGEM, and other stakeholders. The necessity for filing this appeal, which wastes public resources and imposes significant new legal risks on the Town, is particularly

{00275039.1} Attachment A- Page 2 of 8
egregious because MCWD’s concerns about the impacts of geothermal projects is longstanding and well-known to Town/PEDC staff and everyone else in the community. Yet, despite PEDC staff’s knowledge, they only made a casual effort to engage MCWD or other stakeholders early in the process of working with the developer on a generic geothermal project and appear to have withheld the details of the applicant’s actual proposal to add the Geothermal Component to the Project to the last possible moment. This lack of basic diligence required by law occurred even though applicant’s proposed change to the Project was being contemplated as least as early as June 8, 2021, when the Geothermal Resource Group issued its Limelight Hotel Geothermal Drilling Study (the “Drilling Report”). Note that the Drilling Study identified the possibility of impacts from the Geothermal Component and MCWD’s likely concerns with the proposal more than one year ago. (See Drilling Report, subsection 6.1.2, page 44; subsection 6.4.1, pages 45-46; and attached March 5, 2021 letter to Dan Patton and Greg Villegas of WATG, pages 1-2.) In spite of these identified concerns, and a 220-page staff report which appears to be PEDC staff’s effort to paper over the defects in its process to evaluate the new Geothermal Component and include stakeholder input, PEDC staff concluded without any real investigation, communication or analysis, and without any substantial technical or other evidence, that, “the proposed addition of the [Geothermal Component] to the Limelight Hotel development would not result in any new significant environmental effects or a substantial increase in the severity of previously identified significant effects.” (See Staff Report for PEDC consideration of Project approvals, Key Issue #4, page 574 of 593 of May 11, 2022 PEDC meeting agenda packet (the “May 11 Packet”).) Yet nowhere in the 220-page staff report and attachments for this item is there any meaningful analysis of potential effects or anything supporting PEDC staff’s conclusion that none exist. The CEQA addendum prepared to support the approval of the Geothermal Component makes conclusions that no impacts would occur, but fails to cite any technical data or studies to support that conclusion. (See, e.g., May 11 Packet, Limelight Hotel – Addendum to the North Village Specific Plan Environmental Impact Report, May 2022 (the “Addendum”), Section 3.8, Groundwater Supplies, page 641; addendum, Section 3.10, Public Services/Utilities, page 645; Addendum, Section 3.14, Hazards/Hazardous Materials, page 647.)
To compound its failure to comply with CEQA, PEDC staff’s so-called “analysis” is based on at least two false premises. The first false premise is that the Geothermal Component would be a “closed loop system”, meaning that a heat transfer fluid is circulated through a closed loop of pressure-tight piping underground or submerged in water, and a heat exchanger transfers heat between the refrigerant in a heat pump and the heat transfer fluid in the closed loop.. (See, e.g., May 11 Packet, Staff Report for PEDC consideration of Project approvals, Table 3, page 567; Addendum, Section 3.8, Groundwater Supplies, page 641.) But the fact is that the Geothermal Component is not intended to be a closed loop system at all, as a simple reading of the Drilling Report would reveal. (See Drilling Report, Executive Summary, fourth paragraph, page 5; subsection 3.1, page 31.)

{00275039.1} Attachment A- Page 3 of 8
The second false premise is that the Addendum properly and completely describes the Geothermal Component, so that there is an “accurate, stable and finite project description,” which California courts recognize as “the sine qua non” of an informative and legally sufficient CEQA review document.1 The lack of a proper description of the Geothermal Component is a sufficient basis alone to invalidate the Addendum and reverse the PEDC’s approval of the Geothermal Component.

The insufficiency of the Addendum as a basis for the PEDC to approve such a significant change in the Project is apparent because the Addendum describes the Geothermal Component as consisting only of an open-loop geothermal well system. But the Addendum fails to discuss how those wells would be harnessed to actually generate power and heat. In fact, the well could not do anything by themselves. In order to operate them as a power system, the applicant also will be required to construct and operate mechanical systems in order to heat, cool or generate electricity utilizing the geothermal energy produced by the wells. There is no mention or discussion of such a plant, nor of its location or the potential hazards inherent in such an operation. Those hazards include heat transfer fluids used in the power system and risks inherent in their transportation, handling, and storage. Such fluids can be toxic and require special handling and containment facilities.

Yet, the only project description and supporting evidence PEDC staff relies on is a concept provided by the Project applicant in the form of the Drilling Report, which was written for the express purpose of evaluating the geologic and economic feasibility of a geothermal project. The report does not contain any meaningful identification or analysis of potentially significant impacts that might be caused by the Geothermal Component, including pressure effects and water quality effects that could result from drilling and operation of the two offset, open-loop wells. The Drilling Report also fails to fully describe the Geothermal Component’s true scope or risks inherent in this new Project element, or propose any mitigation measures or alternatives to address the potential impacts. (See Drilling Report, generally and Introduction, pages 6-7.)
There is much more that renders PEDC’s staff’s use of the Addendum illegal under CEQA.

MCWD’s chief concern, and an issue which barely rated a mention in the 220-page staff report, is that the two wells to be drilled as part of the Geothermal Component would be located between 1,000 and 1,700 feet of one of the District’s major production wells, Well 17.

This well produces up to 25% of MCWD’s drinking water in dry years when minimum amounts of surface water are available, including in the 2022 water year. Thus, Well 17 is critical for maintaining adequate water supplies to serve the Mammoth Lakes community in a drought year, such as we are currently in. In addition, Well 17 is already the warmest well in the District’s groundwater supply system, with a chemical composition indicative of mixing with geothermal waters as documented by the United States Geological Survey’s (USGS) 2019 analysis of monitoring data collected as part of the CD-IV Groundwater Mitigation and Monitoring Program (USGS, 2019). This geothermal water has higher 1 City of San Jose v. Great Oaks Water Co. (1987) 192 Cal.App.3d 1005, 1017.

{00275039.1} Attachment A- Page 4 of 8
concentrations of heavy metals and dissolved constituents including arsenic which is already elevated at Well 17 compared with other MCWD wells. If the concentration of arsenic, and other contaminates including chloride and boron, increases as a result of drilling and operating the Geothermal Component, it could make water from Well 17 untreatable. All PEDC staff had to do was pick up the phone and call MCWD staff to obtain this information and identify the potential for such a significant environmental impact.

Additional defects in the Addendum process and the basis for a much more robust CEQA analysis in the form of a supplemental or subsequent EIR include the following.

The Drilling Report mentions that the applicant will need to provide proof of noninteraction with water supply, yet there is no discussion regarding how this will be accomplished. Or of the level of risk of interaction or any mitigation measures or alternatives that might avoid such potential harm to the Mammoth Lakes community’s water supply.

The Project documents also paint an overly simplistic representation of a “shallow reservoir” and the “deeper reservoir” and assumes, without evidence, that they are completely distinct and separated by an aquitard or other barrier that the well driller can simply punch through and case without any ill effects. These are all unsubstantiated assumptions that are neither analyzed in any meaningful way or supported by any references to technical data or documents or included in the record. As noted in the Drilling Report, “…the entire property sits above the Long Valley Caldera ring fracture zone, which is a known conduit for geothermal fluids just to the north.” The report’s authors point this out because they hope to drill into rock with lots of faulting and high permeability. The same faulting could be a conduit to transport untreatable geothermal fluids into the “shallow reservoir” comprising the community’s drinking water supply. The Drilling Report also notes that both the “shallow reservoir” and the “deeper reservoir” have elevated Chloride to Boron ratios indicating geothermal influence in both. There is even speculation in the report on how the geothermal fluids might be mixing in the system. Yet, PEDC staff ignored all of these potentially serious adverse impacts and instead dismissed them with no more than a conclusion that is essentially “there is nothing to see here, so let’s move on.”
Given the evident, potentially serious adverse environmental impacts of the proposed new Geothermal Component and its novel use in Mammoth Lakes, not only did PEDC staff have a duty to properly identify and fully analyze those impacts, but staff had an obligation in the circumstances to evaluate potentially feasible mitigation measures and project alternatives. For example, the Drilling Report advises that a true “closed-loop” heat pump system could be an effective alternative. Another option might be an off-site geothermal power system located in a much lower-risk location that could serve the existing and future

{00275039.1} Attachment A- Page 5 of 8
North Village Specific Plan Area development.2 Also, given the risks of the Geothermal Component and the Project applicant’s unequivocal statements at the May 11, 2022 PEDC meeting that use of geothermal energy in the Project is significantly more expensive, a “no project” alternative should have been evaluated because it would pose less risk to the drinking water and less risk to the applicant. This failure is sufficient grounds for the Town Counsel to reverse the PEDC’s approval of the Geothermal Component and to direct that PEDC staff prepare a supplemental or subsequent EIR which includes an appropriate alternatives analysis.

Likewise, in light of the readily available information that the new Geothermal Component had the potential to cause significant environmental effects, PEDC staff should have considered what mitigation measures might be required to reduce those potential impacts to less than significant. Feasible measures include pre-Project modeling, construction of monitoring wells both to collect pre-Project baseline water quality and pressure data and to monitor on-going operations to help in early detection of possible migration of geothermal fluids from the deep reservoir into the cold shallow reservoir that provides the community water supply, stress tests as part of well commissioning, and an adaptive monitoring and remediation plan if early impacts are detected. Many of these mitigation measures have been incorporated in the mitigation and monitoring plan for Ormat’s Casa Diablo-IV project.

MCWD hereby provides Appendix 1 to this appeal, which is a technical memorandum prepared by the District’s consulting hydrogeologists, West Yost Associates. This technical memorandum analyzes the Addendum and Drilling Report and explains those documents’ deficiencies and identifies the potentially significant environmental impacts of the Geothermal Component that would have been readily identifiable and subject to further analysis in any competent and diligent CEQA review of this significant Project change.

II. The PEDC violated CEQA by failing to comply with its duties as the lead agency when it failed to perform any meaningful analysis of the potentially significant effects of the Geothermal Component.

The procedural part of MCWD’s appeal also is simple – The PDEC violated CEQA by evading its role as lead agency for the project and instead delegating its independent and primary duty to have analyzed the potentially significant effects of the Geothermal Component to a responsible agency, in this case the Division of Geologic Energy Management Division of the California Department of Conservation (“CalGEM”). This violation is an independent and sufficient ground for the Town Council to reverse the PEDC’s approval of the Geothermal Component.
2 The existing Village development is already plumbed to be operated using geothermal energy. Also note that MCWD has the latent power in statute to own and operate a geothermal energy system to serve the Town.

{00275039.1} Attachment A- Page 6 of 8
It is well established that CEQA embodies California’s “strong and enduring public policy to protect the environment” by requiring state and local agencies to execute their duty to give “major consideration” to preventing environmental damage.3 The purpose of CEQA is to: (1) inform agency decision-makers and the public about potential, significant environmental effects of proposed projects; (2) identify ways that environmental damage can be avoided or significantly reduced; (3) prevent potentially significant damage from projects by changing them through use of feasible alternatives or mitigation measures; and (4) disclose to the public the reasons why an agency approved a project involving significant environmental impacts.4 As the California Supreme Court has ruled:

CEQA review is undertaken by the lead agency, defined as “the public agency which has the principal responsibility for carrying out or approving a project which may have a significant effect on the environment.” The lead agency’s function in the environmental review process is so important that it cannot be delegated to another body.
5 As noted in Section 15020 of Title 14 of the California Code of Regulations (hereafter, the “CEQA Guidelines”):

A public agency must meet its own responsibilities under CEQA and shall not rely on comments from other public agencies or private citizens as a substitute for work CEQA requires the lead agency to accomplish. For example, a lead agency is responsible for the adequacy of its environmental documents. The lead agency shall not knowingly release a deficient document hoping that public comments will correct defects in the document.

As also stated, and often repeated, by the California Supreme Court and appellate courts, the EIR is the “heart of CEQA” and is required to inform the public and its responsible officials of the environmental consequences of a decision before it is made. To fulfill this duty, a public agency must not only use an EIR to identify the environmental impacts and mitigation measures to be considered in a CEQA review, but also project alternatives including a no project option. The alternatives and mitigation analysis forms “the core of an EIR.”6
This appeal involves an addendum to an existing EIR, which has been modified several times previously. As PEDC staff admits both in the Addendum itself and several times during the agenda item at the May 11, 2022 PEDC meeting to consider the addition of the 3 Friends of the Eel River v. North Coast Railroad Authority (2017) 3 Cal.5th 677, 712, citing Public Resources Code section 21067.
4 Tomlinson v. County of Alameda ((2012) 54 Cal.4th 281, 285-286. 5 Public Resources Code section 21002.1, subd. (d) [“The lead agency shall be responsible for considering the effects, both individual and collective, of all activities involved in a project.”]; Friends of the Eel River, supra, 3 Cal.5th at pages 712-713 (italics added; original emphasis and internal citations omitted).
6 Id., at page 713.

{00275039.1} Attachment A- Page 7 of 8
Geothermal Component, the Geothermal Component is an entirely new addition to the Project that was not previously considered or analyzed in the 1999 SEIR or any previous modification to it. The new and previously unanalyzed addition of the Geothermal Component fundamentally changes an important aspect of the Project – substituting a relatively rare, unconventional energy source for heating and powering a hotel operation instead of using conventional propane and electrical power sources already available from existing providers immediately within the Project vicinity.

CEQA permitted the PEDC to consider using a CEQA addendum for the Project change to include the Geothermal Component. But the PEDC staff’s decision to use an addendum required complying with Public Resources Code section 21166 and CEQA Guidelines section 15162 by finding, on the basis of substantial evidence in light of the record, that the Geothermal Component would not involve any new significant environmental effects not known or reviewed in previous project CEQA documents and that would necessitate the preparation of a supplemental or subsequent EIR. As noted in CEQA Guidelines section 15164, an addendum may only be used if project changes are minor and technical in nature.

If a determination to use an addendum is not supported by substantial evidence in the record, it is subject to challenge and a court may invalidate the addendum.7 As noted in Part I of this appeal, the PEDC’s decision was made without any substantial evidentiary support in the record. Town staff simply concluded, without any analysis, supporting evidence or consultation with responsible agencies and experts, that the Geothermal Component would not have any significant environmental impacts. Worse, and as noted in this Part II, PEDC staff simply absolved itself of addressing the issue in any meaningful way and instead punted the issue without any basis in fact to CalGEM.

In an analogous case involving the City of San Jose’s proposed change in water supply sources for a land use project approval, a California Court of Appeal concluded that the city violated CEQA by “simply ignor[ing] the potentially adverse environmental impacts wrought by a change in the water supply system from one based on . . . preexisting wells to one based on . . . proposed new wells in an area known to have underground contamination of the water supply.”8 The court was particularly concerned that the lack of any substantive analysis of potential impacts of the project change deprived the public and agency decisionmakers of any meaningful participation and information, noting that, “Only through an accurate view of the project may affected outsiders and public decision-makers balance the proposal’s benefit against its environmental cost, consider mitigation measures, assess the advantage of terminating the proposal and weigh other alternatives in the balance.9

In addition, PEDC staff violated CEQA by failing to perform their duty to engage in early and full collaboration with MCWD, CalGEM, and other responsible agencies to assist in staff’s identification and analysis of the potentially significant effects of the Geothermal 7 Save our Heritage Organisation v. City of San Diego (2018) 28 Cal.App.5th 656, 667. 8 City of San Jose v. Great Oaks Water Co., supra, 192 Cal.App.3d at pages 1016-1017. 9 Id., at page 1017.

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Component. Because the Geothermal Component is an entirely new Project component and raises the potential for significant environmental effects that would not have been raised when the Project was planned to use conventional power sources delivered by established providers, PEDC staff should have engaged with MCWD and other responsible agencies as soon as possible after the Project applicant proposed replacing conventional power sources with the Geothermal component. This is particularly true of those with special expertise such as MCWD and CalGEM. (Public Resources Code section 21153, see also, Section 21003.1; CEQA Guidelines section 15086.)
As recognized by PEDC staff both in the staff report and in verbal comments during the May 11, 2022 PEDC meeting, both MCWD and CalGEM have special interests and expertise regarding the potential environmental effects of drilling and operating geothermal wells. In spite of this admitted knowledge, MCWD staff only learned of the specific details of the proposed Geothermal Project when it received agenda notice of it on May 6 and, even then, had to ask PEDC staff to provide the Drilling Report. Staff did not provide the report until May 10, one day before the PEDC meeting at which this significant change was approved. Staff’s obvious failure to consult with expert and responsible agencies also was clear at the hearing – they could not describe the CalGEM permitting process or provide the commission any assurance of the scope of CalGEM’s authority to further review or condition the Geothermal Component. As shown on Appendix 2 to this appeal, the scope of CalGEM’s authority and review of the Geothermal Component will be extremely limited and is unlikely to include any substantive CEQA review of the component’s potentially significant environmental effects.

MCWD’s Request for Council Action in Response to this Appeal:

Based on the PEDC’s violations of CEQA in approving the Geothermal Component, MCWD requests that the Town Council reverse the approval of the Geothermal Component and remand the issue to the PEDC with direction to: (1) conduct an appropriate review of the potential environmental impacts of the Geothermal Component, which is a completely new component of the Project not analyzed in the 1999 SEIR or any subsequent environmental document prepared for it. That direction also should instruct PEDC staff to consult with MCWD, CalGEM, and other interested regulatory/responsible agencies including Mono County, the Great Basin Unified Air Pollution Control District, the SWRCB’s Division of Drinking Water, and Lahontan Regional Water Quality Control Board, in order to obtain information about potentially significant environmental effects of the new Geothermal Component of the Project; and (2) prepare a supplement to the SEIR or subsequent EIR as necessary to analyze any significant impacts of the Geothermal Component and alternatives to the Geothermal Component identified during the study and consultation with responsible and expert agencies.

2020 Research Park Drive
Suite 100
Davis CA 95618
530.756.5905 phone
530.756.5991 fax
westyost.com
{00275225.1}
APPENDIX 1

TECHNICAL MEMORANDUM
DATE: May 25, 2022 Project No.: 947-80-20-02
SENT VIA: EMAIL
TO: Mammoth Community Water District
FROM: Kenneth Loy, PG #7008
REVIEWED BY: Mark Wildermuth, PE, RCE #32331
SUBJECT: Preliminary Review of Limelight Hotel, Addendum to the North Village Specific Plan Environmental Impact Report, and Limelight Hotel Geothermal Drilling Study
West Yost conducted a preliminary review of the referenced documents and identified several concerns, which are documented in this technical memorandum.

BACKGROUND
Limelight Mammoth, LLC (Applicant) has requested approval to develop a 185,754 square foot, 166-unit condominium hotel (Limelight Hotel project) within the Town of Mammoth Lakes’ (Town) North Village Specific Plan (NVSP) area. The Town made the determination that the Limelight Hotel project, as currently proposed, is consistent with prior NVSP environmental analyses required by the California Environmental Quality Act (CEQA), except for a proposed geothermal well system, which would be located at the Limelight Hotel project, and would be used to offset propane gas and electricity use by supplying heat, electricity, hot water, de-icing, and other beneficial uses for Limelight Hotel facilities.

The Applicant commissioned a study titled Limelight Hotel Geothermal Drilling Study (Geothermal Drilling Study) (Geothermal Resource Group, Inc. [GRG], 2021). As documented in the Geothermal Drilling Study, GRG evaluated the geologic setting and concluded that “geothermal wells drilled on the property have a strong likelihood of achieving the project goals of 85-250 gallons per minute (gpm) of water between 140-175°F”. The Geothermal Drilling Study did not include site-specific drilling, testing or water quality sampling, and did not provide analysis of the potential impacts to the Town’s groundwater resourcesfrom the proposed geothermal well system.

Mammoth Community Water District (MCWD) provides potable water supply to the Town, and groundwater is a significant source, comprising 100 percent of the Town’s supply during summer and fall months and more of the year during drought conditions. The proposed Limelight Hotel project is located in MCWD’s service area and within the area from which MCWD pumps groundwater for drinking water supply. Notably, MCWD-17, a major production well that supplies up to 25 percent of the total groundwater supply, is located between 1,000 and 1,700 feet from the proposed Limelight Hotel project’s proposed geothermal well system.

TM – Mammoth Community Water District
May 25, 2022

{00275225.1} N-C-947-80-20-028-WP-TM-LIMELIGHT
The Town prepared the Limelight Hotel, Addendum to the North Village Specific Plan Environmental Impact Report (EIR Addendum) to address the CEQA requirements for the proposed geothermal well system (Town of Mammoth Lakes, 2022). EIR Addendum Section 2.1, Addendum’s Purpose and Need, concludes that no “Substantial changes are proposed in the project, which will require major revisions of the previous EIR or negative declaration due to the involvement of new significant environmental effects or a substantial increase in the severity of previously identified significant effects.” Section 3.8, Hydrology and Drainage states that the proposed geothermal well system “would involve a closed loop system” and goes on to conclude that, “the upper aquifer is the aquifer referenced in the Groundwater Management Plan for the Mammoth Basin Watershed (dated July 2005), and the proposed Modified Project does not utilize or impact such groundwater supplies. Therefore, the Modified Project would not conflict with such groundwater management plan and any potential impacts pertaining to groundwater supplies would be less than significant.” The EIR Addendum also concluded that the addition of the proposed geothermal well system would not require new mitigation measures.

PRIMARY CONCERN
Although the EIR Addendum states that potential impacts to groundwater supplies would be less than significant, neither the EIR Addendum nor the Geothermal Drilling Study provide any evaluation or technical analysis of the potential impacts to the beneficial uses of groundwater resources resulting from the proposed geothermal well system or to support the conclusion that no significant impacts would occur. The proposed geothermal well system would be located in an important groundwater resource area beneficially used for municipal and domestic drinking water supplies and in close proximity to an important MCWD municipal supply well. The proposed project could cause depletion to, or contamination of, the Town’s drinking water supplies.

The primary scientific concern is the potential for the operation of the proposed geothermal well system to degrade groundwater quality. The EIR Addendum and the Geothermal Drilling Study assert, but do not demonstrate with any technical analysis or evidence, that the proposed geothermal reservoir is isolated from the groundwater resource area and the drinking water supply wells within it. The Geothermal Drilling Study notes that both the “shallow reservoir” and the “deeper reservoir” have elevated chloride to boron ratios indicating geothermal influence in both. The Geothermal Drilling Study also points out that the Limelight Hotel project “sits above the Long Valley Caldera ring fracture zone, which is a known conduit for geothermal fluids just to the north.” These faults and fractures may also be conduits for the lateral or vertical movement of mineral-laden geothermal waters or brines into the groundwater resource area used for drinking water supply. The similarity of chloride to boron ratios in water samples from the “deeper reservoir” and the “shallow reservoir” is evidence that these conduits exist and provide pathways for the movement and intermixing of water and geothermal fluids. Connectivity between the “shallow reservoir” and “deeper reservoir” is well documented in the United States Geologic Survey’s Open-File Report 2019-1063 entitled “Hydraulic, Geochemical, and Thermal Monitoring of an Aquifer System in the Vicinity of Mammoth Lakes, Mono County, California, 2015-17.

The proposed project will place new stresses on the Mammoth Basin’s complex hydrologic system.

Operation of the proposed geothermal well system will change the spatial distribution of pressure in the geothermal reservoir. Pressure will decrease near the proposed extraction well and increase near the proposed injection well. These changes in pressure will result in flow gradients towards the proposed extraction well and away from the proposed injection well. Movement of geothermal fluids will occur along conduits subject to flow gradients. As stated above, the geologic and water quality data demonstrate the existence of a connection between the deeper geothermal reservoir and the shallow groundwater aquifer. Therefore, changes in reservoir pressure caused by the proposed geothermal well

TM – Mammoth Community Water District
May 25, 2022

{00275225.1} N-C-947-80-20-028-WP-TM-LIMELIGHT
system have the potential to introduce increased flows of geothermal waters into the potable groundwater supply. This intermixing could cause potentially significant water quality degradation in the groundwater supply, which in turn could cause exceedances of drinking water regulatory standards in public supply wells. In addition, because of the nature of this kind of impact, any significant inducement of contaminated fluids into the water supply aquifer could persist for decades. If the contamination is extreme enough, the quality of the community water supply could be rendered too contaminated to effectively treat to even minimum drinking water standards.

MCWD wells that have geothermal influence (including MCWD-17) have higher concentrations of arsenic, boron, and chloride than other colder-temperature MCWD wells. Data shows that wells with geothermal influence generally have arsenic concentrations about five to forty times greater than colder-temperature MCWD wells.

As of 2018, the average arsenic concentration in MCWD-17 was about 10 times the California and federal Maximum Contaminant Level (MCL) of 0.010 milligrams per liter (mg/L). To meet drinking water standards, MCWD already must blend high-arsenic waters from MCWD-17 with groundwater from MCWD wells with low-arsenic concentrations and then treat this blended supply to produce water that meets arsenic concentrations below the MCL. The arsenic concentration in the geothermal fluid in the Casa Diablo geothermal well field (the same geothermal reservoir the Applicant proposes to use) is very high (1.0 to 1.5 mg/L, which is 10 to 15 times the arsenic concentration in MCWD-17), and this arsenic is a source of the high arsenic concentrations in MCWD-17. Future increases in arsenic concentrations in MCWD-17 waters due to increases in geothermal fluid intruding into the shallow groundwater aquifer could increase MCWD’s treatment costs and, at some point, could require MCWD to shut down MCWD-17 until MCWD could upgrade the groundwater treatment capacity to handle the increased arsenic concentration, which would be very expensive.

MCWD operates under Permit No. 05-13-14P-014 from the California State Water Resources Control Board – Division of Drinking Water (DDW). Condition 3 of the permit states, “The District shall protect its sources from any encroachment by sanitary hazards. In particular, any new possible contaminating activity (PCA) shall be noted in the Source Assessment”. The proposed geothermal well system is a PCA and construction of the project would likely require an update to the Source Assessment for MCWD-17 and could lead to additional monitoring and treatment requirements from DDW.

If there is a long-term imbalance between the proposed geothermal production and injection, the resulting reductions in pressures in the geothermal reservoir may cause groundwater to seep downwards into the geothermal reservoir. This could cause a drop in the water table in the shallow reservoir and may cause the geothermal fluids in the deeper reservoir to boil and release steam and other gases that could seep upwards through fractures and contaminate the shallow groundwater aquifer used by MCWD. These potential impacts are not hypothetical and have been observed in the nearby Casa Diablo geothermal well field.

The EIR Addendum refers to the proposed geothermal well system as a “closed-loop geothermal well system”. This is misleading. A “closed loop system” is one in which a heat transfer fluid is circulated through a closed-loop of pressure-tight piping underground or submerged in water, and a heat exchanger transfers heat between the refrigerant in a heat pump and the heat transfer fluid in the closed loop.

Although volumetrically equal amounts of geothermal fluids are proposed to be extracted and injected with no net change in the volume of geothermal fluids in the reservoir, it cannot be said that all of the same fluids will be recycled through the system. The proposed extraction well will capture fluids in a threedimensional volume surrounding the well intake. Some of these fluids will originate from the injection well; others will be captured from storage in the surrounding rock comprising the reservoir. Similarly,

TM – Mammoth Community Water District
May 25, 2022

{00275225.1} N-C-947-80-20-028-WP-TM-LIMELIGHT
fluids injected through the proposed injection well will be distributed in the three-dimensional volume around the injection well. Some of these fluids will be captured by the extraction well, while others will move away from the well into the surrounding rock. This means that operation of the proposed geothermal well system will result in a partial recycling of geothermal fluids along with a continual flow of fluids towards the proposed extraction well and away from the proposed injection well along conduits not connected to each well’s respective pair but potentially connected to the potable groundwater of the groundwater resource area. Again, this could result in water quality degradation in the groundwater supply and exceedances of drinking water regulatory standards in public supply wells.

OTHER CONCERNS
CEQA requires projects to prepare and evaluate project alternatives where feasible. The Geothermal Drilling Study states that a true closed-loop heat pump system could be an effective alternative if geothermal fluid temperature and/or permeability do not meet expectations.

The description of the proposed geothermal well system does not describe in any detail the mechanical systems that will be used to heat, cool or generate electricity. The project description does not describe if or what type of heat transfer fluids are proposed.

The Geothermal Drilling Study states that the applicant will need to provide proof of non-interaction with the water supply; however, there is no discussion regarding how this will be accomplished.

CONCLUSION
The EIR Addendum and the Geothermal Drilling Study do not evaluate potential impacts to the beneficial uses of groundwater resources resulting from the Limelight Hotel project’s proposed geothermal well system. Potential water quality impacts to the groundwater resource area and drinking water wells within it could be potentially significant, persistent over many years and very difficult to remediate after they are manifested.

RECOMMENDATIONS
The CEQA analysis should be revised to evaluate the potential effects of the proposed geothermal well system on the groundwater resource area, the beneficial uses of this resource, and the municipal and domestic well infrastructure. The analysis should include the construction, testing and monitoring of test wells to support the impact analysis and the development of a monitoring program.

The CEQA analysis should be revised to consider project alternatives, including true closed-loop systems.

Monitoring and mitigation measures appropriate to the revised analysis should be developed.

Technical studies should be conducted to support a more complete and definitive evaluation of the potential impacts of the proposed geothermal well system on the groundwater resource area, the beneficial uses of this resource, and the municipal and domestic well infrastructure.

TM – Mammoth Community Water District
May 25, 2022

{00275225.1} N-C-947-80-20-028-WP-TM-LIMELIGHT

REFERENCES
Geothermal Resource Group, Inc. 2021. Limelight Hotel Geothermal Drilling Study. June 8.

Town of Mammoth Lakes. 2022. Limelight Hotel, Addendum to the North Village Specific Plan Environmental Impact Report. May 3.

United States Geologic Survey. 2019. Open-File Report 2019-1063 entitled “Hydraulic, Geochemical, and Thermal Monitoring of an Aquifer System in the Vicinity of Mammoth Lakes, Mono County, California, 2015-17.

1 Garrett Higerd
From: Salera, Jerry@DOC <[email protected]> Sent: Monday, May 23, 2022 5:37 PM
To: Garrett Higerd
Cc: Mark Busby; Wardlow, Charlene@DOC
Subject: RE: Limelight Hotel Geothermal Project
Follow Up Flag: Follow up
Flag Status: Flagged
Hi Garrett,
I’m sorry I have not been able to respond right away to your email. I did see you called as well and left me 2 voice messages.

With respect to the EIR Addendum and the request for us to support MCWD’s appeal, I think we cannot take a position. We have not received any Notices of Intentions (NOIs) and any accompanying documentation for us to review and evaluate.

In answer to your questions:
• Who is the decision-making body at CalGEM that will make the decision on the permit and file the CEQA Notice of Determination?
I review the application together with my Associate Engineer and the Geothermal Program Manager approves the permit on behalf of the State Oil and Gas Supervisor, the top person in CalGEM.
• When in the process will we be able to review and comment? In the typical process for reviewing and approving drilling permits, we don’t engage the public for comments. We just want to make sure that the proposal conforms/meets our regulations.

However, for the operation of the injection well, we will accept public comments for a certain period during the injection permitting process. As mentioned before, the injection permitting process also involves EPA Region 9 (based in San Francisco).

• How many other geothermal projects are there in the state in such proximity to a community’s drinking water supply? Can you provide examples?
Offhand, I can mention injection projects we have permitted in Susanville (Lassen Co.), Calistoga (Napa Co.) and Alturas (Modoc Co.) where there are USDWs in proximity to the project area. Similarly, in Desert Hot Springs in Riverside Co. we have not permitted any injection but only production wells.

Sincerely,
APPENDIX 2

2 Jerry Salera
Senior Oil and Gas Engineer (Supervisor)
Geothermal Program
CA Geologic Energy Management Division (CalGEM)
715 P Street, MS 18-03, Sacramento, CA 95814
M: (916) 203-7785
[email protected]

Appeal 3
Monache Condominium Owners
Association, Inc.

ATTORNEYS AT LAW
A LAN A. B LAKEBORO 1421 S TATE S TREET , S UITE B
J OHN G. B USBY S ANTA B ARBARA , CA 93101
R . M ARK C ARNEY
B ARTON E. C LEMENS , J R . T ELEPHONE : (805) 966 - 2440 R OBERT B . F OROUZANDEH FACSIMI LE : (805) 966 - 3320
D IANA J ESSUP LEE WWW . R EICKERPFAU. COM
K EVIN R . N IMMONS RMCARNEY @ RPPMH . COM
M ICHAEL E. P FAU
D ANIEL A. REICKER
R USSELL D. T ERRY
TIMOTHY J. T RAGER
F ERNANDO V ELEZ , J R .

M EGHAN K. W OODSOME

C ORY T. B AKER
N ICHOLAS A. B EHRMAN
D IANE Y. B YUN
A NDREW W. H AZLETT
June 30, 2022
Mayor Lynda Salcido By E-Mail Only
Town Council
Town of Mammoth Lakes
Mammoth Lakes, CA 93546
Re: Aspen Skiing Company's Opposition to the Appeal filed by Monache Condominium Owners Association, Inc. (the "HOA") of the Approval of the Limelight Mammoth Hotel and Residences ("Limelight") by the Planning and Economic Development Commission ("PEDC") Dear Mayor Salcido:

My firm represents Aspen Skiing Company and The Little Nell Hotel Group ("Aspen") in connection with the HOA's appeal of the PEDC's May 11, 2022 approval of Aspen's application for a Tentative Tract Map, Conditional Use Permit, and Major Design Review ("Entitlements") for the Limelight. This summary letter, together with Attachment 1, which provides a more detailed response to each of the HOA's contentions, comprise Aspen's opposition to the appeal.

To document its approval of the Entitlements at its May 11, 2022 hearing, the PEDC adopted PEDC Resolution No. 2022-12 (the "Resolution"). The HOA's appeal challenges five components of the PEDC's approval of the Entitlements, as set forth in the Resolution: (1) Roof Design and Equipment Screening; (2) Noise; (3) Hours of Construction; (4) CEQA Findings; and (5) Grading and Tree Removal. This letter and Attachment 1 address each category in order.

I. The Limelight's Roof Design and Equipment Screening Comply with the North Village Specific Plan and the Design Guidelines for The Village at Mammoth.

The HOA makes two primary contentions to support its claim that the Limelight's roof design and equipment screening do not comply with the North Village Specific Plan ("NVSP") and the Design Guidelines for the Village at Mammoth ("NV Design Guidelines"). First, the HOA contends that the Limelight's predominantly flat roof "represents a significant departure from the

Date: June 30, 2022
Page: 2
NVSP and design guidelines." Second, the HOA contends that the hotel's rooftop mechanical equipment is not "integrated into the roof or dormer design to avoid visual impact on other properties." Aspen disputes both contentions.

A. Roof Design.

The Resolution notes that because the Limelight is located within the NVSP area, it is subject to the NV Design Guidelines rather than the Town of Mammoth Lakes Design Guidelines.

The introduction to the NV Design Guidelines states that they are "intended to have sufficient flexibility to allow for incorporation of future creative design solutions, advances in building materials technologies, and proactive responses to the dynamics of the market place that improve the project." The guidelines invite applicants "to submit creative and imaginative projects which build on the Guidelines and contribute to the evolving character of the Village." The application of the guidelines "is intended to be reasonable and practical, and not as regulations." The Resolution finds that the Limelight is consistent with the NV Design Guidelines because the "site design and building design elements including the architectural style, size, design quality, use of building materials, and similar elements, combine together in an attractive and visually cohesive manner that is compatible with and complements the desired architectural and/or aesthetic character of the area and a mountain resort community, encourages increased pedestrian activity, and promotes compatibility among neighboring land uses." The Resolution also makes a specific finding that "the roofline of the hotel provides variation through varied wall heights and wall offsets" and that "a parapet wall serves to screen roof-mounted equipment and incorporates a cornice detail to add depth and detail to the roof form." [Page 5, paragraph 3, emphasis added.] The HOA contends that the design of the Limelight's roof "represents a significant departure from the NVSP and design guidelines" because it is predominantly flat. Nonetheless, the HOA concedes that the NVSP specifically provides that "flat roofs will be allowed where required for snow management, upper level exterior uses or architectural character" [Page 48, paragraph 11. a., emphasis added] and that "flatter [roof] slopes will be permitted for specific design effect or snow management purposes." [Page 23, paragraph 2]

The administrative record establishes beyond dispute that the Limelight's flat roof is required for snow management, upper level exterior use, and architectural character. Specifically, the lead architect for the Limelight spoke at the PEDC hearing and confirmed that the flat roof:
(1) provides better support for the structure itself and the heavy snow loads that the roof will carry; and (2) controls snow shedding much more effectively, which significantly enhances circulation and reduces risks of injury in the pedestrian-friendly environment that encircles the hotel. In addition, the Limelight may provide a rooftop social space for guests, with outdoor furniture and a spa, atop a portion of the four-story section, which requires a flat roof. Finally, the flat roof complements the Limelight's minimalist architectural character and contemporary aesthetic, in recognition of the preferences and demands of the mountain resort marketplace.

Date: June 30, 2022
Page: 3
B. Equipment Screening.

The NV Guidelines provide: "Mechanical equipment and elements such as video receivers must be concealed from view to the extent feasible." [Emphasis added.] The Limelight has been designed to conceal mechanical equipment to the extent feasible. The Limelight's mechanical equipment is not visible from any public property, right of way, or sidewalk. Accordingly, the Resolution states that "a parapet wall serves to screen roof-mounted equipment and incorporates a cornice detail to add depth and detail to the roof form." [Page 5, paragraph 3] Nonetheless, the HOA seizes upon one sentence in the NVSP to challenge the configuration of the Limelight's rooftop mechanical equipment: "Mechanical, electrical and roof access equipment, vents and antenna shall be integrated into the roof or dormer design to avoid visual impact on other properties." The HOA focuses on this one sentence in the NVSP, and ignores the more specific NV Design Guideline, because it does not include the qualifying clause "to the extent feasible." But it need not include that clause; the policies of the NVSP, in line with the NV Design Guidelines, are intended to be applied in a "reasonable and practical" manner.

Any requirement for rooftop mechanical, electrical, and roof access equipment to be invisible from a higher vantage point on a neighboring property would not be reasonable or practical. Therefore, the only logical interpretation of this NVSP provision is that mechanical equipment must be shielded to avoid visual impact on the ground level of other properties. The Limelight's mechanical equipment will not be visible from the ground level of any property in Mammoth. In fact, the only vantage point in the entire town from which the mechanical equipment may be visible is a handful of condo hotel units located on the top two floors on the southeast side of the Westin Monache.

Ironically, the only reason that any section of the Limelight roof may be visible from those upper-floor units is that a portion of the Limelight property is burdened by a restrictive covenant which limits its height to four stories to preserve those units' views of the Sherwin Mountains to the south. Those mountain views will not be impacted by the Limelight.

In spite of the fact that the configuration of the Limelight's mechanical equipment complies with the NV Design Guidelines, Aspen offered to provide additional screening for the mechanical equipment consistent with the materials and colors of the building. Alas, the HOA rejected Aspen's offer and chose instead to pursue its appeal. Nonetheless, Aspen's offer remains open. Digital depictions of the proposed screening, from the vantage point of a 6th floor unit on the south side of the Westin Monache, are attached as Exhibit A to Attachment 1.

Date: June 30, 2022
Page: 4
II. The Terms of Aspen's Approval Comply with the Noise Element of the NVSP and the Town's Noise Ordinance.

Condition 38 of the Resolution provides: "Noise generated by the project shall meet the applicable requirement of the Specific Plan and/or the Town's noise regulations, as applicable. In addition, during the PEDC hearing, Aspen consented to an additional condition by which it will be required, prior to the issuance of a certificate of occupancy for the hotel, to provide evidence that the rooftop equipment complies with the Town’s Noise Ordinance.

Nonetheless, the HOA appealed the PEDC's approval of the Entitlements based upon its unfounded concern that noise "will emanate from the mechanical equipment on the rooftop" of the Limelight and "will travel up the hillside toward units of the Westin Monache during times of the year when owners and guests of units facing the Project like to avail themselves of open windows and balconies, including at night when ambient noise is reduced and people wish to sleep with open windows."
The Westin Monache units that are closest to the Limelight are approximately 80 feet away from the four-story section of the hotel and approximately 130 feet away from the 6-story section, so the likelihood that anyone at the Westin Monache will hear the equipment is remote. Moreover, the Limelight's roof has parapets that will serve to attenuate any potential noise impact. In addition, Aspen has offered to screen the mechanical equipment which, in addition to mitigating any potential visual impacts, would serve to mitigate any noise. However, the HOA rejected Aspen's offer and instead, chose to pursue its appeal. In any event, the Resolution requires Aspen to comply with the Town's Noise Ordinance, and to provide the Town evidence of that fact prior to opening the Limelight.

III. Aspen's Proposed Hours of Construction Will Comply with the Requirements of the Town's Municipal Code.

The HOA's appeal challenges the extended hours of construction during which Aspen would be permitted to dig the geothermal well. However, for reasons unrelated to the HOA's appeal, Aspen has requested the Town to amend the Project Description for the Limelight to eliminate any reference to the geothermal system. Therefore, the HOA's appeal of the hours or construction for well digging has been rendered moot.

In addition, the HOA's appeal challenges clauses in the Resolution and the Addendum to the NVSP Environmental Impact Report ("Addendum") which state, erroneously, that the hours of construction for the project will be Monday through Saturday, from 7:00 a.m. to 10:00 p.m.

The HOA correctly observes that the Town's Municipal Code limits the hours of construction to Monday through Saturday, from 7:00 a.m. to 8:00 p.m. We understand that the Town has revised the Resolution and the Addendum accordingly.

Date: June 30, 2022
Page: 5
IV. The HOA's Claim that the Addendum is Inadequate Has Been Rendered Moot by the Revised Project Description, Which Does Not Include a Geothermal System.

The HOA contends that the Addendum is not adequate because "it fails to address noise pollution associated with the construction and drilling phase of the geothermal wells." As discussed above, Aspen has requested the Town to amend the Project Description for the Limelight to eliminate any reference to the geothermal system. Therefore, the HOA's claim that the Addendum is inadequate because it fails to address any noise associated with construction and drilling of the geothermal system has been rendered moot.

V. The Town's Issuance of the Rough Grading Permit is Authorized by Aspen's Existing Entitlements and, Therefore, Is Not a Proper Basis for Appeal.

The HOA challenges the fact the Town issued a rough grading permit to enable Aspen to begin site work before the Council addresses the HOA's appeal of the PEDC's approval of the Entitlements. The Town's issuance of the rough grading permit is authorized by the existing entitlements for the property, which were approved in 2015. Therefore, the Town's issuance of the rough grading permit is not a proper basis for appeal of the Entitlements.

VI. Conclusion.

For the reasons set forth above and in Attachment 1, Aspen respectfully requests the Town Council to deny the HOA's appeal. Thank you for your careful consideration of Aspen's request.

Sincerely,
REICKER, PFAU, PYLE & McROY LLP
By R. Mark Carney
CC: Members of the Town Council (By E-Mail)
Sandra Moberly (By E-Mail)
Kim Cooke (By E-Mail)
Andrew Morris (By E-Mail)

1 ATTACHMENT 1

RESPONSE TO APPEAL BY
WESTIN MONACHE OWNER’S ASSOCIATION
The Westin Monache Owners Association (“HOA”) has appealed the Limelight’s roof design and mechanical equipment.

The Limelight team first heard about concerns from members of the HOA on May 11, 2022, and since that time has worked with the HOA to understand their concerns and modify our design to accommodate their requests. The Westin found potential solutions unsatisfactory, and appealed our PEDC approval.

We note that the project complies with all zoning ordinances and has not asked for any variances, and received and incorporated feedback from Mammoth’s ADP over multiple meetings.

The HOA noted 5 categories for its appeal, which we address below.

1. MATTERS APPEALED RE ROOF DESIGN AND EQUIPMENT SCREENING HOA Comment: “Effect on value or utility of adjoining properties of inappropriate, inharmonious, or inadequate [design] is a legitimate consideration in design and planning decision making.” Limelight: We agree, and that is why we have designed the hotel to align with the North Village Specific Plan and its subsequent and more specific Design Guidelines. The introduction to the Design Guidelines state:
• “the standards of urban design, architecture and landscape architecture will provide a sense of place.”
• “The high-quality finishes and details on the builds, on the storefronts, and throughout the pedestrian level will be attractive”
• “Although the Design Guidelines provide design direction for all elements within the project area, they are intended to have sufficient flexibility to allow for incorporation of future creative design solutions, advances in building materials technologies, and proactive responses to the dynamics of the marketplace that improve the project.” • Applicants are invited to submit creative and imaginative projects which build on these Guidelines and contribute to the evolving character of the Village. • The application of these guidelines is intended to be reasonable and practical, and not as regulations.

The hotel, as designed, aligns with the foregoing principles.

HOA Comment: “Visual harmony with surrounding development is a legitimate consideration in design and planning decision making.”
Limelight: We agree, and that is why we have designed the hotel to align with the North Village Specific Plan and the more specific Design Guidelines, which state:

2 • “the village will be experienced as a collection of many individual structures, and a sense that it is truly special and distinctive.”
• “the Village is organized so that it can be developed in several phases. Each phase is to operate successfully as a complete entity.”
The hotel, as designed, aligns with the foregoing principles.

HOA Comment: “flat roofs are not expressly prohibited in the North Village Specific Plan.” Limelight: We agree, a flat roof is permitted by the North Village Specific Plan, and contributes to the desires of the Design Guidelines, such as: (i) an urban design, (ii) sufficient flexibility, (iii) a proactive response to the dynamics of the marketplace, and (iv) a creative and imaginative project.

Further, the Design Guidelines confirm they are intended to be reasonable and practical, and not as regulations.

HOA Comment: The roof is visible to owners and guests of the Westin.

Limelight: The roof height (and its visibility to owners and guests of the Westin) is a function of the private height covenant the Westin has onto the Limelight property. Zoning actually permits a much higher roof.

HOA Comment: Flat roofs may be used if the design or function warrants.

Limelight: We agree. The Limelight is creating a pedestrian-friendly experience, per the Design Guidelines, and our design furthers the Design Guideline’s goals of establishing the village as a hub. A flat roof achieves: (i) our desired design, which is a proactive response to the marketplace encouraged by the Design Guidelines and (ii) function for safe snow storage. Additional function is being considered for guests of the hotel to utilize some portion of the rooftop (i.e. we are considering adding a hot tub and outdoor furniture, which requires a flat roof). Given the desired pedestrian activity below by ADP and the NVSP, a flat roof is the safest with respect to potential snow shedding onto below pedestrians. The design incorporates, at the direction of the Design Guidelines and the ADP, “multiple walking routes creating the ability for visitors to wander,” “special places, memorable views and experiences,” and “many opportunities to sit and rest” – these pedestrian experiences must be safe from snow shedding.

HOA Comment: flat roofs will be allowed where required for snow management, upper level exterior uses or architectural character.

Limelight: We agree. In addition to snow management purposes, which the flat roof functions to provide, the roof is part of the Limelight’s design intent and therefore architectural character. The architectural character is aligned with the Design Guidelines, which is confirmed in many areas of the Design Guidelines and through our multiple iterations to incorporate ADP comments.

Specifically, the Design Guidelines state “there are many rich traditions in California architecture that can be considered as inspirational for village applications.” The Design Guidelines state that

3 “the buildings must relate carefully to the pedestrian experience,” applying further focus on a safe snow management plan.

The Design Guidelines further state that “in order to create the sense of a village which might have grown over time, larger buildings will be conceived as an assemblage of smaller buildings that express both individuality and harmony, or where appropriate, the building itself will represent a period of time in the evolution of the village development.” The Limelight design appears as an assemblage (it steps down in roof level from 6 levels to 4 levels), and it expresses both individuality and harmony. Further, as the first true hotel in the village in decades, the building does represent a period of time in the evolution of the village development.

As noted by the HOA, pursuant to the Design Guidelines: “flatter (roof) slopes will be permitted for specific design effect or snow management purposes.” We are utilizing a flat roof for both design effect and for snow management purposes, both of which are permitted in the North Village Specific Plan and the Design Guidelines.

HOA Comment: Flat roofs are permitted in cases of snow management.

We agree, and given the pedestrian activity below (which has been encouraged by ADP, the NVSP, and its design guidelines,) the safest manner for snow management is a flat roof, in addition to the modern architectural character that we are trying to achieve, as encouraged by the Design Guidelines.

HOA Comment: Guidelines for roof design and mechanical equipment argue for a revised roof design and concealed mechanical equipment.

Limelight: The Design Guidelines state: “Mechanical equipment and elements such as video receivers must be concealed from view to the extent feasible.” The hotel has been designed to conceal mechanical equipment to the extent feasible. The height of the roof, however, is a function of the restrictive height covenant the Westin has on the Limelight site, limiting the building’s height.

HOA Comment: “Mechanical, electrical and roof access equipment, vents and antenna shall be integrated into the roof or dormer design to avoid visual impact on other properties. This language is mandatory, not discretionary.”
Limelight: It is impossible to place mechanical, electrical and roof access equipment on a roof that would be invisible to individuals who are positioned at a higher vantage point on a neighboring property. The design guidelines speak to the reasonableness and practicality as a standard. It would be unreasonable and impractical to interpret this provision as a requirement for mechanical equipment to be integrated into the roof or dormer design "to avoid visual impact" from a higher vantage point on a neighboring property.” Consequently, the only logical interpretation of this provision is that mechanical equipment must be shielded to avoid visual

4 impact from the ground level of other properties. The mechanical equipment that will be located on the roof of the Limelight will not be visible from the ground level of any property in Mammoth.

The reference to “other properties” is defined in more specific manner relating to the public-level, and not with respect to private views.

Moreover, the views that owners and guests seek enjoy at the Westin are not the views of the rooftops of neighboring buildings. The views that owners and guests covet are those of the surrounding mountains and sky. The units that are located above the Limelight will still maintain excellent views of the surrounding mountains and sky.

After receiving feedback from the HOA (for the first time) during the May 11, 2022 PEDC, we generated images from specific units of the Westin of what the views may look like. As shown, from this unit, vistas are available and uninterrupted to the gondola building, village, 8050, and mountains.

HOA Comment: “Visual impact of utilities and service equipment shall be minimized.” Limelight: The parapets offer screening, and the utilities are grouped. The views of the Limelight’s utilities and service equipment may be less visible than the Westin’s own utilities.

HOA Comment: “Building forms and facades shall be composed to provide variation, visual interest, appropriate scale and proportions.”
Limelight: We agree, and have designed a building that steps down such that is varied in height, is of visual interest, and appropriate scale and proportions. The building is compliant with zoning standards, rules, and regulations.

HOA Comment: Building design should “provide aesthetic appeal to all sides of a building where visible from adjacent properties or public spaces.”
Limelight: The building is designed with high quality materials and design. Pedestrian activity has been prioritized, and the building is appealing from adjacent properties and public spaces. The notion of being appealing from adjacent properties refers to the public, not private, views, although: (i) we have done what is feasible in terms of grouping the mechanical equipment and (ii) the Design Guidelines state: “Mechanical equipment and elements such as video receivers must be concealed from view to the extent feasible.”
HOA Comment: “Roofs shall have a dominant form with interesting design features such as changes of height, taller accents, towers, roof dormers, or special architectural features.” Limelight: We agree, and the Limelight building has interesting design features, including changes of height. Beyond meeting the standard (the Limelight includes changes in height), the parapets provide special architectural features.

5 HOA Comment: “All roof forms should hide roof-top mechanical equipment,” and “flat roofs are generally not a form permitted in Mammoth.”
Limelight: Both of these items are addressed above.

HOA Comment: “When flat roof sections are used, they must have a distinctive cornice or architectural feature to screen the flat portion.”
Limelight: The roof design provides an architectural feature and the flat portion is screened from public view. Further, as noted, the more specific Design Guidelines are to be applied as “reasonable and practicable” and not as strict regulations, and are intended to provide sufficient flexibility, allowing for urban design, and proactive responses to the marketplace. The ADP encouraged a pedestrian experience, as do the NVSP and the Design Guidelines. To provide function to the design, a flat roof is the safest with regards to snow management.

HOA Comment: Utility enclosures.

Limelight: This entire section referenced by the HOA refers to ground-level utility enclosures (and not rooftop mechanical equipment), with which the hotel complies. This includes the note made by the HOA stating “where size of structure and location warrant, enclose structure behind walls or screens,” and “where possible, locate utility structures in landscape areas where they can be screened by shrub planting.”
HOA Comment: “To the extent feasible, building height is varied so that a portion of the building has a noticeable change in height, or roof forms are varied over different portions of the building through changes in pitch, plan, and orientation.”
Limelight: This condition is satisfied. The building has a change in height from 6 stories to 4.

Further, the building changes in plan and orientation.

HOA Comment: The HOA notes the absence of screening of equipment as a reason for the appeal.

It notes that “all exterior mechanical and electrical equipment shall be screened or incorporated into the design of the builds so as not to be visible from the street. Equipment to be screened includes: all roof mounted equipment… Screening materials shall be consistent with the exterior colors and materials of the building.”
Limelight: As designed, the equipment is not visible from the street. Further, the Limelight team offered to screen roof mounted equipment using exterior colors and materials consistent with the building. This offer was rejected by the HOA.

HOA Comment: The HOA notes a condition of approval from a density bonus program, stating mechanical equipment on the roof shall “be combined and/or collected together on slopes of roof out of public view to the greatest extent possible.”

6 Limelight: Even if this is outdated density bonus condition of approval is still applicable, the hotel complies with this condition of approval.

HOA Comment: With respect to site design, the hotel does not appear to contemplate the impact on the Westin owners/occupants who will look across the large, flat roof of the Limelight with unscreened mechanical equipment.

Limelight: The mechanical equipment, as approved, is compliant with applicable rules and regulations. The Limelight team offered to further screen roof mounted equipment using exterior colors and materials consistent with the building. This offer was rejected by the HOA. Limelight has rendered many views from the Westin, at our own expense, so the Westin can see how this may look.

HOA Comment: “Roof forms should be varied to create visual interest.” Limelight: The Limelight satisfies this condition per the Design Guidelines, which suggest:
• “Finally, the buildings must function well from operational and environmental standpoints.

They must be energy efficient.” (The roof design is highly energy efficient, as a flat roof design is the most energy efficient roof design.)
• “Legible and safe ingress and egress is required.” (With pedestrians below, this is the safest roof form).
• “Structures have to withstand the rigors of a high mountain environment, with roof structures that hold or shed snow in a manageable manner.” (With pedestrians below, this is the safest roof form).
• “Vary roof forms with changes of height, some taller accents, towers, or special vertical architectural features or projections, or multiple story changes”. (The Limelight changes height, has some taller accents, and architectural features.) • “The ridgeline… should be varied in height, or broken with chimneys, cupolas, towards, or other features”. (The roof is varied in height and has “other features”).

The hotel, as designed, aligns with the foregoing principles.

2. MATTERS APPEALED RE NOISE
HOA Comment: “Prior to issuance of a building permit, the applicant shall provide evidence that the rooftop equipment complies with the Town’s Noise Ordinance.” Limelight: We agree.

HOA Comment: The HOA notes concerns regarding noise that will travel uphill towards units of the Westin. Appellant is concerned that sound emanating from individual pieces of equipment may be minimal, but that multiple pieces of equipment could have a compounding effect.

7 Limelight: As noted above, prior to issuance of a building permit, Limelight shall provide evidence that the rooftop equipment complies with the Town’s Noise Ordinance. During the PEDC hearing, we also consented to a new condition that will require us, prior to receipt of a COO, to demonstrate that the equipment complies with the Noise Ordinancet
HOA Comment: “There are various commercial acoustic screening or buffering materials available for rooftop mechanical equipment. Further, screening of equipment could be done in a way which provides both visual and acoustical screening.”
Limelight: The closest units at the Westin are 80 feet away from the 4-story section of the Limelight, and 130 feet away from the 6-story section of the Limelight. Further, the Limelight team offered to further screen roof mounted equipment using exterior colors and materials consistent with the building. This offer was rejected by the HOA.

HOA Comment: In previous circumstances, the Town has offered “mechanical equipment shall be placed as far practicable from sensitive receptors,” and would utilize “rooftop parapet further attenuating potential noise impacts.”
Limelight: The hotel is a substantial distance from the Westin, and in some cases closer to other buildings in the village. Moving equipment to satisfy the Westin would move equipment closer to other village buildings and homeowners. The Limelight roof already has parapets that will act to attenuate potential noise impacts. Further, the hotel design meets all Town requirements.

HOA Comment: “Two of the primary factors that reduce levels of environmental sounds are increasing the distance between the sound source to the receiver and having intervening obstacles such as walls, buildings, or terrain features between the sound source and the receiver.” Limelight: Beyond complying with all ordinances, the closest point between the Limelight and the Westin is 80 feet or 130 feet, and in most cases much further. The Limelight roof has parapets that will act as sound attenuation.

HOA Comment: The HOA includes sections of the municipal code.

Limelight: We are compliant with municipal code. Moving the equipment from one side of the roof to the other only moves it closer to other neighbors. The mechanical is generally centered, which is the fairest to everyone and all of our neighbors.

3. MATTERS APPEALED RE HOURS OF CONSTRUCTION
Limelight: We will comply with the hours of construction set forth in the Town Code. We have eliminated the geothermal system from the Project Description.

8 The HOA notes areas of disturbance for potential geothermal wells.

Limelight: . We have eliminated the geothermal system from the Project Description.

The HOA notes the duration of geothermal well drilling.

Limelight:. We have eliminated the geothermal system from the Project Description. .

4. MATTERS APPEALED RE CEQA FINDINGS
The HOA appeals the CEQA findings, noting the addendum would not result in any new significant environmental effects or substantial increase in the severity of previously identified significant effects.

Limelight: . We have eliminated the geothermal system from the Project Description.

The HOA notes the addendum fails to address the noise pollution associated with the construction and drilling phase of the geothermal wells.

Limelight: . We have eliminated the geothermal system from the Project Description.

5. MATTERS APPEALED RE GRADING AND TREE REMOVAL
HOA Comment: The HOA appeals the grading and tree removal. The HOA notes it found out “completely by chance” that Limelight planned to start staging equipment on the site.

Limelight: We are unsure of how the HOA can state it found out “completely by chance” - Limelight’s contractor told the engineering team at the Westin as a courtesy, which is how the Westin “found out” the intentions with respect to grading. This is a disappointing perspective from the HOA. We also created a project-specific website and wrote a letter in the Sheet.

HOA Comment: The HOA references existing entitlements with respect to a grading permit.

Limelight: Limelight Mammoth LLC is utilizing existing entitlements and permits to begin grading, making way, eventually, for the project. We are committed to developing this hotel, the funds have been set aside, and we would like to keep the overall construction cycle as short as possible, to minimize our overall impact.

9 HOA Comment: The HOA notes various conditions of approval from permits.

Limelight: We are complying with all conditions of approval, including as it relates to tree removal.

HOA Comment: The HOA notes concerns over erroneous tree removal.

Limelight: We have posted a bond to the Town, which acts to protect the community. Construction reviews are ongoing to ensure compliance with all permits.

10 EXHIBIT 1

RESPONSE TO HOA APPEAL
The below image (view from the 6th floor) has been shared with the HOA, showing views from the units of the Westin with the most direct views over the Limelight. Multiple iterations of screening were provided to the HOA, from multiple perspectives.

We offered concessions in response to the HOA’s concerns, but they were not accepted as of this response.

After presenting to the HOA as a courtesy in the past, and sharing Andy Reed’s contact information, no one ever reached out. The first time we heard about any unhappiness was during the May 11, 2022 PEDC meeting.

In immediate response to the HOA, at own expense, we prepared renderings from the perspective of specific units that noted issue with our building and/or roof design so the Westin owners could see how their private view may look after the development of the Limelight.

View from 6th Floor, including Additional MEP Screening Offered to the HOA • The distance from the Westin to the Limelight roof is approximately 80 feet away at its closest point.
• There are numerous trees between the Westin and the Limelight. • The views of the horizon remain, along with visibility to other buildings in the Village. • The height of the roof is a function of the Westin’s height covenant, and is below allowable density and height by zoning.
• Unlike how the taller Westin building blocked views from its neighbors, the Limelight is more accommodating.
• The Design Guidelines note “of particular importance is the gondola building,” which is largely visible.
• The rendering indicates a vista of the gondola building and other village buildings, including the mountains beyond and the horizon.

11 Addition Perspective from the Westin’s 6th Floor
• The distance from the Westin to the closest portion of the stepped-up roof is 130 feet, and it further to the MEP on that roof section.
• Vistas to the mountains and horizon beyond are accommodated, and trees exist between buildings.
• The below image of the taller Westin building shows MEP visible from the public level, though the Limelight’s rooftop mechanical equipment is arguably better screened from the public than this clearly visible equipment.

View of the Westin and its Visible MEP

12 EXHIBIT 2

RESPONSE TO HOA APPEAL
While expressly not included in the appeal, the HOA mentioned during PEDC on May 11, 2022 a question about the parking structure; as well during Town Council on 6/15.

The Design Guidelines indicate below an acceptable parking structure, which is clearly consistent with the Limelight design.

The parking should be under the structure, which is what Limelight has designed.

Image from the Design Guidelines Relating to Under-Structure Parking Garages

sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:33:54 PM

COVER SHEET
AP0-000
194168 02/04/22
LL
Author

LIMELIGHT HOTEL
5 CANYON BOULEVARD, MAMMOTH LAKES, CA 93546

ENTITLEMENT RESUBMITTAL PACKAGE
APRIL 1, 2022

PROJECT LOCATION:
15 CANYON BLVD. MAMMOTH LAKES, CA 93546
PROJECT DESCRIPTION:

THE LIMELIGHT MAMMOTH LAKES HOTEL CONSISTS OF A 6-STORY, 151 KEY HOTEL AND 15 KEY RESIDENTIAL UNITS, AN OUTDOOR POOL AND SPA TERRACE WITH LANDSCAPING AND OPEN SPACE, AND 1 LEVEL OF SUBTERRANEAN STRUCTURAL PARKING AND 1 LEVEL OF UNDERGROUND MECHANICAL LEVEL BUILT ON AN EXISTING MOUNTAINSIDE SLOPING SITE. THE HOTEL ALSO INCLUDES TOWNHALL DINING, MEETING SPACE, LOBBY, SKI CLUB LOUNGE AS WELL AS A FITNESS CENTER.

THE BUILDING HEIGHT TO THE ROOF PLANE IS 74’-8” AND THE HIGHEST POINT OF THE ROOF IS 109’-8” ABOVE THE ADJACENT CANYON BOULEVARD SLOPING GRADE LEVEL.

SITE AREA INFORMATION INCLUDING PHASE I AND PHASE II:

TOTAL SITE AREA (PARCELS 1-7) = 301,118+ SQUARE FEET, 6.91+ ACRES ZONING:

THE CURRRENT ZONING FOR THE SUBJECT PARCELS IS PER THE NORTH VILLAGE SPECIFIC PLAN. PARCELS 1, 2, 3 AND 8 ARE ZONED RESORT LODGING PER THE NORTH VILLAGE SPECIFIC PLAN. PARCELS 4, 5, 6, AND 7 ARE ZONED SPECIALTY LODGING PER THE NORTH VILLAGE SPECIFIC PLAN.
(PARCELS 1-7) APN# 33-390-002 THROUGH 33-390-007, AND 031-110 - 027; PARCEL 8: AN EASEMENT FOR THE PEDESTRIAN BRIDGE
PARCEL 9: AN EASEMENT FOR TEMPORARY CONSTRUCTION AND OTHER RIGHT

SPECIALTY LODGING (SL), PLAZA RESORT (PR) - NORTH VILLAGE SPECIFC PLAN (NVSP)

TOWN OF MAMMOTH LAKES
SITE COVERAGE:

MAXIMUM SITE COVERAGE INCLUDING ALL BUILDINGS AND PAVED OR OTHERWISE

DEVELOPED IMPERVIOUS SURFACES FOR EACH DEVELOPMENT AREA SHALL BE AS FOLLOWS:

MAXIMUM SITE COVERAGE ALLOWED: PR DISTRICT - 75%
SL DISTRICT - 60%
SITE COVERAGE PROVIDED (SEE LOT COVERAGE PLAN):

PR DISTRICT - 62.4%
SL DISTRICT - 60%
COMBINED - 62.1%
SITE AREA INFORMATION:

PHASE I SITE AREA: 174,655+ SF

4.01 + ACRES
PHASE II SITE AREA: 126,465+ SF

2.90 + ACRES
TOTAL SITE AREA = 301,118+ SF,

6.91+ ACRES
BUILDING AREA:

THROUGHOUT NORTH VILLAGE, THE MAXIMUM BUILDING FLOOR AREA FOR ALL DEVELOPMENTS SHALL BE 87,000 SQUARE FEET PER ACRE (EXCLUDING STRUCTURED PARKING) IN THE DISTRICTS DESIGNATED PR.

MAXIMUM BUILDING FLOOR AREA ALLOWED: 6.91+ ACRES x 87,000 SF = 601,170 SF BUILDING FLOOR AREA (PHASE I) PROVIDED:

PROJECT DESCRIPTION
BUILDING HEIGHT:

PER NORTH VILLAGE SPECIFIC PLAN - TABLE 4. BUILDING HEIGHTS

LAND USE BUILDING MAXIMUM MAXIMUM
AREA LEVELS PERMITTED HT. PROJECTED HT.

PR PLANNING AREAS( FIGURE 1)
-RESORT LODGING AREA 1-7 75’ 90’
HEIGHT = ± 75 FT **, 6 STORIES
(PODIUM + 5 STORIES)
**80’ MAX. PERMITTED SUBJECT TO ADDITIONAL REVIEW
AND APPROVAL PER NVSP TABLE 4.

PROVIDED: 74'-8"± , 6 STORIES (PODIUM + 5 STORIES)
PER COVENANT AND AGREEMENT REGARDING HEIGHT LIMITATIONS:

HEIGHT LIMITATION. NO BUILDING IMPROVEMENTS CONSTRUCTED WITHIN THE RESTRICTED AREA DESCRIBED ON EXHIBITS B AND B-I (THE "NORTH RESTRICTED AREA") SHALL EXCEED AN ELEVATION OF 8,130 FEET ABOVE SEA LEVEL. FOR PURPOSES OF THIS COVENANT, "SEA LEVEL" SHALL BE DETERMINED BASED ON THE

CURRENT DATUM USED BY THE TOWN OF MAMMOTH LAKES AS OF THE EFFECTIVE DATE OF THIS COVENANT. NOTWITHSTANDING THE FOREGOING, (I) FOR ANY BUILDING, AN AREA OF ROOF LENGTH UP TO BUT NOT MORE THAN TWENTY (20)

PERCENT OF THE LENGTH OF THE BUILDING, WHEN MEASURED IN A STRAIGHT LINE

ALONG THE BUILDING'S LONGEST- AXIS AT THE BUILDINGS' FIRST LEVEL ABOVE GRADE, MAY BE CONSTRICTED BETWEEN 8,130 FEET AND 8,135 FEET ABOVE SEA LEVEL. IF A BUILDING HAS TWO OR MORE LEVELS WHICH COULD BE CONSIDERED THE "FIRST LEVEL ABOVE GRADE", THE FIRST LEVEL ABOVE GRADE WITH THE LONGEST AXIS SHALL BE THE LEVEL TO BE MEASURED; AND (II) ANTENNAE,

CHIMNEYS, TURRETS, CUPOLAS AND SIMILAR ROOF APPURTENANCES MAY HAVE A MAXIMUM ELEVATIONS BETWEEN 8,130 FEET AND 8,135 FEET ABOVE SEA LEVEL.

BUILDING SETBACKS:

PER NORTH VILLAGE SPECIFIC PLAN - TABLE 5: BUILDING SETBACKS FROM

ROADWAYS AND SPECIFIC PLAN

BOUNDARIES
BUILDING HEIGHT 0-24’ 25-34’ 35-54’ 55’+
LAKE MARY/MAIN 10’ 20’ 30’ 40’
CANYON BLVD REALIGNMENT 10’ 20’ 30’ 40’
(NO SETBACKS REQUIRED ON INTERNAL SIDE AND REAR LOT LINES OF PR DISTRICT) MIXED OCCUPANCY:

A2, A3, A4, B, R1, R2, S2
NOTE: HOTEL WILL BE CONDITIONED TO LIMIT ROOM OCCUPANCY TO NO MORE THAN 30 DAYS AT A TIME.

CONSTRUCTION TYPES:

THE HOTEL BUILDING TYPE I-B SPRINKLERS (CBC 504)
NOTE: THE FIRE-RESISTANCE RATINGS OF THE BUILDING ARE PERMITTED TO BE

REDUCED TO TYPE II-A EXCEPT FOR THE PRIMARY STRUCTURAL FRAME (CBC 403.2.1.1 EXCEPTION 2).

PROJECT
SITE

VILLAGE
203)
(HWY

LAKE MARY ROAD

BERNER STREET

MINARET
ROAD

MAMMOTH

FIRESIDE
8050
CLUB

WHISKEY
CREEK
UNITS
1-31
CANYO
B
VD

GONDOLA

VILLAGE
NORTH
N
L

MAMMOTH

LAKEVIEW
BLVD
WESTIN
VICINITY MAP (N.T.S.)
N
Client
The Little Nell Hotel Group
Limelight Mammoth, LLC
222 n Lasalle St. Suite 2000
Chicago, IL 60601
Ken Ishiguro
Tel: 415 755 3206
E-mail: [email protected]
Architect
WATG
300 Spectrum Center Drive, Suite 500
Irvine, CA 92618 USA
Dan Patton
Telephone: 1 949 574 8500
Email: [email protected]
www.watg.com
Shoring Engineer
Cefali & Associates, Inc.
4344 Laurel Canyon Blvd., Suite 3
Studio City, CA 91604
David Cefali
818.752.1812
[email protected]
cefali.com
Civil Engineer
THA Engineering
PO Box 1570 (mailing address)
549 Old Mammoth Rd, Ste. 202
Mammoth Lakes, CA 93546
Tom Platz
Tel: 760 934 7588
E-mail: [email protected]
Lighting Design
First Circle Design, Inc
3187 Airway Ave, Suite C
Costa Mesa, CA 92626
Matt Levesque
Tel: 949 681 0500
E-mail: [email protected]
Geotechnical Engineer
Sierra Geotechnical Services Inc.

P.O. Box 5024
Mammoth Lakes CA 93546
Joe Adler
Tel: 760 934 3992
E-mail: [email protected]
Structural Engineer
Englekirk Engineering
3621 S. Harbor Blvd., Suite 125
Santa Ana, CA 92704
Zen Hoda
T: 1 (714) 557-8551
Email: [email protected]
www.englekirk.com
Landscape
WATG
300 Spectrum Center Drive, Suite 500
Irvine, CA 92618 USA
Lance Walker
Telephone: 1 949 574 8500
E-mail: [email protected]
www.watg.com
Construction Management
Group
JONES LANG LASALLE INC.

PDS-Hotels & Hospitality
8343 Douglas Avenue, Suite 100, Dallas, TX. 75225

DENNIS PATCHAKOS
Tel: 214.438.6124
Email: [email protected]
PARKING SPACES REQUIRED PER NVSP PG. 72 (i)

UNIT COUNT
1 BEDROOM WITH

LOCK- OFF
(51 UNITS TOTAL)
166 TOTAL UNITS

NVSP PARKING

STANDARD
# STALLS

REQUIRED

UNIT TYPE

LIMELIGHT MAMMOTH HOTEL
LEVEL 2 = 13
LEVEL 3 = 14
LEVEL 4 = 14
LEVEL 5 = 5
LEVEL 6 = 5

1.5 STALLS PER
UNIT X 51 UNITS

76.5 1 BEDROOM
(51 UNITS TOTAL)
LEVEL 2 = 13
LEVEL 3 = 14
LEVEL 4 = 14
LEVEL 5 = 5
LEVEL 6 = 5
1 STALL PER UNIT
X 51 UNITS
51 2 BEDROOM
(2 UNITS TOTAL)
LEVEL 2 = 0
LEVEL 3 = 1
LEVEL 4 = 1
LEVEL 5 = 0
LEVEL 6 = 0
1 STALLS PER
UNIT X 2
2 3 BEDROOM
(4 UNITS TOTAL)
LEVEL 2 = 1
LEVEL 3 = 0
LEVEL 4 = 1
LEVEL 5 = 1
LEVEL 6 = 1

1.5 STALLS PER
UNIT X 4
6 4 BEDROOM
(4 UNITS TOTAL)
LEVEL 2 = 2
LEVEL 3 = 2
LEVEL 4 = 0
LEVEL 5 = 0
LEVEL 6 = 0

1.5 STALLS PER
UNIT X 4
6 5 BEDROOM
(3 UNITS TOTAL)
LEVEL 2 = 0
LEVEL 3 = 0
LEVEL 4 = 1
LEVEL 5 = 1
LEVEL 6 = 1

1.5 STALLS PER
UNIT X 3

4.5 146
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:33:58 PM

PROJECT DATA
AP0-001
194168 01/25/21
Checker
Author

PROJECT DATA SUMMARY

PROJECT DIRECTORY VICINITY MAP
APPLICABLE CURRENT CODES:

NORTH VILLAGE SPECIFIC PLAN (2000)
2019 CALIFORNIA BUILDING CODE (CBC)
2019 CALIFORNIA FIRE CODE (CFC)
2019 CALIFORNIA ELECTRICAL CODE (CEC)
2019 CALIFORNIA MECHANICAL CODE (CMC)
2019 CALIFORNIA PLUMBING CODE (CPC)
2019 CALIFORNIA ENERGY CODE (CENC)
2019 CALIFORNIA GREEN BUILDING STANDARDS CODE (CGBC)

APPLICABLE CODES
ENT_SHEET INDEX - ARCHITECTURAL
Sheet # Sheet Name
02/04/202204/01/2022
AP0-000 COVER SHEET X X
AP0-001 PROJECT DATA X X
AP0-002 GENERAL NOTES X X
AP0-003 BUILDING AREA X X
AP0-004 BUILDING AREA X X
AP0-010 SITE PLAN X X
AP0-011 LOT COVERAGE PLAN X X
AP0-012 FIRE DEPARTMENT ACCESS PLAN X X
AP0-013 SNOW MANAGEMENT & STORAGE PLAN X X
AP0-014 SHADE/SHADOW ANALYSIS X X
AP2-101 OVERALL FLOOR PLANS - LEVEL B2 X X
AP2-102 OVERALL FLOOR PLANS - LEVEL B1 X X
AP2-103 OVERALL FLOOR PLANS - LEVEL 1 X X
AP2-104 OVERALL FLOOR PLANS - LEVEL 2 & 3 X X
AP2-105 OVERALL FLOOR PLANS - LEVEL 4 & 5 X X
AP2-106 OVERALL FLOOR PLANS - LEVEL 6 & ROOF X X
AP3-101 OVERALL ELEVATIONS X X
AP3-102 PODIUM HEIGHT X
AP3-501 PERSPECTIVES X X
AP3-502 PERSPECTIVES X X
AP3-503 PERSPECTIVES X X
AP3-504 PERSPECTIVES X X
AP3-601 BUILDING ISOMETRIC VIEWS X X
AP3-602 BUILDING ISOMETRIC VIEWS X X
AP4-101 BUILDING SECTIONS X X
AP4-102 BUILDING SECTIONS X X

SHEET INDEX PARKING SUMMARY
PARKING:

REQUIRED PARKING STALLS:

HOTEL/RESIDENTIAL = 166 KEYS
REQUIRED: 146 STALLS (REQUIRED PER NVSP PG. 72 (i)); SEE THE TABLE BELOW.

ADMIN. & MANAGEMENT OFFICES = 1,460± SF x 2 STALLS = 4 STALLS REQUIRED TOTAL REQUIRED: 150 STALLS
REQUIRED 10% OF REQUIRED PARKING SPACES (146 STALLS) FOR GUEST ACCESS:
= 10% x 146 = 15 STALLS
ACCESSIBLE PARKING SPACES: PER CBC TABLE 11B-208.2 (151-200) REQUIRED - 6
PROVIDED - 6
CALGREEN SUMMARY:

CLEAN AIR / VANPOOL/ EV VEHICLE STALLS
REQUIRED - 16
PROVIDED - 16
PER CALGREEN TABLE 5.106.5.2 (151-200)

EV CHARGING STALLS
REQUIRED - 10 (INCLUDING 1 VAN ACCESSIBLE EV AND 1 STANDARD ACCESSIBLE EV)
PROVIDED - 10 (INCLUDING 1 VAN ACCESSIBLE EV AND 1 STANDARD ACCESSIBLE EV)
PER CALGREEN TABLE 5.106.5.3.3 (151-200) & CBC TABLE 11B-228.3.2.1 PARKING PROVIDED:

PARKING STRUCTURE VALLET STALLS: 179
CHECK-IN STALLS: 9
OVERSIZE / VISITOR STALLS / 10% GUEST ACCESS: 16
TOTAL PARKING PROVIDED: 204 STALLS
BICYCLE PARKING:

BICYCLE PARKING - SHORT TERM
REQUIRED - 5% OF 200= 10
PROVIDED - 28
PER CALGREEN 5.106.4.1.1

BICYCLE PARKING - LONG TERM
REQUIRED - 5% OF 113 (TENANT) = 5.65
PROVIDED - 6
PER CALGREEN 5.106.4.1.2
ASSUME STAFF OF 113
THE TOWN’S MUNICIPAL CODE AND THE CA BUILDING CODE REQUIRE THE PROVISION OF LONG-TERM AND SHORT-TERM BIKE PARKING. THE TOWN’S MUNICIPAL CODE REQUIRES 0.2 BICYCLE PARKING SPACES PER HOTEL UNIT FOR A TOTAL OF 33 SPACES (166 UNITS X 0.2 = 33).

REQUIRED: SECURE BICYCLE PARKING REQUIRED = 0.2 BICYCLE PARKING

SPACES / UNIT
166 UNITS X 0.2 = 34 BICYCLE PARKING
PROVIDED: 36 BICYCLE PARKING

PARKING SUMMARY
Level TYPE COUNT

1. PARKING STRUCTURE VALLET STALLS
LEVEL B1 9' x 18' - ACCESSIBLE 4
LEVEL B1 9' x 18' - ACCESSIBLE EV 1
LEVEL B1 9' x 18' - EV 8
LEVEL B1 9' x 18' - REGULAR 146
LEVEL B1 10' x 20' - ACCESSIBLE 1
LEVEL B1 10' x 23' AISLE PARALLEL PARKING 19
179

2. CHECK-IN STALLS
LEVEL 01 10' x 20' - EXTERIOR 7
LEVEL 01 10' x 20' - EXTERIOR ACCESSIBLE EV 1
LEVEL 01 10' x 20' - EXTERIOR VAN ACCESSIBLE 1
9 3. OVERSIZE / VISITOR STALLS
LEVEL B1 10' x 20' - EXTERIOR 16
16 204

PHASE I - TOTAL CONDITIONED GROSS BUILDING AREAS
Name
PR - ENCLOSED 131,902.2 SF
SL - ENCLOSED 53,852.1 SF
TOTAL CONDITINOED GROSS BUILDING AREAS: 185,754.3 SF

TUB
SHWR
TUB

GUESTROOM UNIT MATRIX

STD BUNK
LEVEL 2 2 1 13 15 4 4 39
LEVEL 3 2 2 13 18 3 4 42
SUBTOTAL 8 7 49 57 16 14 151
TOTAL GUESTROOM 151 KEYS

RESIDENTIAL UNIT MATRIX
LEVEL 2 - - 1 2 - 3
TOTAL RESIDENTIAL 15 UNITS
UNIT SUMMARY: 151 KEY HOTEL WITH = 151 BEDROOMS
15 RESIDENTIAL UNITS = 49 BEDROOMS
DELUXE
KING
DELUXE
DQ
JR
SUITE
1 BED
1 BEDROOM
UNITS
2 BEDROOM
UNITS

STD KING
LEVEL 5 1 1 5 3 3 1 14

SUBTOTAL
LEVEL 4 2 2 13 18 3 4 42
LEVEL 6 1 1 5 3 3 1 14
3 BEDROOM
UNITS
4 BEDROOM
UNITS
5 BEDROOM
UNITS

SUBTOTAL
LEVEL 3 - 1 - 2 - 3
LEVEL 4 - 1 1 - 1 3
LEVEL 5 1 - 1 - 1 3
LEVEL 6 1 - 1 - 1 3
SUBTOTAL 2 2 4 4 3 3

1. THE DRAWINGS AND SPECIFICATIONS, AND ALL COPIES THEREOF, ARE

LEGAL INSTRUMENTS OF SERVICE FOR THE USE OF THE OWNER AND AUTHORIZED REPRESENTATIVES ON THE DESIGNATED PROPERTY ONLY.

OTHER USE, WITHOUT THE EXPRESSED WRITTEN PERMISSION OF THE ARCHITECT, IS PROHIBITED.

2. SPECIFICATIONS, DETAILS AND SCHEDULES WHICH MAY BE BOUND SEPARATELY, ARE PART OF THESE CONTRACT DOCUMENTS. DRAWINGS BY CONSULTING PROFESSIONALS, SUCH AS STRUCTURAL, MECHANICAL, ETC.,

ARE SUPPLEMENTARY TO THE ARCHITECTURAL DRAWINGS AND ARE PART OF THESE CONTRACT DOCUMENTS.

3. THE CONTRACTOR SHALL NOTIFY THE ARCHITECT IMMEDIATELY OF ANY

OMISSIONS OR DISCREPANCIES BETWEEN THE ARCHITECTURAL DRAWINGS,

CONSULTING PROFESSIONALS DRAWINGS, SPECIFICATIONS OR EXISTING CONDITIONS. SHOULD THERE BE AN OMISSION OR DISCREPANCY BETWEEN

SAID DRAWINGS AND SPECIFICATIONS, IT SHALL BE BROUGHT TO THE

ARCHITECT'S ATTENTION IN WRITING FOR CLARIFICATION PRIOR TO INSTALLATION OF SAID WORK.

4. THE CONTRACTOR SHALL NOTIFY THE ARCHITECT IMMEDIATELY IF INFORMATION IS NOT SHOWN OR IS UNCLEAR.

5. THE CONTRACTOR SHALL VERIFY ALL DIMENSIONS, ELEVATIONS AND

EXISTING CONDITIONS PRIOR TO STARTING WORK AND REPORT ANY DISCREPANCIES IN WRITING TO THE ARCHITECT. ANY WORK INSTALLED IN

CONFLICT WITH THE ARCHITECTURAL DRAWINGS SHALL BE CORRECTED BY THE CONTRACTOR AT HIS EXPENSE.

6. THE CONTRACTOR SHALL OBTAIN ALL NECESSARY PERMITS AND APPROVALS FOR ALL WORK.

7. THE CONTRACTOR SHALL BE RESPONSIBLE FOR SCHEDULING AND COORDINATING THE WORK FOR ALL UTILITIES AND SERVICES.

8. NO CHANGES ARE TO BE MADE ON THESE PLANS WITHOUT THE

KNOWLEDGE OR CONSENT OF THE ARCHITECT/ENGINEER WHOSE
SIGNATURE APPEARS HEREON.

9. NO FRAMING OF ANY TYPE IS TO BE CONCEALED PRIOR TO INSPECTION BY GOVERNING AGENCIES.

10. REFERENCES TO ANY DETAIL OR DRAWING IS FOR CONVENIENCE ONLY AND DOES NOT LIMIT THE APPLICATION OF SUCH DETAIL OR DRAWINGS.

11. ALL WORK, CONSTRUCTION AND MATERIALS SHALL COMPLY WITH ALL

PROVISIONS OF THE BUILDING CODE AND WITH OTHER RULES,

REGULATIONS, AND ORDINANCES GOVERNING THE PLACE OF THE
CONSTRUCTION. IT IS THE RESPONSIBILITY OF ANYONE SUPPLYING LABOR

OR BOTH TO BRING TO THE ATTENTION OF THE ARCHITECT AND THE OWNER

ANY DISCREPANCIES OR CONFLICT BETWEEN THE REQUIREMENTS OF THE CODE AND THE DRAWINGS. THE APPLICABLE CODES SHALL INCLUDE, BUT SHALL NOT BE LIMITED TO: 2019 CALIFORNIA BUILDING CODE.

12. THESE DRAWINGS DO NOT CONTAIN THE NECESSARY COMPONENTS FOR CONSTRUCTION SAFETY.

13. ALL CONSTRUCTION SHALL BE PERFORMED IN ACCORDANCE WITH THE

STATE CONSTRUCTION SAFETY ORDERS ENFORCED BY THE STATE DIVISION OF INDUSTRIAL SAFETY.

14. CONSTRUCT NO TRENCHES OR EXCAVATIONS 5' OR MORE IN DEPTH INTO

WHICH A PERSON IS REQUIRED TO DESCEND, OR OBTAIN NECESSARY

PERMIT FROM THE STATE OF CALIFORNIA, DIVISION OF INDUSTRIAL SAFETY PRIOR TO THE ISSUANCE OF A BUILDING OR GRADING PERMIT (HSC 17922.5 EFFECTIVE 3-6-76).

15. PRIOR TO THE ISSUANCE OF A BUILDING PERMIT, THE APPLICANT SHALL

HAVE EVIDENCE OF CURRENT WORKMEN'S COMPENSATION INSURANCE

COVERAGE ON FILE WITH THE DEPARTMENT IN COMPLIANCE WITH SECTION 3800 OF THE CALIFORNIA LABOR CODE.

16. ALL SYMBOLS AND ABBREVIATIONS USED ON THE DRAWINGS ARE CONSIDERED TO BE CONSTRUCTION STANDARDS. QUESTIONS REGARDING

THE SAME, OR THEIR EXACT MEANING, SHALL BE DIRECTED TO THE ARCHITECT.

17. WRITTEN DIMENSIONS SHALL TAKE PRECEDENCE OVER SCALE. DO NOT SCALE DRAWINGS. THE CONTRACTOR SHALL BE RESPONSIBLE FOR THE

ACCURATE PLACEMENT AND CONFIGURATION OF THE BUILDING ON THE SITE.

18. ALL EXTERIOR WALL DIMENSIONS ARE TO FACE OF EXTERIOR

SHEATHING AT STUD WALLS, OR TO FACE OF CONCRETE OR MASONRY UNLESS NOTED OTHERWISE.

19. ALL INTERIOR WALL DIMENSIONS ARE TO FACE OF STUD AT STUD WALLS, OR TO FACE OF MASONRY OR CONCRETE, UNLESS OTHERWISE NOTED.

20. FINISH FLOOR ELEVATIONS ARE TO TOP OF CONCRETE SLAB, UNLESS OTHERWISE NOTED.

21. CEILING HEIGHT DIMENSIONS ARE TO FINISHED SURFACE OF CEILING, UNLESS OTHERWISE NOTED.

22. REFER TO DOOR SCHEDULE FOR REQUIRED DOOR DIMENSIONS AND NOTES. ALLOWANCE FOR THRESHOLDS, CLOSERS, ETC. SHALL BE PROVIDED. DOOR FRAMES SHALL BE REINFORCED WHERE REQUIRED FOR CLOSERS, STOPS, AND HARDWARE.

23. CONTRACTOR SHALL PROVIDE AND INSTALL ALL STIFFENERS, BRACINGS,

BLOCKING, BACKING, HANGERS, BACK-UP PLATES, AND SUPPORTING

BRACKETS REQUIRED FOR THE INSTALLATION OF ALL CASEWORK, TOILET

ACCESSORIES, FIXTURES, PARTITIONS, AND ALL WALL-MOUNTED OR SUSPENDED MECHANICAL, KITCHEN, ELECTRICAL OR MISC. EQUIPMENT, FURNISHINGS AND ARTWORK.

24. CONTRACTOR SHALL VERIFY EXACT SIZES AND LOCATIONS OF ALL

MECHANICAL EQUIPMENT PADS, BASE STRUCTURES, ROOF OPENINGS, AS

WELL AS POWER, WATER, DRAIN INSTALLATIONS AND STRUCTURAL STEEL

SUPPORT LOCATIONS WITH EQUIPMENT MANUFACTURERS BEFORE
PROCEEDING WITH THE WORK. CHANGES TO ACCOMMODATE FIELD

CONDITIONS OR APPROVED SUBSTITUTIONS SHALL BE MADE WITHOUT ADDITIONAL CHARGE TO THE OWNER.

25. ALL PIPES, CONDUIT, WIRES, AND DUCTS SHALL BE CONCEALED FROM VIEW, UNLESS OTHERWISE NOTED.

26. ALL SPRINKLER SHUT-DOWNS MUST BE COORDINATED THROUGH THE FIRE AUTHORITY.

27. ELEVATORS, DUMBWAITERS, ESCALATORS AND MOVING WALKS TO COMPLY WITH THE 2019 CALIFORNIA BUILDING CODE (CBC) AND DESIGN STANDARD ASME A17.1 AND (CBC-3001.2).

28. PLUMBING PENETRATIONS THROUGH FIRE WALLS MUST BE CAST IRON OR WROUGHT IRON.

29. SMOKE AND/OR FIRE DAMPERS ARE REQUIRED AT DUCTED OR UNDUCTED OPENINGS IN ACCORDANCE WITH CBC SECTION-717.

30. (SMOKE/ FIRE) DAMPERS ARE REQUIRED FOR DUCT OPENINGS IN CORRIDORS - EXCEPT AS EXEMPTED UNDER THE CODE. WHERE BOTH ARE REQUIRED COMBINATION FIRE & SMOKE DAMPERS SHALL BE USED.

31. NO MECHANICAL DUCT PENETRATION IS PERMITTED (EXCEPT FOR THOSE SERVING THE EXIT ENCLOSURE) THROUGH EXIT ENCLOSURE WALLS.

32. EXIT SIGNS SHALL BE ILLUMINATED AT ALL TIMES AND FOR A MINIMUM OF 1 1/2 HOURS IN CASE OF PRIMARY POWER LOSS. THE EXIT SIGNS SHALL

BE CONNECTED TO AN EMERGENCY ELECTRICAL SYSTEM PROVIDED FROM

STORAGE BATTERIES, UNIT EQUIPMENT, OR AN ON-SITE GENERATOR SET,

AND THE SYSTEM SHALL BE INSTALLED IN ACCORDANCE WITH THE ELECTRICAL CODE.

33. THE POWER SUPPLY FOR MEANS OF EGRESS ILLUMINATION SHALL NORMALLY BE PROVIDED BY AN "ON-PREMISES" ELECTRICAL SUPPLY.

34. FIRE EXTINGUISHER LOCATIONS ARE SUBJECT TO REVIEW AND MODIFICATION BY SITE VISIT OF LOCAL AUTHORITY.

35. OPENINGS FOR STEEL ELECTRICAL BOXES NOT EXCEEDING 16 SQUARE

INCHES ARE PERMITTED PROVIDED OPENINGS DO NOT AGGREGATE MORE THAN 100 SQUARE INCHES IN 100 SQUARE FEET OF WALL OR PARTITIONS.

OUTLET BOXES ON OPPOSITE SIDES OF WALLS OR PARTITIONS MUST BE SEPARATED BY A HORIZONTAL DISTANCE OF 24 INCHES OR BY A

HORIZONTAL DISTANCE NOT LESS THAN THE DEPTH OF THE WALL CAVITY

WHERE THE WALL CAVITY IS FILLED WITH CELLULOSE LOOSE-FILL OR MINERAL FIBER INSULATION; OR BY SOLID BLOCKING, OR BY PROTECTING

BOTH OUTLET BOXES BY LISTED PUTTY PADS, OR BY OTHER LISTED MATERIALS AND METHODS (CBC-714.3.2)

36. WATERPROOF MEMBRANES SHALL BE INSTALLED IN STRICT

ACCORDANCE WITH THE MANUFACTURERS WRITTEN INSTRUCTIONS,

INCLUDING BUT NOT LIMITED TO SURFACE PREPARATION, PRIMING AND DRYING TIME.

37. PER CBC 907.2.1 FIRE ALARM WITH NOTIFICATION SYSTEM IN ACCORDANCE WITH CBC 907.5 IS REQUIRED IN GROUP A WITH AN OCCUPANT LOAD OVER 300 AND GROUP R1 OCCUPANCIES. NOTIFICATION SYSTEM SHALL INCLUDE AUDIBLE AND VISIBLE ALARMS.

38. PER CBC 907.2.8.1. MANUAL FIRE ALARM SYSTEM THAT ACTIVATES THE OCCUPANT NOTIFICATION SYSTEM SHALL BE INSTALLED IN R-1.

39. PER CBC 907.2.8.3. SMOKE ALARM, SINGLE AND MULTIPLE STATION

SMOKE ALARMS SHALL BE INSTALLED IN ACCORDANCE WITH SECTION 907.2.11.

40. NOT USED

41. WATERPROOF MEMBRANES SHALL BE PROTECTED USING DRAINAGE

BOARD OVER THE MEMBRANE AND UNDER THE FINISHED SURFACE OR TOPPING.

42. FIRE STOPPING: MAINTAIN INTEGRITY OF FIRE RATED WALLS BY

PROVIDING FIRESTOPPING MATERIAL AT GAPS AND VOIDS CREATED BY

PENETRATION, STRUCTURAL MEMBERS AND INTERSECTIONS WITH
ADJACENT SURFACES.

43. EXTERIOR WALLS: EXTERIOR STUD WALLS SHALL BE 6"X 18 GA. METAL STUDS AT 16" O.C. UNLESS NOTED OTHERWISE. INTERIOR SIDE OF ALL EXTERIOR WALLS SHALL HAVE 5/8" GYP. BOARD, FULL HEIGHT TO THE UNDERSIDE OF THE FLOOR OR ROOF ABOVE.

44. ALL EXTERIOR STUD WALLS SHALL BE INSULATED WITH MIN. R-19 BATT INSULATION.

45. ROOFING MEMBRANES SHALL BE INSTALLED IN STRICT ACCORDANCE WITH MANUFACTURER'S WRITTEN INSTRUCTIONS AND DETAILS.

46. THE OWNER SHALL EMPLOY AN INDEPENDENT THIRD PARTY ROOFING

CONSULTANT TO REVIEW AND STIPULATE THE SCOPE OF WORK AND TO PROVIDE CONTINUOUS INSPECTION AND DIRECTION OF THE INSTALLATION.

47. NOT USED

48. NOT USED

49. INSULATION MATERIALS: INSULATION MATERIALS OTHER THAN FOAM PLASTIC SHALL HAVE A FLAME SPREAD INDEX OF NOT MORE THAN 25.

GENERAL NOTES
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:34:01 PM

GENERAL NOTES
AP0-002
194168 01/13/22
Checker
Author

GUESTROOM SUMMARY

GUESTROOMS ADA / HEARING ROOM COUNTS
Level Number ROOM NAME ABBREV. COUNT

ACCESSIBLE TUB WITH HEARING
LEVEL 03 326 DELUXE KING 1 ADA HEARING K1 ADA HEARING 1 1 ACCESSIBLE WITH SHOWER
LEVEL 02 209 DELUXE KING 1 W/FIREPLACE ADA K1-F ADA 1
LEVEL 02 232 DELUXE QUEEN/QUEEN 1 ADA DQ1 ADA 1
2 ACCESSIBLE WITH TUB
LEVEL 04 427 DELUXE QUEEN/QUEEN 1 ADA DQ1 ADA 1
LEVEL 06 612 DELUXE QUEEN/QUEEN 1 W/FIREPLACE
ADA
DQ1-F ADA 1
LEVEL 05 504 JUNIOR SUITE 1 W/FIREPLACE ADA JRS-1 ADA 1 LEVEL 04 416 JUNIOR SUITE 2 W/FIREPLACE JRS-2 1
LEVEL 03 310 STANDARD KING 1 ADA SK1 ADA 1
5 HEARING
LEVEL 02 220 DELUXE KING 1 HEARING K1 HEARING 1
LEVEL 04 429 DELUXE KING 1 HEARING K1 HEARING 1
LEVEL 06 611 DELUXE KING 1 W/FIREPLACE HERAING K1-F HEARING 1 LEVEL 02 227 DELUXE QUEEN/QUEEN 1 HEARING DQ1 HEARING 1 LEVEL 03 327 DELUXE QUEEN/QUEEN 1 HEARING DQ1 HEARING 1 LEVEL 04 403 DELUXE QUEEN/QUEEN 1 HEARING DQ1 HEARING 1 LEVEL 05 512 DELUXE QUEEN/QUEEN 1 W/FIREPLACE

HEARING
DQ1-F HEARING 1
LEVEL 06 604 JUNIOR SUITE 1 W/FIREPLACE HEARING JRS-1 HEARING 1 LEVEL 04 438 JUNIOR SUITE 2 W/FIREPLACE HEARING JRS-2 HEARING 1 LEVEL 05 514 ONE BEDROOM SUITE 1 - KING

W/FIREPLACE HEARING
1BR-1 HEARING 1
LEVEL 06 614 ONE BEDROOM SUITE 1 - KING

W/FIREPLACE HEARING
1BR-1 HEARING 1
LEVEL 03 343 ONE BEDROOM SUITE 2 - KING

W/FIREPLACE HEARING
1BR-2 HEARING 1
LEVEL 04 411 STANDARD BUNK ROOM 1 HEARING SB1 HEARING 1 LEVEL 02 223 STANDARD KING 1 HEARING SK1 HEARING 1
14 TOTAL ADA/HEARING ROOMS: 22

RESIDENTIAL MIX SUMMARY

RESIDENTIAL UNIT MATRIX
ROOM NAME ABBREV. COUNT
LEVEL 02
THREE BEDROOM UNIT 3 BR 1
FOUR BEDROOM UNIT 4 BR 2
3 LEVEL 03
TWO BEDROOM UNIT ADA HEARING 2BR 1
FOUR BEDROOM UNIT 4 BR 2
3 LEVEL 04
TWO BEDROOM UNIT ADA HEARING 2BR 1
THREE BEDROOM UNIT 3 BR 1
FIVE BEDROOM UNIT 5 BR 1
3 LEVEL 05
ONE BEDROOM UNIT 1 BR 1
THREE BEDROOM UNIT 3 BR 1
FIVE BEDROOM UNIT 5 BR 1
3 LEVEL 06
ONE BEDROOM UNIT 1 BR 1
THREE BEDROOM UNIT 3 BR 1
FIVE BEDROOM UNIT 5 BR 1
3 TOTAL RESIDENTIAL UNITS: 15

ROOM MIX SUMMARY

GUESTROOM MIX MATRIX
ROOM NAME ABBREV. COUNT
LEVEL 02
DELUXE KING 1 K1 9
DELUXE KING 1 HEARING K1 HEARING 1
DELUXE KING 1 W/FIREPLACE ADA K1-F ADA 1
DELUXE KING 2 K2 2
STANDARD KING 1 SK1 1
STANDARD KING 1 HEARING SK1 HEARING 1
STANDARD BUNK ROOM 1 SB1 1
DELUXE QUEEN/QUEEN 1 DQ1 13
DELUXE QUEEN/QUEEN 1 ADA DQ1 ADA 1
DELUXE QUEEN/QUEEN 1 HEARING DQ1 HEARING 1
DELUXE QUEEN/QUEEN 1 W/FIREPLACE DQ1-F 1
JUNIOR SUITE 2 W/FIREPLACE JRS-2 1
JUNIOR SUITE 2 W/FIREPLACE JRS-2 1
JUNIOR SUITE 3 W/FIREPLACE JRS-3 1
ONE BEDROOM SUITE 1 - KING W/FIREPLACE 1BR-1 2
ONE BEDROOM SUITE 2 - KING W/FIREPLACE 1BR-2 2
39 LEVEL 03
DELUXE KING 1 K1 9
DELUXE KING 1 ADA HEARING K1 1
DELUXE KING 1 ADA HEARING K1 ADA HEARING 1
DELUXE KING 1 W/FIREPLACE K1-F 1
DELUXE KING 2 K2 2
STANDARD KING 1 SK1 1
STANDARD KING 1 ADA SK1 ADA 1
STANDARD BUNK ROOM 1 SB1 2
DELUXE QUEEN/QUEEN 1 DQ1 15
DELUXE QUEEN/QUEEN 1 HEARING DQ1 HEARING 1
DELUXE QUEEN/QUEEN 1 W/FIREPLACE DQ1-F 1
JUNIOR SUITE 2 W/FIREPLACE JRS-2 2
JUNIOR SUITE 3 W/FIREPLACE JRS-3 1
ONE BEDROOM SUITE 1 - KING W/FIREPLACE 1BR-1 2
ONE BEDROOM SUITE 2 - KING W/FIREPLACE 1BR-2 1
ONE BEDROOM SUITE 2 - KING W/FIREPLACE HEARING 1BR-2 HEARING 1 42 LEVEL 04
DELUXE KING 1 K1 8
K1 2
DELUXE KING 1 HEARING K1 HEARING 1
DELUXE KING 1 W/FIREPLACE K1-F 1
DELUXE KING 2 K2 2
STANDARD KING 1 SK1 2
STANDARD BUNK ROOM 1 SB1 1
STANDARD BUNK ROOM 1 HEARING SB1 HEARING 1
DELUXE QUEEN/QUEEN 1 DQ1 12
DELUXE QUEEN/QUEEN 1 DQ1 1
DELUXE QUEEN/QUEEN 1 ADA DQ1 ADA 1
DELUXE QUEEN/QUEEN 1 HEARING DQ1 HEARING 1
DELUXE QUEEN/QUEEN 1 W/FIREPLACE DQ1-F 1
JUNIOR SUITE 1 W/FIREPLACE JRS-1 1
JUNIOR SUITE 2 W/FIREPLACE JRS-2 1
JUNIOR SUITE 2 W/FIREPLACE HEARING JRS-2 HEARING 1
JUNIOR SUITE 3 W/FIREPLACE JRS-3 1
ONE BEDROOM SUITE 1 - KING W/FIREPLACE 1BR-1 1
ONE BEDROOM SUITE 2 - KING W/FIREPLACE 1BR-2 3
42 LEVEL 05
DELUXE KING 1 K1 3
DELUXE KING 1 W/FIREPLACE K1-F 1
STANDARD KING 1 SK1 1
STANDARD BUNK ROOM 1 SB1 1
DELUXE QUEEN/QUEEN 1 DQ1 3
DELUXE QUEEN/QUEEN 1 W/FIREPLACE HEARING DQ1-F HEARING 1 JUNIOR SUITE 1 W/FIREPLACE ADA JRS-1 ADA 1
JUNIOR SUITE 2 W/FIREPLACE JRS-2 1
JUNIOR SUITE 2 W/FIREPLACE JRS-2 1
ONE BEDROOM SUITE 1 - KING W/FIREPLACE HEARING 1BR-1 HEARING 1 14 LEVEL 06
DELUXE KING 1 K1 3
DELUXE KING 1 W/FIREPLACE HERAING K1-F HEARING 1
STANDARD KING 1 SK1 1
STANDARD BUNK ROOM 1 SB1 1
DELUXE QUEEN/QUEEN 1 DQ1 3
DELUXE QUEEN/QUEEN 1 W/FIREPLACE ADA DQ1-F ADA 1
JUNIOR SUITE 1 W/FIREPLACE HEARING JRS-1 HEARING 1
JUNIOR SUITE 2 W/FIREPLACE JRS-2 2
ONE BEDROOM SUITE 1 - KING W/FIREPLACE HEARING 1BR-1 HEARING 1 14 TOTAL ROOMS: 151

D Y
H
D
Y
H
D Y
H
S
S
S
D Y H
S
62 '
+8050
DN TO B1
+8048
+8046
+8067
+8066
+8053
+8063
+8063
+8063
13,309.4 SF
PR -

ENCLOSED
2,372.3 SF
PR -

COVERED
383.1 SF
SL -

ENCLOSED
37,697.6 SF
PR -

COVERED
899.6 SF
SL -

ENCLOSED
712.3 SF
SL -

ENCLOSED
1,281.4 SF
PR -

ENCLOSED
460 SF
PR -

ENCLOSED
367.8 SF
SL -

COVERED/OPEN
AIR
10,565.1 SF
SL -

COVERED
24,244.8 SF
PR -

ENCLOSED
689.3 SF
PR -

COVERED/OPEN
AIR
715.6 SF
PR -

COVERED/OPEN
AIR
715.6 SF
PR -

COVERED/OPEN
AIR
1,170.3 SF
PR -

COVERED/OPEN
AIR
11,144.2 SF

PR - OPEN
TO SKY
1,777.1 SF

PR - OPEN
TO SKY
317.4 SF

SL - OPEN
TO SKY
9,617.8 SF
SL -

ENCLOSED

82.8 SF

PR - OPEN
TO SKY
2,375.3 SF

SL - OPEN
TO SKY
N
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"

KEYNOTES / LEGENDS
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:34:16 PM

BUILDING AREA
AP0-003
194168 01/17/22
Checker
Author
1" = 50'-0"
LEVEL B2 AREA PLAN - ENTITLEMENT
1 1" = 50'-0"
LEVEL B1 AREA PLAN - ENTITLEMENT
2 1" = 50'-0"
LEVEL 01 AREA PLAN - ENTITLEMENT
3 0
SCALE 1" =

12.5 50 25 100 FT
50'-0"

PHASE I - TOTAL CONDITIONED GROSS BUILDING AREAS
Name
PR - ENCLOSED 131,902.2 SF
SL - ENCLOSED 53,852.1 SF
TOTAL CONDITINOED GROSS BUILDING AREAS: 185,754.3 SF

GROSS BUILDING AREAS - ENTITLEMENT & PLANNING

SPECIALTY LODGING (SL) -

GROSS BUILDING AREAS

GROSS BUILDING AREA (PR - COVERED)
Level Name Area
LEVEL B1 PR - COVERED 37,697.6 SF
LEVEL B2 PR - COVERED 2,372.3 SF
Grand total: 2 40,069.9 SF

GROSS BUILDING AREA (PR - ENCLOSED)
Level Name Area
LEVEL 01 PR - ENCLOSED 24,244.8 SF
LEVEL 02 PR - ENCLOSED 24,708.5 SF
LEVEL 03 PR - ENCLOSED 24,708.5 SF
LEVEL 04 PR - ENCLOSED 24,708.5 SF
LEVEL 05 PR - ENCLOSED 8,954.6 SF
LEVEL 05 PR - ENCLOSED 176.1 SF
LEVEL 06 PR - ENCLOSED 8,954.6 SF
LEVEL B1 PR - ENCLOSED 1,281.4 SF
LEVEL B1 PR - ENCLOSED 460 SF
LEVEL B2 PR - ENCLOSED 13,309.4 SF
ROOF PR - ENCLOSED 111.9 SF
ROOF PR - ENCLOSED 283.8 SF
Grand total: 12 131,902.2 SF

GROSS BUILDING AREA (PR - COVERED/OPEN AIR)
Level Name Area
LEVEL 01 PR - COVERED/OPEN AIR 689.3 SF
LEVEL 01 PR - COVERED/OPEN AIR 715.6 SF
LEVEL 01 PR - COVERED/OPEN AIR 715.6 SF
LEVEL 01 PR - COVERED/OPEN AIR 1,170.3 SF
LEVEL 02 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 02 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 02 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 02 PR - COVERED/OPEN AIR 63.2 SF
LEVEL 03 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 03 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 03 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 03 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 03 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 03 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 03 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 03 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 03 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 03 PR - COVERED/OPEN AIR 63.2 SF
LEVEL 03 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 04 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 04 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 04 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 04 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 04 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 04 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 04 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 04 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 04 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 04 PR - COVERED/OPEN AIR 63.2 SF
LEVEL 04 PR - COVERED/OPEN AIR 26.4 SF
LEVEL 05 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 05 PR - COVERED/OPEN AIR 44.1 SF
LEVEL 05 PR - COVERED/OPEN AIR 57.3 SF
LEVEL 05 PR - COVERED/OPEN AIR 63.2 SF
LEVEL 05 PR - COVERED/OPEN AIR 26.4 SF
LEVEL 06 PR - COVERED/OPEN AIR 63.2 SF
Grand total: 36 4,932.9 SF

GROSS BUILDING AREA (PR - OPEN TO SKY)
Level Name Area
LEVEL 01 PR - OPEN TO SKY 11,144.2 SF
LEVEL 01 PR - OPEN TO SKY 1,777.1 SF
LEVEL 01 PR - OPEN TO SKY 82.8 SF
LEVEL 05 PR - OPEN TO SKY 15,577.8 SF
LEVEL 06 PR - OPEN TO SKY 190.5 SF
LEVEL 06 PR - OPEN TO SKY 44.1 SF
LEVEL 06 PR - OPEN TO SKY 44.1 SF
LEVEL 06 PR - OPEN TO SKY 57.3 SF
LEVEL 06 PR - OPEN TO SKY 26.4 SF
ROOF PR - OPEN TO SKY 8,622.1 SF
Grand total: 10 37,566.2 SF

PLAZA RESORT (PR) -

GROSS BUILDING AREAS

GROSS BUILDING AREA (SL - COVERED)
Level Name Area
LEVEL B1 SL - COVERED 10,565.1 SF
Grand total: 1 10,565.1 SF

GROSS BUILDING AREA (SL - COVERED/OPEN AIR)
Level Name Area
LEVEL 02 SL - COVERED/OPEN AIR 148 SF
LEVEL 02 SL - COVERED/OPEN AIR 148 SF
LEVEL 02 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 03 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 03 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 03 SL - COVERED/OPEN AIR 148 SF
LEVEL 03 SL - COVERED/OPEN AIR 148 SF
LEVEL 03 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 04 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 04 SL - COVERED/OPEN AIR 35.3 SF
LEVEL 04 SL - COVERED/OPEN AIR 148 SF
LEVEL 04 SL - COVERED/OPEN AIR 148 SF
LEVEL 04 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 04 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 05 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 05 SL - COVERED/OPEN AIR 148 SF
LEVEL 05 SL - COVERED/OPEN AIR 148 SF
LEVEL 05 SL - COVERED/OPEN AIR 35.3 SF
LEVEL 05 SL - COVERED/OPEN AIR 44.1 SF
LEVEL 05 SL - COVERED/OPEN AIR 44.1 SF
LEVEL B1 SL - COVERED/OPEN AIR 367.8 SF
Grand total: 21 2,063.3 SF

GROSS BUILDING AREA (SL - ENCLOSED)
Level Name Area
LEVEL 01 SL - ENCLOSED 9,617.8 SF
LEVEL 02 SL - ENCLOSED 8,401.2 SF
LEVEL 03 SL - ENCLOSED 8,401.2 SF
LEVEL 04 SL - ENCLOSED 8,401.2 SF
LEVEL 05 SL - ENCLOSED 8,401.2 SF
LEVEL 06 SL - ENCLOSED 8,401.2 SF
LEVEL B1 SL - ENCLOSED 899.6 SF
LEVEL B1 SL - ENCLOSED 712.3 SF
LEVEL B2 SL - ENCLOSED 383.1 SF
ROOF SL - ENCLOSED 121.4 SF
ROOF SL - ENCLOSED 111.9 SF
Grand total: 11 53,852.1 SF

GROSS BUILDING AREA (SL - OPEN TO SKY)
Level Name Area
LEVEL 01 SL - OPEN TO SKY 317.4 SF
LEVEL 01 SL - OPEN TO SKY 2,375.3 SF
LEVEL 06 SL - OPEN TO SKY 35.3 SF
LEVEL 06 SL - OPEN TO SKY 44.1 SF
LEVEL 06 SL - OPEN TO SKY 44.1 SF
LEVEL 06 SL - OPEN TO SKY 44.1 SF
LEVEL 06 SL - OPEN TO SKY 148 SF
LEVEL 06 SL - OPEN TO SKY 148 SF
ROOF SL - OPEN TO SKY 8,167.9 SF
Grand total: 9 11,324.2 SF

24,708.5 SF
PR -

ENCLOSED

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN

44.1 SF AIR
PR -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR

63.2 SF
PR -

COVERED/OPEN
AIR
8,401.2 SF
SL -

ENCLOSED

44.1 SF
SL -

COVERED/OPEN
AIR
24,708.5 SF
PR -

ENCLOSED

57.3 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR

63.2 SF
PR -

COVERED/OPEN
AIR
8,401.2 SF
SL -
ENCLOSED 44.1 SF
SL -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR
24,708.5 SF
PR -

ENCLOSED

57.3 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
PR -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR

35.3 SF
SL -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR

63.2 SF
PR -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR
8,401.2 SF
SL -

ENCLOSED

26.4 SF
PR -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR
8,954.6 SF
PR -

ENCLOSED

44.1 SF
PR -

COVERED/OPEN
AIR 44.1 SF
PR -

COVERED/OPEN
AIR

57.3 SF
PR -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR
148 SF
SL -

COVERED/OPEN
AIR

35.3 SF
SL -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR

44.1 SF
SL -

COVERED/OPEN
AIR

63.2 SF
PR -

COVERED/OPEN
AIR
15,577.8 SF

PR - OPEN
TO SKY
176.1 SF
PR -

ENCLOSED
8,401.2 SF
SL -

ENCLOSED

26.4 SF
PR -

COVERED/OPEN
AIR
8,954.6 SF
PR -

ENCLOSED
190.5 SF

PR - OPEN
TO SKY

44.1 SF

PR - OPEN
TO SKY

44.1 SF

PR - OPEN
TO SKY 57.3 SF

PR - OPEN
TO SKY

35.3 SF

SL - OPEN
TO SKY

44.1 SF

SL - OPEN
TO SKY

44.1 SF

SL - OPEN
TO SKY

44.1 SF

SL - OPEN
TO SKY
148 SF

SL - OPEN
TO SKY
148 SF

SL - OPEN
TO SKY

63.2 SF
PR -

COVERED/OPEN
AIR
8,401.2 SF
SL -

ENCLOSED

26.4 SF

PR - OPEN
TO SKY
111.9 SF
PR -
ENCLOSED 283.8 SF
PR -

ENCLOSED
121.4 SF
SL -

ENCLOSED
111.9 SF
SL -

ENCLOSED
8,622.1 SF

PR - OPEN
TO SKY
8,167.9 SF

SL - OPEN
TO SKY
N
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"

KEYNOTES / LEGENDS
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:34:39 PM

BUILDING AREA
AP0-004
194168 01/17/22
Checker
Author
1" = 50'-0"
LEVEL 02 AREA PLAN - ENTITLEMENT
1 0
SCALE 1" =

12.5 50 25 100 FT
50'-0"
1" = 50'-0"
LEVEL 03 AREA PLAN - ENTITLEMENT
2 1" = 50'-0"
LEVEL 04 AREA PLAN - ENTITLEMENT
3 1" = 50'-0"
LEVEL 05 AREA PLAN - ENTITLEMENT 4
1" = 50'-0"
LEVEL 06 AREA PLAN - ENTITLEMENT 5
1" = 50'-0"
ROOF AREA PLAN - ENTITLEMENT 6

S
S
S
S
S
S

OHU OHU OHU
WV
WV
D
Y
H
S
D
Y
H
D
Y
H
S
S
S
S
S
S
S
Y D
H
S
LAKEV
EI
W
BLVD
HILLSIDE DR.

EXIST BLDG
+8050
+8053
TERRACE @ 1ST FLOOR
SPA
POOL

ENTRY DRIVE
TRELLIS @ 1ST FLOOR TERRACE
PARKING ENTRY TO LEVEL B1

FIRE ACCESS/EMERGENCY

EGRESS STAIRS

EXISTING

WESTIN MONACHE

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING

MAIN ENTRY

OVERSIZE VEHICLE,
RESIDENTIAL VISITOR, 10% GUEST

ACCESS & EVENT AREA LOT
SPA
CANYON
BLVD.

ENTRY DRIVE

SERVICE ENTRY
DRIVE
6'-0" SIDEWALK
6'-0" SIDEWALK

WALKWAY

CLEAR FIRE
ACCESS

HOTEL ARRIVAL

COURT/PORTE COCHERE

CHECK-IN PARKING

PROPERTY LINE POOL / SPA DECK PROPERTY LINE

PROPERTY LINE
P
RO
P
E
RTY
LIN
E

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE
MAIN
ENTRY
P
RO
P
E
RTY
LIN
E

WESTIN STAIRS

LIMELIGHT

MAMMOTH
HOTEL

MAMMOTH VIEW
VILLAS

EXISTING VILLAGE GONDOLA

BUILDINGS

EXISTING

BUILDING

SETBACK
10'-0"

SETBACK
30'-0"
S
4 E
0 TBACK
'-0"
S
4 ETBACK
0'-0"

ACCESSIBLE PATH OF

TRAVEL FROM HOTEL
ENTRY TO POOL DECK.
5% MAX. SLOPE

PROPOSED BRIDGE TO

GONDOLA

BUS PARKING

PHASE II

PHASE I
48'-0"

TRELLIS
@ POOL DECK
20'-0"
46'-0"
20'-0"
2 0'-0"
26'-0"

LANDSCAPE SCREENING ABOVE

RETAINING WALLTO SCREEN
PARKING / EVENT AREA.

FIRE ACCESS @ 1ST

FLOOR EXTERIOR

HALLWAY
+8075
+8074.75
CANYON BLVD. ACCESS

TO UPPER TERRACE

EMPLOYEE

ENTRANCE
30'-0"
20'-0"
+8063

TRELLIS
@ 1ST FLOOR TERRACE
26'-0"
26'-0"
TYP.
20'-0" 20'-0"
35'-0"
MIN.
6'-0"
6'-0"
5'-0" TALL GLASS POOL

FENCE PER LANDSCAPE
DWGS. TYP.

TRASH ENCLOSURE @
LEVEL B2
+8075 @
1ST FLOOR
3 0. %

3.1%

5.6%
77'-7"
19'-8"
84'-5"

3.9%

MONUMENT SIGN
TYP.
20'-0"
TYP.
10'-0"
(8) BIKE RACKS WITH
(16) BIKE PARKING
(8) BIKE RACKS WITH
(16) BIKE PARKING

PROPERTY LINE
20'-0"
10'-0"
SITE

RETAINING
WALLS

PLANTING AREA
SITE

RETAINING
WALLS
SITE

RETAINING
WALLS
SITE

RETAINING
WALLS
CANYON BLVD. VILLAGE

ACCESS TO UPPER TERRACE
(P) STANDPIPE
42" ALUMINUM GUARDRAIL

WITH WOOD CAP
42" ALUMINUM GUARDRAIL

WITH WOOD CAP

6.2%
5%
MAX.

2.0%
AP2-102
2 ACCESSIBLE PATH OF

TRAVEL FROM HOTEL
ENTRY TO POOL DECK.
8% MAX. SLOPE
4 6. %

PROPOSED GEOTHERMAL
WELL #1

PROPOSED GEOTHERMAL
WELL #2

GENERAL NOTES

1. ALL DIMENSIONS ARE TO CENTERLINE OF COLUMN / GRID LINES, TOP OF SLAB OR TOPPING AND FACE OF FRAMING U.N.O.

2. REFER TO ENLARGED FLOOR PLANS, BUILDING ELEVATIONS,

AND DOOR AND WINDOW SCHEDULES FOR NOTES, DETAILS,
DIMENSIONS, DOOR AND WINDOW NUMBERS NOT SHOWN HERE.

3. REFER TO EXTERIOR ELEVATIONS, FINISH SCHEDULE, RCP AND

ENLARGED PLANS FOR INFORMATION ON FLOOR, WALL AND
CEILING FINISHES.

4. SEE CIVIL DRAWINGS FOR GRADING, DRAINGE, SITE
IMPROVEMENTS AND SITE DEMOLITION.

5. ALL DRAINS (FLOOR SINKS, FLOOR DRAINS, AND DRAIN RISERS)

IN MECHANICAL ROOMS, ROOF, BASEMENT, ANCILLARY SPACES,

SHALL BE MARKED WITH PERMANENT PLACARDS IDENTIFYING
TERMINATION OF EACH DRAIN (SANITARY SEWER –OR- STORM
DRAIN). ANY DRAINS WHEREVER EXPOSED TO WEATHER AND

TERMINATING TO SANITARY SEWER SHALL BE PROTECTED
AGAINST RAINWATER DISCHARGE.

6. ACCESSIBLE PATH OF TRAVEL SHALL NOT EXCEED 5% SLOPE IN THE DIRECTION OF TRAVELAND 2% CROSS SLOPE. A SLOPE
GREATER THAN 5% SHALL BE DESIGNED AS A RAMP PER CBC
11B-402.2. REFER TO CIVIL DRAWINGS

7. ACCESSIBLE PATH OF TRAVEL SHAL MAINTAIN A 4' MINIMUM CLEAR WIDTH PER CBC 11B-403.5.1 EXCEPTION

ACCESSIBLE PATH OF TRAVEL

LEGENDS
N
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"

KEYNOTES / LEGENDS
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
5/3/2022 2:40:36 PM

SITE PLAN
AP0-010
194168 01/12/21
Checker
Author
0 SCALE 1" =
15 60 30 120 FT
60'-0"
1" = 50'-0" REFA3-101
SITE PLAN - ENTITLEMENT 1

WV
WV
D
Y
H
S
D
Y
H
D
Y
H
S
S
S
S
S
S
Y D
H
S
26'
LAKEV
EI
W
BLVD
HILLSIDE DR.
+8050
DN TO B1
+8048
+8046
+8060
+8067
+8066
+8053
+8063
+8063
+8063
+8062
S
S
S
S
S

OHU OHU OHU
H
I
L
L
S
IDE DR.

PHASE I SITE AREA - RESORT

LODGING (PR)
(99,238± SF - 2.28 AC)

PHASE II SITE AREA
(126,456 SF - 2.90 AC)

PHASE I COVERED AREA

RESORT LODGING (PR)
(62,911± SF ± SF - 63.4%)

PHASE I BUILDING AREA

RESORT LODGING (PR)
(131,902± SF)

SITE LEGEND

PHASE I SITE AREA -

SPECIALTY LODGING ZONE (SL)
75,415± SF - 1.73 AC)

PHASE I COVERED AREA

SPECIALTY LODGING ZONE (SL)
(47,539± SF - 63%)

PHASE I BUILDING AREA

SPECIALTY LODGING ZONE (SL)
(53,852± SF)

OVERALL SITE
AREA: 301,118± SF
(6.91 AC)

PHASE I BUILDING AREA

RESORT LODGING (PR)
(131,902± SF)

PHASE II TOTAL ENCLOSED
BUILDING AREA ALLOWED:
217,500± SF

TOTAL ALLOWABLE SITE
COVERAGE IN PHASE II (APPROX.
75,879 SQ.FT.)

PROPOSED PHASE I COVERED

SITE AREA

SPECIALTY LODGING ZONE (SL)
47,539± SF / 75,415± SF = 63%
WESTIN

MONACHE

MAMMOTH

VIEW VILLAS

MAMMOTH

VILLAGE
168'-0"
48'-0"
PHASE II AREA:

SPECIALTY LODGING ZONE (SL)
126,456± SF (2.90 AC)

PHASE I SITE AREA -

RESORT LODGING (PR)
(99,238± SF - 2.28 AC)

BOUNDARY LINE BETWEEN

RESORT LODGING (PR) AND

SPECIALTY LODGING ZONE (SP)

PROPOSED PHASE I COVERED

SITE AREA

RESORT LODGING (PR)
62,911± SF / 99,238± SF = 63.4%

PHASE I SITE AREA -

SPECIALTY LODGING ZONE (SL)
75,415± SF; (1.73 ± ACRES）

PHASE I BUILDING AREA

SPECIALTY LODGING ZONE (SL)
(53,852± SF)
99,238± SF; (2.28± ACRES)

RESORT LODGING (PR) SPECIALTY LODGING ZONE (SL)
75,415± SF; (1.73 ± ACRES)
75% OF 99,238± SF. = 74,429±
SQ.FT.
60% OF 75,415± SF. IS 45,249±
SQ.FT.

LIMELIGHT MAMMOTH HOTEL - SITE COVERAGE PER NORTH VILLAGE SPECIFIC PLAN (NVSP)

TOTAL SITE AREA

MAXIMUM

ALLOWABLE

SITE COVERAGE

COMBINED

PHASE I COMBINED MAXIMUM
SITE COVERAGE = 119,678±
SQ.FT (2.75± ACRES)

PHASE I PHASE II
PHASE I COMBINED SITE AREA:
174,655+ SF (4.01 + ACRES)
PHASE II SITE AREA: 126,465+ SF
(2.90 + ACRES)

TOTAL (IN PHASE I AND PHASE II)
TOTAL SITE AREA = 301,118+
SF, 6.91+ ACRES
PHASE II MAXIMUM SITE COVERAGE:
60% OF 126,465+ SQ.FT. IS 75,879±
SQ.FT.

MAXIMUM

BUILDING AREA
PR = 2.28± ACRES X 87,000 SQ FT =
198,336 SQ.FT.

SL = 1.73± ACRES X 75,000 SQ.FT. =
129,750 SQ.FT.

PHASE I COMBINED MAXIMUM
BUILDING AREA = 328,110 ± SQ.FT

PROJECT

DENSITY
PR DISTRICT DENSITY (80 ROOMS
PER ACRE X 2.28 ACRES) = 182.4
THE SL DISTRICT DENSITY (48
ROOMS PER ACRE X 1.73 ACRES) =
83 SPECIALTY LODGING ZONE (SL)

TOTAL MAXIMUM ALLOWABLE
SITE COVERAGE =119,678 +
75,879 = 195,557± SF

PHASE II MAXIMUM BUILDING
AREA : SL = 2.90± ACRES X 75,000
SQ.FT. = 217,500± SQ.FT.

TOTAL MAXIMUM BUILDING
AREA = 328100 + 217,500 =
545610± SF
PHASE II PROJECT DENSITY: SL
DISTRICT DENSITY (48 ROOMS PER
ACRE X 2.90 ACRES) = 139.2
TOTAL PROJECT DENSITY =
265.4 + 139.2 = 404.6

PHASE I COMBINED PROJECT
DENSITY = 182.4 + 83 = 265.4

PROPOSED SITE

COVERAGE
62,911± SF / 99,238 SF = 63.4% 47,539± SF / 75,415± SF = 63% PROPOSED PHASE I COMBINED

PROJECT SITE COVERAGE
(62,911± SF + 47,539± SF) / 174,655+ SF
= 63.2%

PROPOSED

BUILDING AREA

PROPOSED

PROJECT DENSITY
TOTAL = 174 ROOMS (PR)+ 62 ROOMS
(SL) = 236 ROOMS PROVIDED
INCLUDING:
16,166± (COMMERCIAL OR
RESTAURANT SPACES) /450 SF PER
ROOM = 36 ROOMS
151 GUESTROOM
15 RESIDENTIAL UNITS (49 BEDROOMS)
131,902± SF 53,852± SF PHASE I COMBINED
BUILDING AREA 185,754± SF
LEVEL 1 - 11,209± SF
(COMMERCIAL OR RESTAURANT
SPACES) /450 SF PER ROOM = 26
ROOMS
LEVEL 2 - 39 GUESTROOM
LEVEL 3 - 42 GUESTROOM
LEVEL 4 - 42 GUESTROOM
LEVEL 5 - 13 GUESTROOM
LEVEL 6 - 13 GUESTROOM
PR ZONE SUBTOTAL 174 ROOMS
LEVEL 1 - 4,957± SF (COMMERCIAL OR
RESTAURANT SPACES) /450 SF PER ROOM =
11 ROOMS
LEVEL 2 - (3 UNITS = 11 RESIDENTIAL ROOMS)
LEVEL 3 - (3 UNITS = 10 RESIDENTIAL ROOMS)
LEVEL 4 - (3 UNITS = 10 RESIDENTIAL ROOMS)
LEVEL 5 - (1 GUESTROOM; 3 UNITS = 9

RESIDENTIAL ROOMS)
LEVEL 6 - (1 GUESTROOM; 3 UNITS = 9

RESIDENTIAL ROOMS)
SL ZONE SUBTOTAL 62 ROOMS
N
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:35:07 PM

LOT COVERAGE PLAN
AP0-011
194168 01/20/21
Checker
Author
0 SCALE 1" =
15 60 30 120 FT
60'-0"
1" = 50'-0"

LOT COVERAGE PLAN
1

D
Y
H
D
Y
H
D
Y
H
S
S
S
S
D
Y
H
S
62 '
+8050
DN TO B1
+8048
+8046
+8060
+8067
+8066
+8053
+8063
+8063
+8063
+8062
EXIT /
ENTRY

COVERED

WALKWAY
SPA
POOL
ENTRY
DRIVE

TRELLIS
ABOVE
LOBBY

TERRACE
POOL
DECK
RAMP
DOWN

SERVICE
ENTRY

PARKING
ENTRY

BUS STOP

EXISTING

WESTIN MONACHE

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING
MAIN
ENTRY

TEMPORARY

PARKING/EVENT
AREA
SPA

TRELLIS
CANYON BLVD.

LAKE MARY RD.

ENTRY
DRIVE
ACCESS
FIRE

HYDRANT

FIRE ACCESS

STAIR TO
ROOF

CLEAR FIRE
ACCESS
48'-0" CLEAR TURN

RADIUS AREA

FIRE ACCESS

STAIR TO ROOF

AND ELEVATOR

ENTRY CANOPY

ONLY COVER

PEDESTRIAN WALKWAY
FIRE

HYDRANT

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

MAIN ENTRY

PROPERTY LINE

PROPERTY LINE
WESTIN
STAIRS

LIMELIGHT MAMMOTH
HOTEL
FIRE

HYDRANT

FIRE ACCESS

TO MAIN

KITCHEN

FIRE ACCESS

TO FIRE RISER
& GENERATOR

FIRE ACCESS

STAIR TO

TERRACE

FIRE ACCESS

TO MAIN

LOBBY AND

ELEVATORS

FIRE ACCESS

STAIR TO

TERRACE
90'-0"
TURN
RADIUS

PROPOSED

STANDPIPE ON SITE
48'-0"
64'-0"
90'-0"
26'-0"
150'
150'
150'
150'
150'
20'-0"
20'-0"
S
E
T
B
A
C
K
40'-0"

TRELLIS
ABOVE
26'-0"
62'-0"
72'-5"
22'-9"
20'-0"
15'-0"
20'-0"
26'-0"
120'
34'-0"

3.0%

3.1%

5.6%

5.0%

PROPOSED

STANDPIPE

PROPOSED

STANDPIPE INSIDE
STAIR

PROPOSED

STANDPIPE INSIDE
STAIR
28'-0"
24'-0"
10'-0"
20'-0"
TYP.
20'-0"
TYP.
10'-0"

4.6%

6.2%

REFER TO CIVIL FOR

ALL GRADING SLOPE

FIRE APPARATUS ACCESS

ACCESS / EGRESS POINT

PLAN LEGEND

EGRESS PATH

PROPOSED STANDPIPE
0 SCALE =
1'-0"
FT
N
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"
key plan
project logo

7.5 30 15 60
1/32" U.N.O.

Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL

KEYNOTES / LEGENDS
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:35:23 PM

FIRE DEPARTMENT ACCESS
PLAN
AP0-012
194168 01/20/21
Checker
Author
1" = 30'-0"
FIRE DEPARTMENT SITE ACCESS PLAN 1

D
Y
H
S
D
Y
H
D
Y
H
S
S
S
S
S
D
Y
H
S
62 '
+8050
DN TO B1
+8048
+8046
+8060
+8067
+8066
+8053
+8063
+8063
+8063
+8062
REQUIRED 10'-0" MINIMUM STREET

FRONTAGE STORAGE AREA

PARKING AND DRIVEWAY AREA
(31,462 SF)

PARKING AND DRIVEWAY SNOW

STORAGE AREA
*MINIMUM 60% OF PARKING AND DRIVEWAY AREA
(19,074 SF - 60.6%)

SIDEWALK AND WALKWAY AREA

SNOW STORAGE LEGEND

SIDEWALK AND WALKWAY SNOW

STORAGE AREA

CURB ENTRY TO BE MANUALY

CLEARED AND PLOWED

SNOW MELT SYSTEM PROPOSED

SNOW CLEARING DIRECTION
EVENT
LAWN

TRELLIS
EXIT /
ENTRY

COVERED
PORTECOCHERE
SPA
POOL
ENTRY
DRIVE

TRELLIS
ABOVE
LOBBY

TERRACE
POOL
DECK
RAMP
DOWN

PARKING
ENTRY

BUS STOP

EXISTING

WESTIN MONACHE

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING

EXISTING

BUILDING
MAIN
ENTRY

OVERSIZE VEHICLE,
RESIDENTIAL VISITOR, 10%

GUEST ACCESS & EVENT

AREA LOT
SPA
CANYON BLVD.

LAKE MARY RD.
10'-0" MIN.

CANYON BLVD.

SNOW STORAGE
10'-0" MIN.

CANYON BLVD.

SNOW STORAGE
10'-0" MIN.

CANYON BLVD.

SNOW STORAGE
10'-0" MIN.

LAKE MARY RD.

SNOW STORAGE
CLEAR
ENTRY
DRIVE
CLEAR

SERVICE

ENTRY DRIVE
CLEAR

ENTRY DRIVE
CLEAR

WALKWAYS
CLEAR

WALKWAYS
CLEAR

WALKWAYS

SNOW MELT

SYSTEM AT
STAIRS
CLEAR

WALKWAYS

CLEAR FIRE
ACCESS

SNOW MELT

SYSTEM AT ENTRY

DRIVEWAY &

PARKING RAMP

DRIVEWAY SNOW

STORAGE AREA

DRIVEWAY SNOW

STORAGE AREA

SNOW PILE

STORAGE
AREA

PARKING SNOW

STORAGE AREA
CLEAR

WALKWAYS

SNOW MELT SYSTEM

AT DROP OFF AND

TEMPORARY PARKING

WALKWAY SNOW

STORAGE AREA

SNOW MELT SYSTEM

AT POOL/SPA

DECK/TERRACE

SNOW MELT SYSTEM

AT LOBBY/DINING

TERRACE

SNOW MELT

SYSTEM AT
LOUNGE

TERRAACE &

SKI VALLET

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE

PROPERTY LINE
MAIN
ENTRY

PROPERTY LINE

PROPERTY LINE
WESTIN
STAIRS

LIMELIGHT MAMMOTH
HOTEL

COVERED
DECK

TRELLIS
ABOVE

SNOW MELT

SYSTEM AT
STAIRS

PROPERTY LINE
0 SCALE =
1'-0"
FT
N
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"
key plan
project logo

7.5 30 15 60
1/32" U.N.O.

Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL

KEYNOTES / LEGENDS
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:35:41 PM

SNOW MANAGEMENT &

STORAGE PLAN
AP0-013
194168 01/20/21
Checker
Author
1" = 30'-0"
SNOW MANGEMENT & STORAGE PLAN 1

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

CANYON
B
LVD.

LAKE MARY RD.

N
sheet title
sheet no.
component
project no.
checked by:
drawn by:
date
irvine | CA | 949 574 8500
strategy planning architecture landscape interiors
client | consultant
stamp | approval
issues | revisions
no. date issue
watg.com
The original size of this drawing is 24"x36"

KEYNOTES / LEGENDS
key plan
project logo
Copyright © 2016 WATG. All rights reserved.
5 CANYON BLVD. MAMMOTH LAKES,
CA 93546

LIMELIGHT HOTEL
ENTITLEMENT RESUBMITTAL | APRIL 1, 2022
4/1/2022 9:37:51 PM

SHADE/SHADOW ANALYSIS
AP0-014
194168 02/08/21
Checker
Author
1" = 160'-0"
JUNE 20TH | 9 AM | SUMMER SOLSTICE 2
1" = 160'-0"
MARCH 20TH | 9 AM | VERNAL EQUINOX 1
1" = 160'-0"
SEPT 21ST | 9 AM | FALL EQUINOX 3
1" = 160'-0"
DEC 22ND | 9 AM | WINTER SOLSTICE 4
1" = 160'-0"
MARCH 20TH | 12 NOON | VERNAL EQUINOX 5
1" = 160'-0"
JUNE 20TH | 12 NOON | SUMMER SOLSTICE 6
1" = 160'-0"
SEPT 21ST | 12 NOON | FALL EQUINOX 7
1" = 160'-0"
DEC 22ND | 12 NOON | WINTER SOLSTICE 8
1" = 160'-0"
MARCH 20TH | 3 PM | VERNAL EQUINOX
9 1" = 160'-0"
JUNE 20TH | 3 PM | SUMMER SOLSTICE
10 1" = 160'-0"
SEPT 21ST | 3 PM | FALL EQUINOX
11 1" = 160'-0"
DEC 22ND | 3 PM | WINTER SOLSTICE
12 1" = 160'-0"
MARCH 20TH | 5 PM | VERNAL EQUINOX
13 1" = 160'-0"
JUNE 20TH | 5 PM | SUMMER SOLSTICE
14 1" = 160'-0"
SEPT 21ST | 5 PM | FALL EQUINOX
15 1" = 160'-0"
DEC 22ND | 5 PM | WINTER SOLSTICE
16 0
SCALE 1" =
40 80 320 160 FT
160'-0"