Rancho Mirage
City Council Meeting
December 18, 2025
Public Testimony - Agenda Item No. 6A
Environmental Assessment Case No. EA21-0002,
General Plan Zoning Map Amendment Case
No. GPZMA21-0001, Development Agreement
Amendment Case No. DA21-0002, Major Modification
Case No. MOD21-0004, and Tentative Parcel Map
Case No. TPM23-0002 (TPM38768) -
Ritz Carlton Rancho Mirage
From: Ben Torres
To: Kristie Ramos, CMC
Subject: FW:
Date: Friday, December 12, 2025 3:40:55 PM
Attachments: city seal transparent 2 4b81bffe-bb95-4b18-a74a-4086edea3b60.pnq doc00428120251212153921.pdf
Hello Kristie,
Please see the attached public comment we received in the mail today for the Ritz Carlton project, I did not receive this comment via email.
Thank you,
Ben Torres
Planning Manager
Phone: 760-328-2266 Ext. 253
E-mail: [email protected]
69-825 Highway 111, Rancho Mirage, California, 92270
www.RanchoMirageCa.gov
TRANSPARENCY NOTICE
Some or all of the content of this e-mail and its attachments may be subject to disclosure pursuant to the California Public Records Act (Government Code section 7920-7931, et seq.) Original Message
From: [email protected]
Sent: Friday, December 12, 2025 3:39 PM
To: Ben Torres
Subject:
TASKa1fa 4054ci
[d4:f0:c9:12:24:98]
25 DEC i2 PH 3:37
December 9, 2025
Via Email & U.S. Mail
Ben Torres, Planning Manager ([email protected])
City of Rancho Mirage
69-825 California Highway 111
Rancho Mirage, CA 92270
RE: Ritz Carlton Rancho Mirage - Environmental Assessment Case No.
EA21-0002, General Plan Zoning Map Amendment Case No. GPZMA21- 0001, Development Agreement Amendment Case No. DA21-0002, Major MoGification Case No. MOD21-0004, & Tentative Parcel Map Case Number TPM23-0002 (TPM38768),
Dear Planning Manager, Ben Torres:
I have been a resident for the past six years at the Mirada Estates (and Mirada Villas) community. Mirada Estates, also known as "The Mountain Sanctuary," is located in the Santa Rosa Mountains and is adjacent to the Ritz Carlton Resort. Our neighborhood is a small enclave of custom homes built by owners and developers and was inspired by the natural beauty of 272,000 acres of surrounding pristine wilderness. The residents of my community have selected this neighborhood because of the solitude that exists in our area. This prized solitude is the one of chief reasons, among others, that I write this letter concerning problems with the below project that that is proposed in the City of Rancho Mirage ("City").
A. The Proposed Project.
I am writing to you concerning the proposed development project at the Ritz -Carlton Rancho Mirage. The proposed project involves construction described as the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.3 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 ("Project"). The Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/ commercial space, and approximately 5,510 -square feet of amenity space.
The overall Project site includes an existing hotel that opened as a Ritz -Carlton in 1988.
The Project would also provide a total of 499 vehicle parking spaces.
As part of the proposed Project, the developer requested a General Plan Zoning Map Amendment to amend the City's Mountain Reserve (MR) designation for the Project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres.
B. The City's Analysis of the Project.
In March 2024, the City released the first Initial study result of the Project. That study resulted in a recommendation to adopt a Mitigated Negative Declaration (MND) for the Project. In July 2024, the City released a Recirculated Initial Study / Mitigated Negative
v1,..v.aw1awuv11 , 1N.w11•.. / wI a •a. I I VJI.. L. I III.14CAILGI, Nlc Vlly IJJuc\I ILO 1-/GleGI IIucI CAI Z..1. I Illal Initial Study / Mitigated Negative Declaration ("FMND") for the Project.
C. Planning Commission Approval of Project.
On January 9, 2025, as party of the proposed Project, the City's Planning Commission considered the following requests from the developer of the Project:
(1) General Pan Zoning Map Amendment to amend the iviountain Reserve (MR) designation for the project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres (APNs: 689-020-012 & 689-020-014). (2) A Tentative Parcel Map (TPM38768) to establish three parcels (excluding Sky Mesa area) with Parcel 3 of the map containing condo units (Ritz Carlton residences).
(3) Lastly, a 10th Amendment to the existing Deveiopment Agreement with Newage Rancho Mirage, LLC (the "10th Amendment") is proposed. Please note that the proposed project (excluding Sky Mesa) is a modification to the originally approved 2006 project entitlements that included residential villas and condominiums.
It is my understanding that the City's Planning Commission previously voted on January 9, 2025, to recommend that this Project move forward and approved the following resolutions and actions:
(1) A resolution approving the mitigation monitoring and reporting program and mitigated negative declaration (sch# 2024030267) for the Project based on environmental assessment case no. EA21- 0002.
(2) A resolution approving general plan zoning map amendment (GPZMA21- 0001), tentative parcel man case nn_TPM23- 0002. and major modification case no MOD21- 0004.
(3) And ordinance approving development agreement amendment (DA21-0002).
D. Problems with the Project.
aril corlcerileu t iat i le i,i y's Plaiiriiny .;uiiiiiiission has approved This Pr ojeci wiiiioui addressing numerous problems that will arise with the Project. Before I address those problems, I want to make it abundantly clear that I am not opposed the Project. The Ritz - Carlton has been a wonderful neighbor. I am not opposed to principal of development at all. However, there are a number of issues that I think the City, and the developer, need to address concerning the Project before it proceeds and that is the purpose of this letter.
The proposed Project will significantly impact my neighborhood. In particular, I am deeply l:bncerlied about the envlrorllllelltai ar Id irillaslructuF& it IIpacts this Project way IIaVe 01 our neighborhood. I am concerned about this Project moving forward in the follow areas:
(1) Construction phase of the Project and impact on Frank Sinatra Drive; (2) Pedestrian traffic on Frank Sinatra Drive; and
(3) Construction noise; and,
(4) The Project buildings will obstruct resident's views.
I will address each of these points further below.
(1) CONSTRUCTION PHASE OF THE PROJECT AND IMPACT ON FRANK
SINATRA DRIVE
One of the primary problems with the Project will be the increased construction activity that
...n u•-• vi aIle vvIwuuvuvII IIl.vl,OO Iy UJ ul ll ly QIJlJUL LI 110 GI IVI I IIVUA F I U)CI L into fruition. Since Frank Sinatra Drive will be the main arterial for construction traffic into the Project, traffic will be enormously and negatively impacted in that area. This construction traffic will impact my neighborhood greatly since the visitor numbers are likely to significantly affect ingress and egress via Frank Sinatra Drive. The chief entry point to the Project will be Frank Sinatra Drive. As this street is shared by both the existing Ritz - Carlton, and my neighborhood, this additional stress on that artery would overload its capabilities. This thoroughfare is crucial for daily commutes and, more importantly, for emernency vehicle access_ Many of the residents in my community are elrierly and rely_ nn prompt emergency services. Obstructions or delays on this route could have serious consequences.
To address the above concerns, I would propose that the paved service road located behind the Ritz -Carlton be expanded and utilized for all construction -related activities. It is unused currently, and leads directly to the area where the planned Project will be built.
This would include the transportation of heavy equipment, steel girders, concrete, material and construction personnel_ RI/ diverting construction traffic away from Frank Sinatra Drive, construction on the Project can proceed but residents and emergency vehicles can retain uninterrupted access to our community. Additionally, this proposed solution would help to minimize noise, dust, and debris in residential areas, preserving the peaceful environment we value. Finally, this solution would decrease the risk of accidents or delays associated with increased traffic on Frank Sinatra Drive.
There are additionally other means to address the above concerns as follows:
• Aluminize unnecessary vehicular and machinery activities.
Require contractors to assemble a comprehensive inventory list (Le., make, model, engine year, horsepower, emission rates) of all heavy-duty off -road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. • Ensure all construction equipment is properly tuned and maintained • Minimizing idling time to 5 minutes or beyond regulatory requirements — saves fuel and reduces emissions.
• Develop a traffic plan to minimize community impacts because of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours.
Minimize obstruction of through- traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. (2) PEDESTRIAN TRAFFIC ON FRANK SINATRA DRIVE
i am very concerned about pedestrian traffic corning up Frank Sinatra Road. As you undoubtedly know, there are no sidewalks that frame Frank Sinatra Road from Highway 111 to the Ritz -Carlton. Despite the absence of sidewalks on that artery, presently there are numerous pedestrians that utilize the road itself to walk and down its length. These pedestrians are often hotel guests unfamiliar with the dangers that await them down the circuitous and steep decline of the road in that area. This foot traffic is guaranteed to increase with the construction of the Project since more residents/visitors will translate to more pedestrians along Frank Sinatra Drive. This increased pedestrian traffic will, then, predictably result in more injuries and accidents in this area. l do not believe that the City, nor the applicant for the Project, has properly analyzed, let alone address, this serious safety concern.
To address this concern, it is urged that a protected pedestrian sidewalk be constructed on either side of Frank Sinatra Drive.
The construction of this Project will take place over months and years. The construction phase then will introduce substantial noise, dust, debris, and general disruption into the surrounding area which threaten the tranquility and environmental quality that residents currently enjoy.
in correspondence addressing Drohlems with the Proiert dated .lanuary 9. 2025. the group "Californians Allied for a Responsible Economy" ("CARE"), noted that City's analysis underestimates construction noise impacts for the Project. In that letter (p. 2), CARE noted that "[d]ue to the proximity of residences to the Project site, construction and operational noise impacts would also be significant. Construction noise would increase ambient noise levels by over 20 decibels, which the City acknowledges would be a significant impact.
The problems with construction noise were also extensively hiahlir.hted by the letter submitted by 28 -page letter from Mitchell M. Tsai law firm, submitted on behalf of the Western States Regional Council of Carpenters ("WSRCC"). In that letter (at p. 19-21), WSRCC focused on problems with the City's analysis of ambient noise problems with the Project and its utilization of improper data to analyze the noise problems at the Project:
Meanwhile, as I understand it, no noise measurements have been taken along the soukhern border of the tvvo paroeis OA the I rujeii site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 6308932-06- and 630893-208) which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area.
In spite of these facts, however, the FMND continues to inaccurately claim that " The long-term noise level measurements were positioned as close to the nearest sensitive receiver locations as possible to assess the existing ambient hourly noise levels surrounding the project site." (FMND at p. 145.) The City's continuing failure and refusal to update the Project's noise studies to address these deficiencies is glaring, and the City's responses to comments fail to address the lack of study of the ambient noise levels at positions closest to the Project's nearby sensitive receptors. (See FMND, Appendix Responses Cornn e t Response to ---n . Letter J, flGbil VItJCJ to VUII Ii IIGIIIJ, F\CSiJU115C 1.0 1 1 11 1 161 11 LCIiGI O1, pp.
RTC -839 - 840.) The City cannot be permitted to shirk the performance of proper environmental analysis for the Project in order to conceal the Project's true impacts.
The FMND has then continued to utilize this faulty and incomplete ambient noise survey data to conclude that there will be no significant impact to the surrounding sensitive receptors from the Project's construction noise. The Fi ti iL -_ d ___ Criteria for Recommended -Stand_.._. w _ aI a.
I IviiVu rruuNicu the vili6iita Ivi n��uninlcllucu v1[]livalu. vi;G4iiaiiviidi iVvi5� Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH) as the threshold for whether the anticipated construction noise from the Project will have a significant impact upon the Project nearby sensitive receptors. (FMND at p. 149.) The FMND then concludes that the threshold of 85 dBA Leq qualifies as an " acceptable threshold for construction noise at the nearby sensitive receiver locations," and the noise sensitive residential receiver locations will satisfy the 85 dBA Leq significance threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.) WSRCC reiterates that the NIOSH Occupational Noise Exposure standard has no proper place in evaluating the significance of construction noise impacts on nearby sensitive receptors. Rather, the NIOSH standard is aimed at protecting workers/laborers exposed to noise during the course job duties and preventing occupational harm/injury from occurring. It has no bearing upon external noise levels that would be suitable for maintaining the quiet
... ��.. y...... .. ... a... n.......auw .� N..vuw r.vNa.�ay. III LIIIAL Ia.yw u, Iw oaica.uvn v1 85 dBA Leg by the MND, RMND, and now the FMND as an acceptable threshold of significant construction noise impact is not only arbitrary, but it is also entirely unfounded.
The Federal Transit Administration's ("FTA") Transit Noise and Vibration Impact Assessment provides superior source of federal regulatory authority regarding a project's noise impacts and their significance on sensitive receptors. To that end, fire FTA guidance on noise level impacts rioies That the impacts should be assessed as a function of their increase over existing noise exposure, and that any noise increase of 15 dBA or greater for a residence is considered a " severe impact." (See Exhibit D-FTA Transit Noise and Vibration Impact Assessment, pp. 17-18, 23-31.) The MND/RMND/FMND arbitrarily elected to use the inapplicable NIOSH standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair arnument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations ( L1, L2, and L3) still have the potential to exceed an FTA guidance - based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment, (FMND at p. 146_ Table 13-2: compare FMND at p. 149; Table 13-3.) Indeed, comparison of the dBA values set forth in Table 12-3 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
One does not need to be a scientist schooled in the above to know that there wiii be a large amount of construction noise attendant to the construction of the Project that is deleterious to the environment of my community. Because construction noise will undoubtedly exceed a significant threshold, it must be mitigated in some reasonable manner.
Construction work on the Project is also to occur (is also exempt from provisions in the City's noise code), within allowable hours of 7 am to 7 pm (and is prohibited to occur on Sundays and holidays.) u addi`ess this concern, ii is urged that the ;iiyresirici the bows of construction by limiting the window under which construction is permitted by allowing construction to begin at 8:00 am, and end at 6:00 pm.
(4) THE PROJECT'S BUILDINGS WILL OBSTRUCT THE VIEW OF RESIDENTS...
Finally, I am concerned about the Project because construction of proposed buildings will I pndoubtedly impart the views of numerous residents in my community. In Dart! mIar, I am concerned about the view of residents of dwellings located at the north-east corner of Mirada Estates along Mirada Circle and Grand View Court. It does not appear that the City property analyzed the impact of the Project on the view of those homeowners. If indeed, those homeowner's view are negatively impacted, then the City, and the applicant for the Project, should (1) make those impacts clear; (2) if so negatively impacted, determine whether or not alternative exists that would allay those impacts/obstructed views.
CONCLUSION
I want to again make clear that I not opposed to the Project, only that portions of the Project, and its impacts, need to be addressed as set forth above. Due to the Project's potentially significant impact on the areas described above, I urge the City not to recommend approval of the Project until the problems and impacts outlined above are properly addressed and are fully mitigated.
Sincerely,
CC: Isaiah Hagerman, City Manager ([email protected])
From:
To:
Cc:
Subject:
Date:
Attachments:
Meryl Young
Lynn Mallotto; Michael O"Keefe; Ted Weill; Eve Fromberg Edelstein; Steve Downs; Kristie Ramos, CMC Ben Torres; Isaiah Hagerman, CPA; George Young
Ritz Carlton Project Concerns
Sunday, December 14, 2025 3:44:32 PM
LTR TO RM RE Ritz Carlton Project 2025 12 05.jdf
CAUTION: This email originated from outside The City of Rancho Mirage. DO NOT CLICK (inks or open attachments unless you recognize the sender and know the content is safe.
All,
Please see the attached letter expressing concerns of Mirada Estates residents regarding the proposed project.
Thank you for your consideration. We look forward to learning how you will address these concerns.
Regards,
George and Meryl Young
December 9, 2025
Via Email
Mayor Lynn Mallotto and Members of the City
Council
City of Rancho Mirage
69-825 California Highway 111
Rancho Mirage, CA 92270
RE: Ritz Carlton Rancho Mirage - Environmental Assessment Case No. EA21- 0002, General Plan Zoning Map Amendment Case No. GPZMA21-0001, Development Agreement Amendment Case No. DA21-0002, Mayor Modification Case No. MOD21-0004, & Tentative Parcel Map Case Number TPM23-0002 'TPM38768;.
Dear Mayor Lynn Mallotto and City Council Members:
I am a resident at the Mirada Estates community. Mirada Estates, also known as "The Mountain Sanctuary," is located in the Santa Rosa Mountains and is adjacent to the Ritz Carlton Resort. Our neighborhood is a small enclave of custom homes built by owners and developers and was inspired by the natural beauty of 272,000 acres of surrounding pristine wilderness. The residents of my community have selected this neighborhood because of the solitude that exists in our area. This prized solitude is the one of chief reasons, among others, that I write this letter concerning problems with the below project hat is proposed in the City of Rancho Mirage ("City").
A. The Proposed Project.
I am writing to you concerning the proposed development project at the Ritz -Carlton Rancho Mirage. The proposed project involves construction described as the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.3 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 ("Project"). The Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/ commercial space, and approximately 5,510 -square feet of amenity space.
The overall Project site includes an existing hotel that opened as a Ritz -Carlton in 1988.
The Project would also provide a total of 499 vehicle parking spaces.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
As part of the proposed Project, the developer requested a General Plan Zoning Map Amendment to amend the City's Mountain Reserve (MR) designation for the Project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres.
B. The City's Analysis of the Project.
In March 2024, the City released the first Initial study result of the Project. That study resulted in a recommendation to adopt a Mitigated Negative Declaration (MND) for the Project. In July 2024, the City released a Recirculated Initial Study / Mitigated Negative Declaration ("RMND") for the Project. Thereafter, the City issued its December 2024 Final Initial Study / Mitigated Negative Declaration ("FMND") for the Project.
C. Planning Commission Approval of Project.
On January 9, 2025, as party of the proposed Project, the City's Planning Commission considered the following requests from the developer of the Project:
(1) General Plan Zoning Map Amendment to amend the Mountain Reserve (MR) designation for the project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres (APNs: 689-020-012 & 689-020-014). (2) A Tentative Parcel Map (TPM38768) to establish three parcels (excluding Sky Mesa area) with Parcel 3 of the map containing condo units (Ritz Carlton residences).
(3) Lastly, a 10th Amendment to the existing Development Agreement with Newage Rancho Mirage, LLC (the "10th Amendment") is proposed. Please note that the proposed project (excluding Sky Mesa) is a modification to the originally approved 2006 project entitlements that included residential villas and condominiums.
It is my understanding that the City's Planning Commission previously voted on January 9, 2025, to recommend that this Project move forward and approved the following resolutions and actions:
(1) A resolution approving the mitigation monitoring and reporting program and mitigated negative declaration (sch# 2024030267) for the Project based on environmental assessment case no. EA21- 0002.
(2) A resolution approving general plan zoning map amendment (GPZMA21- 0001), tentative parcel map case no.TPM23- 0002, and major modification case no.
MOD21- 0004.
(3) And ordinance approving development agreement amendment (DA21-0002).
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
D. Problems with the Project.
I am concerned that the City's Planning Commission has approved this Project without addressing numerous problems that will arise with the Project. Before I address those problems, I want to make it abundantly clear that I am not opposed the Project. The Ritz - Carlton has been a wonderful neighbor. However, there are a number of issues that I think the City, and the developer, need to address concerning the Project before it proceeds and that is the purpose of this letter.
The proposed Project will significantly impact my neighborhood. In particular, I am deeply concerned about the environmental and infrastructural impacts this Project may have on our neighborhood. I am concerned about this Project moving forward in the follow areas:
(1) Construction phase of the Project and impact on Frank Sinatra Drive; (2) Pedestrian traffic on Frank Sinatra Drive; and
(3) Construction noise; and,
(4) The Project buildings will obstruct resident's views.
I will address each of these points further below.
(1) CONSTRUCTION PHASE OF THE PROJECT AND IMPACT ON FRANK
SINATRA DRIVE
One of the primary problems with the Project will be the increased construction activity that will arise as a result of the construction necessary to bring about this enormous Project into fruition. Since Frank Sinatra Drive will be the main arterial for construction traffic into the Project, traffic will be enormously and negatively impacted in that area. This construction traffic will impact my neighborhood greatly since the visitor numbers are likely to significantly affect ingress and egress via Frank Sinatra Drive'. The chief entry point to the Project will be Frank Sinatra Drive. As this street is shared by both the existing Ritz - Carlton, and my neighborhood, this additional stress on that artery would overload its capabilities. This thoroughfare is crucial for daily commutes and, more importantly, for emergency vehicle access. Many of the residents in my community are elderly and rely on prompt emergency services. Obstructions or delays on this route could have serious consequences.
To address the above concerns, I would propose that the paved service road located behind the Ritz -Carlton be expanded and utilized for all construction -related activities. It is unused currently, and leads directly to the area where the planned Project will be built.
This would include the transportation of heavy equipment, steel girders, concrete, ' Frank Sinatra drive is an east west major collector running through the City. Most of Frank Sinatra drive is constructed to its ultimate design standards with 100 foot right of way. However, Frank Sinatra drive, West of Hwy 111, is designed as a two-lane roadway in the general plan.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
materials, and construction personnel. By diverting construction traffic away from Frank Sinatra Drive, construction on the Project can proceed but residents and emergency vehicles can retain uninterrupted access to our community. Additionally, this proposed solution would help to minimize noise, dust, and debris in residential areas, preserving the peaceful environment we value. Finally, this solution would decrease the risk of accidents or delays associated with increased traffic on Frank Sinatra Drive.
There are additionally other means to address the above concerns as follows:
• Minimize unnecessary vehicular and machinery activities.
Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off -road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. • Ensure all construction equipment is properly tuned and maintained • Minimizing idling time to 5 minutes or beyond regulatory requirements — saves fuel and reduces emissions.
• Develop a traffic plan to minimize community impacts because of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours.
Minimize obstruction of through- traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. (2) PEDESTRIAN TRAFFIC ON FRANK SINATRA DRIVE
I am very concerned about pedestrian traffic coming up Frank Sinatra Road. As you undoubtedly know, there are no sidewalks that frame Frank Sinatra Road from Highway 111 to the Ritz -Carlton. Despite the absence of sidewalks on that artery, presently there are numerous pedestrians that utilize the road itself to walk up and down its length. These pedestrians are often hotel guests unfamiliar with the dangers that await them down the circuitous and steep decline of the road in that area. This foot traffic is guaranteed to increase with the construction of the Project since more residents/visitors will translate to more pedestrians along Frank Sinatra Drive. This increased pedestrian traffic will, then, predictably result in more injuries and accidents in this area. I do not believe that the City, nor the applicant for the Project, has properly analyzed, let alone addressed, this serious safety concern.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
To address this concern, it is urged that a protected pedestrian sidewalk be constructed on either side of Frank Sinatra Drive.
(3) CONSTRUCTION NOISE
The construction of this Project will take place over months and years. The construction phase then will introduce substantial noise, dust, debris, and general disruption into the surrounding area which threaten the tranquility and environmental quality that residents currently enjoy.
In correspondence addressing problems with the Project, dated January 9, 2025, the group "Californians Allied for a Responsible Economy" ("CARE"), noted that City's analysis underestimates construction noise impacts for the Project. In that letter (p. 2), CARE noted that "[d]ue to the proximity of residences to the Project site, construction and operational noise impacts would also be significant. Construction noise would increase ambient noise levels by over 20 decibels, which the City acknowledges would be a significant impact2.
The problems with construction noise were also extensively highlighted by the letter from Mitchell M. Tsai law firm, submitted on behalf of the Western States Regional Council of Carpenters ("WSRCC"). In that letter (at p. 19-21), WSRCC focused on problems with the City's analysis of ambient noise problems with the Project and its utilization of improper data to analyze the noise problems at the Project:
Meanwhile, as I understand it, no noise measurements have been taken along the southern border of the two parcels on the Project site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 6308932-06- and 630893-208) which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area.
In spite of these facts, however, the FMND continues to inaccurately claim that " The long-term noise level measurements were positioned as close to 2 And during operations, stationary equipment like HVAC systems would exceed the 45 decibel nighttime noise standards at the nearby residences." CARE highlighted evidence (at p. 6) that the highest construction noise would be 69.9 dBA, the Final IS/MND elsewhere states that the composite source noise level at 50 feet varies between 76.2 and 84.4 dBA.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
the nearest sensitive receiver locations as possible to assess the existing ambient hourly noise levels surrounding the project site." (FMND at p. 145.) The City's continuing failure and refusal to update the Project's noise studies to address these deficiencies is glaring, and the City's responses to comments fail to address the lack of study of the ambient noise levels at positions closest to the Project's nearby sensitive receptors. (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, pp.
RTC -839 - 840.) The City cannot be permitted to shirk the performance of proper environmental analysis for the Project in order to conceal the Project's true impacts.
The FMND has then continued to utilize this faulty and incomplete ambient noise survey data to conclude that there will be no significant impact to the surrounding sensitive receptors from the Project's construction noise. The FMND adopted the Criteria for Recommended Standard: Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH) as the threshold for whether the anticipated construction noise from the Project will have a significant impact upon the Project nearby sensitive receptors. (FMND at p. 149.) The FMND then concludes that the threshold of 85 dBA Leq qualifies as an " acceptable threshold for construction noise at the nearby sensitive receiver locations," and the noise sensitive residential receiver locations will satisfy the 85 dBA Leq significance threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.) WSRCC reiterates that the NIOSH Occupational Noise Exposure standard has no proper place in evaluating the significance of construction noise impacts on nearby sensitive receptors. Rather, the NIOSH standard is aimed at protecting workers/laborers exposed to noise during the course of job duties and preventing occupational harm/injury from occurring. It has no bearing upon external noise levels that would be suitable for maintaining the quiet enjoyment of an individual's private property. In that regard, the selection of 85 dBA Leq by the MND, RMND, and now the FMND as an acceptable threshold of significant construction noise impact is not only arbitrary, but it is also entirely unfounded.
The Federal Transit Administration's ("FTA") Transit Noise and Vibration Impact Assessment provides superior source of federal regulatory authority regarding a project's noise impacts and their significance on sensitive receptors. To that end, the FTA guidance on noise level impacts notes that the impacts should be assessed as a function of their increase over existing noise exposure, and that any noise increase of 15 dBA or greater for a residence is considered a " severe impact." (See Exhibit D-FTA Transit Noise and Vibration Impact Assessment, pp. 17-18, 23-31.) The MND/RMND/FMND arbitrarily elected to use the inapplicable NIOSH
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair argument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations ( L1, L2, and L3) still have the potential to exceed an FTA guidance - based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment. (FMND at p. 146, Table 13-2; compare FMND at p. 149, Table 13-3.) Indeed, comparison of the dBA values set forth in Table 12-3 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
One does not need to be a scientist schooled in the above to know that there will be a large amount of construction noise attendant to the construction of the Project that is deleterious to the environment of my community. Because construction noise will undoubtedly exceed a significant threshold, it must be mitigated in some reasonable manner.
Construction work on the Project is also to occur (is also exempt from provisions in the City's noise code), within allowable hours of 7 am to 7 pm (and is prohibited to occur on Sundays and holidays.) To address this concern, it is urged that the City restrict the hours of construction by limiting the window under which construction is permitted by allowing construction to begin at 8:00 am, and end at 6:00 pm.
(4) THE PROJECT'S BUILDINGS WILL OBSTRUCT THE VIEW OF RESIDENTS...
Finally, I am concerned about the Project because construction of proposed buildings will undoubtedly impact the views of numerous residents in my community. In particular, I am concerned about the view of residents of dwellings located at the north-east corner of Mirada Estates along Mirada Circle and Grand View Court. It does not appear that the City property analyzed the impact of the Project on the view of those homeowners. If indeed, those homeowner's view are negatively impacted, then the City, and the applicant for the Project, should (1) make those impacts clear; (2) if so negatively impacted, determine whether or not alternative exists that would allay those impacts/obstructed views.
CONCLUSION
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
I want to again make clear that I am not opposed to the Project, only that portions of the Project, and its impacts, need to be addressed as set forth above. Due to the Project's potentially significant impact on the areas described above, I urge the City not to recommend approval of the Project until the problems and impacts outlined above are properly addressed and are fully mitigated.
Sincerely,
George and Meryl Young
CC: Isaiah Hagerman, City Manager ([email protected])
2' GEC 16 F^: 3:55
December 9, 2025
Via Email & U.S. Mail
Kristie Ramos, City Clerk ([email protected]) City of Rancho Mirage
69-825 California Highway 111
Rancho Mirage, CA 92270
RE: Ritz Carlton Rancho Mirage - Environmental Assessment Case No. EA21- 0002, General Plan Zoning Map Amendment Case No. GPZMA21-0001, Development Agreement Amendment Case No. DA21-0002, Ma.or Modification Case No. MOD21-0004, & Tentative Parcel Map Case Number TPM23-0002 (TPM38768).
Dear City Clerk, Kristie Ramos:
I have been a resident for the past six years at the Mirada Estates (and Mirada Villas) community. Mirada Estates, also known as "The Mountain Sanctuary," is located in the Santa Rosa Mountains and is adjacent to the Ritz Carlton Resort. Our neighborhood is a small enclave of custom homes built by owners and developers and was inspired by the natural beauty of 272,000 acres of surrounding pristine wilderness. The residents of my community have selected this neighborhood because of the solitude that exists in our area.
This prized solitude is the one of chief reasons, among others, that I write this letter concerning problems with the below project that that is proposed in the City of Rancho Mirage ("City").
A. The Proposed Project.
I am writing to you concerning the proposed development project at the Ritz -Carlton Rancho Mirage. The proposed project involves construction described as the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.3 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 ("Project"). The Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/ commercial space, and approximately 5,510 -square feet of amenity space.
The overall Project site includes an existing hotel that opened as a Ritz -Carlton in 1988.
The Project would also provide a total of 499 vehicle parking spaces.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
As part of the proposed Project, the developer requested a General Plan Zoning Map Amendment to amend the City's Mountain Reserve (MR) designation for the Project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres.
B. The City's Analysis of the Project.
In March 2024, the City released the first Initial study result of the Project. That study resulted in a recommendation to adopt a Mitigated Negative Declaration (MND) for the Project. In July 2024, the City released a Recirculated Initial Study / Mitigated Negative Declaration ("RMND") for the Project. Thereafter, the City issued its December 2024 Final Initial Study / Mitigated Negative Declaration ("FMND") for the Project.
C. Planning Commission Approval of Project.
On January 9, 2025, as party of the proposed Project, the City's Planning Commission considered the following requests from the developer of the Project:
(1) General Plan Zoning Map Amendment to amend the Mountain Reserve (MR) designation for the project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres (APNs: 689-020-012 & 689-020-014). (2) A Tentative Parcel Map (TPM38768) to establish three parcels (excluding Sky Mesa area) with Parcel 3 of the map containing condo units (Ritz Carlton residences).
(3) Lastly, a 10th Amendment to the existing Development Agreement with Newage Rancho Mirage, LLC (the "10th Amendment") is proposed. Please note that the proposed project (excluding Sky Mesa) is a modification to the originally approved 2006 project entitlements that included residential villas and condominiums.
It is my understanding that the City's Planning Commission previously voted on January 9, 2025, to recommend that this Project move forward and approved the following resolutions and actions:
(1) A resolution approving the mitigation monitoring and reporting program and mitigated negative declaration (sch# 2024030267) for the Project based on environmental assessment case no. EA21- 0002.
(2) A resolution approving general plan zoning map amendment (GPZMA21- 0001), tentative parcel map case no.TPM23- 0002, and major modification case no.
MOD21- 0004.
(3) And ordinance approving development agreement amendment (DA21-0002).
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
D. Problems with the Project.
I am concerned that the City's Planning Commission has approved this Project without addressing numerous problems that will arise with the Project. Before I address those problems, I want to make it abundantly clear that I am not opposed the Project. The Ritz - Carlton has been a wonderful neighbor. I am not opposed to principal of development at all. However, there are a number of issues that I think the City, and the developer, need to address concerning the Project before it proceeds and that is the purpose of this letter.
The proposed Project will significantly impact my neighborhood. In particular, I am deeply concerned about the environmental and infrastructural impacts this Project may have on our neighborhood. I am concerned about this Project moving forward in the follow areas:
(1) Construction phase of the Project and impact on Frank Sinatra Drive; (2) Pedestrian traffic on Frank Sinatra Drive; and
(3) Construction noise; and,
(4) The Project buildings will obstruct resident's views.
I will address each of these points further below.
(1) CONSTRUCTION PHASE OF THE PROJECT AND IMPACT ON FRANK
SINATRA DRIVE
One of the primary problems with the Project will be the increased construction activity that will arise as a result of the construction necessary to bring about this enormous Project into fruition. Since Frank Sinatra Drive will be the main arterial for construction traffic into the Project, traffic will be enormously and negatively impacted in that area. This construction traffic will impact my neighborhood greatly since the visitor numbers are likely to significantly affect ingress and egress via Frank Sinatra Drive'. The chief entry point to the Project will be Frank Sinatra Drive. As this street is shared by both the existing Ritz - Carlton, and my neighborhood, this additional stress on that artery would overload its capabilities. This thoroughfare is crucial for daily commutes and, more importantly, for emergency vehicle access. Many of the residents in my community are elderly and rely on prompt emergency services. Obstructions or delays on this route could have serious consequences.
To address the above concerns, I would propose that the paved service road located behind the Ritz -Carlton be expanded and utilized for all construction -related activities. It is unused currently, and leads directly to the area where the planned Project will be built.
This would include the transportation of heavy equipment, steel girders, concrete, Frank Sinatra drive is an east west major collector running through the City. Most of Frank Sinatra drive is constructed to its ultimate design standards with 100 foot right of way. However, Frank Sinatra drive, West of Hwy 111, is designed as a two-lane roadway in the general plan.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
materials, and construction personnel. By diverting construction traffic away from Frank Sinatra Drive, construction on the Project can proceed but residents and emergency vehicles can retain uninterrupted access to our community. Additionally, this proposed solution would help to minimize noise, dust, and debris in residential areas, preserving the peaceful environment we value. Finally, this solution would decrease the risk of accidents or delays associated with increased traffic on Frank Sinatra Drive.
There are additionally other means to address the above concerns as follows:
• Minimize unnecessary vehicular and machinery activities.
Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off -road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. • Ensure all construction equipment is properly tuned and maintained • Minimizing idling time to 5 minutes or beyond regulatory requirements — saves fuel and reduces emissions.
• Develop a traffic plan to minimize community impacts because of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours.
Minimize obstruction of through- traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. (2) PEDESTRIAN TRAFFIC ON FRANK SINATRA DRIVE
I am very concerned about pedestrian traffic coming up Frank Sinatra Road. As you undoubtedly know, there are no sidewalks that frame Frank Sinatra Road from Highway 111 to the Ritz -Carlton. Despite the absence of sidewalks on that artery, presently there are numerous pedestrians that utilize the road itself to walk and down its length. These pedestrians are often hotel guests unfamiliar with the dangers that await them down the circuitous and steep decline of the road in that area. This foot traffic is guaranteed to increase with the construction of the Project since more residents/visitors will translate to more pedestrians along Frank Sinatra Drive. This increased pedestrian traffic will, then, predictably result in more injuries and accidents in this area. I do not believe that the City, nor the applicant for the Project, has properly analyzed, let alone address, this serious safety concern.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
To address this concern, it is urged that a protected pedestrian sidewalk be constructed on either side of Frank Sinatra Drive.
(3) CONSTRUCTION NOISE
The construction of this Project will take place over months and years. The construction phase then will introduce substantial noise, dust, debris, and general disruption into the surrounding area which threaten the tranquility and environmental quality that residents currently enjoy.
In correspondence addressing problems with the Project, dated January 9, 2025, the group "Californians Allied for a Responsible Economy" ("CARE"), noted that City's analysis underestimates construction noise impacts for the Project. In that letter (p. 2), CARE noted that "[d]ue to the proximity of residences to the Project site, construction and operational noise impacts would also be significant. Construction noise would increase ambient noise levels by over 20 decibels, which the City acknowledges would be a significant impact2.
The problems with construction noise were also extensively highlighted by the letter submitted by 28 -page letter from Mitchell M. Tsai law firm, submitted on behalf of the Western States Regional Council of Carpenters ("WSRCC"). In that letter (at p. 19-21), WSRCC focused on problems with the City's analysis of ambient noise problems with the Project and its utilization of improper data to analyze the noise problems at the Project:
Meanwhile, as I understand it, no noise measurements have been taken along the southern border of the two parcels on the Project site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 6308932-06- and 630893-208) which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area.
In spite of these facts, however, the FMND continues to inaccurately claim that " The long-term noise level measurements were positioned as close to 2 And during operations, stationary equipment like HVAC systems would exceed the 45 decibel nighttime noise standards at the nearby residences." CARE highlighted evidence (at p. 6) that the highest construction noise would be 69.9 dBA, the Final IS/MND elsewhere states that the composite source noise level at 50 feet varies between 76.2 and 84.4 dBA.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
the nearest sensitive receiver locations as possible to assess the existing ambient hourly noise levels surrounding the project site." (FMND at p. 145.) The City's continuing failure and refusal to update the Project's noise studies to address these deficiencies is glaring, and the City's responses to comments fail to address the lack of study of the ambient noise levels at positions closest to the Project's nearby sensitive receptors. (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, pp.
RTC -839 - 840.) The City cannot be permitted to shirk the performance of proper environmental analysis for the Project in order to conceal the Project's true impacts.
The FMND has then continued to utilize this faulty and incomplete ambient noise survey data to conclude that there will be no significant impact to the surrounding sensitive receptors from the Project's construction noise. The FMND adopted the Criteria for Recommended Standard: Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH) as the threshold for whether the anticipated construction noise from the Project will have a significant impact upon the Project nearby sensitive receptors. (FMND at p. 149.) The FMND then concludes that the threshold of 85 dBA Leq qualifies as an " acceptable threshold for construction noise at the nearby sensitive receiver locations," and the noise sensitive residential receiver locations will satisfy the 85 dBA Leq significance threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.) WSRCC reiterates that the NIOSH Occupational Noise Exposure standard has no proper place in evaluating the significance of construction noise impacts on nearby sensitive receptors. Rather, the NIOSH standard is aimed at protecting workers/laborers exposed to noise during the course job duties and preventing occupational harm/injury from occurring. It has no bearing upon external noise levels that would be suitable for maintaining the quiet enjoyment of an individual's private property. In that regard, the selection of 85 dBA Leq by the MND, RMND, and now the FMND as an acceptable threshold of significant construction noise impact is not only arbitrary, but it is also entirely unfounded.
The Federal Transit Administration's ("FTA") Transit Noise and Vibration Impact Assessment provides superior source of federal regulatory authority regarding a project's noise impacts and their significance on sensitive receptors. To that end, the FTA guidance on noise level impacts notes that the impacts should be assessed as a function of their increase over existing noise exposure, and that any noise increase of 15 dBA or greater for a residence is considered a " severe impact." (See Exhibit D-FTA Transit Noise and Vibration Impact Assessment, pp. 17-18, 23-31.) The MND/RMND/FMND arbitrarily elected to use the inapplicable NIOSH
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair argument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations ( L1, L2, and L3) still have the potential to exceed an FTA guidance - based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment. (FMND at p. 146, Table 13-2; compare FMND at p. 149, Table 13-3.) Indeed, comparison of the dBA values set forth in Table 12-3 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
One does not need to be a scientist schooled in the above to know that there will be a large amount of construction noise attendant to the construction of the Project that is deleterious to the environment of my community. Because construction noise will undoubtedly exceed a significant threshold, it must be mitigated in some reasonable manner.
Construction work on the Project is also to occur (is also exempt from provisions in the City's noise code), within allowable hours of 7 am to 7 pm (and is prohibited to occur on Sundays and holidays.) To address this concern, it is urged that the City restrict the hours of construction by limiting the window under which construction is permitted by allowing construction to begin at 8:00 am, and end at 6:00 pm.
(4) THE PROJECT'S BUILDINGS WILL OBSTRUCT THE VIEW OF RESIDENTS...
Finally, I am concerned about the Project because construction of proposed buildings will undoubtedly impact the views of numerous residents in my community. In particular, I am concerned about the view of residents of dwellings located at the north-east corner of Mirada Estates along Mirada Circle and Grand View Court. It does not appear that the City property analyzed the impact of the Project on the view of those homeowners. If indeed, those homeowner's view are negatively impacted, then the City, and the applicant for the Project, should (1) make those impacts clear; (2) if so negatively impacted, determine whether or not alternative exists that would allay those impacts/obstructed views.
CONCLUSION
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
I want to again make clear that I not opposed to the Project, only that portions of the Project, and its impacts, need to be addressed as set forth above. Due to the Project's potentially significant impact on the areas described above, I urge the City not to recommend approval of the Project until the problems d impacts outlined above are properly addressed and are fully mitigated.
Sincer
4,%ea' lex3
CC: Isaiah Hagerman, City Manager ([email protected])
75 Da:
December 9, 2025
Via Email & U.S. Mail
Kristie Ramos, City Clerk ([email protected]) City of Rancho Mirage
69-825 California Highway 111
Rancho Mirage, CA 92270
RE: Ritz Carlton Rancho Mirage - Environmental Assessment Case No. EA21- 0002, General Plan Zoning Map Amendment Case No. GPZMA21-0001, Development Agreement Amendment Case No. DA21-0002, Ma'or Modification Case No. MOD21-0004, & Tentative Parcel Map Case Number TPM23-0002 (TPM38768).
Dear City Clerk, Kristie Ramos:
I have been a resident for the past six years at the Mirada Estates (and Mirada Villas) community. Mirada Estates, also known as "The Mountain Sanctuary," is located in the Santa Rosa Mountains and is adjacent to the Ritz Carlton Resort. Our neighborhood is a small enclave of custom homes built by owners and developers and was inspired by the natural beauty of 272,000 acres of surrounding pristine wilderness. The residents of my community have selected this neighborhood because of the solitude that exists in our area.
This prized solitude is the one of chief reasons, among others, that I write this letter concerning problems with the below project that that is proposed in the City of Rancho Mirage ("City").
A. The Proposed Project.
I am writing to you concerning the proposed development project at the Ritz -Carlton Rancho Mirage. The proposed project involves construction described as the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.3 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 ("Project"). The Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/ commercial space, and approximately 5,510 -square feet of amenity space.
The overall Project site includes an existing hotel that opened as a Ritz -Carlton in 1988.
The Project would also provide a total of 499 vehicle parking spaces.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
As part of the proposed Project, the developer requested a General Plan Zoning Map Amendment to amend the City's Mountain Reserve (MR) designation for the Project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres.
B. The City's Analysis of the Project.
In March 2024, the City released the first Initial study result of the Project. That study resulted in a recommendation to adopt a Mitigated Negative Declaration (MND) for the Project. In July 2024, the City released a Recirculated Initial Study / Mitigated Negative Declaration ("RMND") for the Project. Thereafter, the City issued its December 2024 Final Initial Study / Mitigated Negative Declaration ("FMND") for the Project.
C. Planning Commission Approval of Project.
On January 9, 2025, as party of the proposed Project, the City's Planning Commission considered the following requests from the developer of the Project:
(1) General Plan Zoning Map Amendment to amend the Mountain Reserve (MR) designation for the project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres (APNs: 689-020-012 & 689-020-014). (2) A Tentative Parcel Map (TPM38768) to establish three parcels (excluding Sky Mesa area) with Parcel 3 of the map containing condo units (Ritz Carlton residences).
(3) Lastly, a 10th Amendment to the existing Development Agreement with Newage Rancho Mirage, LLC (the "10th Amendment") is proposed. Please note that the proposed project (excluding Sky Mesa) is a modification to the originally approved 2006 project entitlements that included residential villas and condominiums.
It is my understanding that the City's Planning Commission previously voted on January 9, 2025, to recommend that this Project move forward and approved the following resolutions and actions:
(1) A resolution approving the mitigation monitoring and reporting program and mitigated negative declaration (sch# 2024030267) for the Project based on environmental assessment case no. EA21- 0002.
(2) A resolution approving general plan zoning map amendment (GPZMA21- 0001), tentative parcel map case no.TPM23- 0002, and major modification case no.
MOD21- 0004.
(3) And ordinance approving development agreement amendment (DA21-0002).
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
D. Problems with the Proect.
I am concerned that the City's Planning Commission has approved this Project without addressing numerous problems that will arise with the Project. Before I address those problems, I want to make it abundantly clear that I am not opposed the Project. The Ritz - Carlton has been a wonderful neighbor. I am not opposed to principal of development at all. However, there are a number of issues that I think the City, and the developer, need to address concerning the Project before it proceeds and that is the purpose of this letter.
The proposed Project will significantly impact my neighborhood. In particular, I am deeply concerned about the environmental and infrastructural impacts this Project may have on our neighborhood. I am concerned about this Project moving forward in the follow areas:
(1) Construction phase of the Project and impact on Frank Sinatra Drive; (2) Pedestrian traffic on Frank Sinatra Drive; and
(3) Construction noise; and,
(4) The Project buildings will obstruct resident's views.
I will address each of these points further below.
(1) CONSTRUCTION PHASE OF THE PROJECT AND IMPACT ON FRANK
SINATRA DRIVE
One of the primary problems with the Project will be the increased construction activity that will arise as a result of the construction necessary to bring about this enormous Project into fruition. Since Frank Sinatra Drive will be the main arterial for construction traffic into the Project, traffic will be enormously and negatively impacted in that area. This construction traffic will impact my neighborhood greatly since the visitor numbers are likely to significantly affect ingress and egress via Frank Sinatra Drive'. The chief entry point to the Project will be Frank Sinatra Drive. As this street is shared by both the existing Ritz - Carlton, and my neighborhood, this additional stress on that artery would overload its capabilities. This thoroughfare is crucial for daily commutes and, more importantly, for emergency vehicle access. Many of the residents in my community are elderly and rely on prompt emergency services. Obstructions or delays on this route could have serious consequences.
To address the above concerns, 1 would propose that the paved service road located behind the Ritz -Carlton be expanded and utilized for all construction -related activities. It is unused currently, and leads directly to the area where the planned Project will be built.
This would include the transportation of heavy equipment, steel girders, concrete, ' Frank Sinatra drive is an east west major collector running through the City. Most of Frank Sinatra drive is constructed to its ultimate design standards with 100 foot right of way. However, Frank Sinatra drive, West of Hwy 111, is designed as a two-lane roadway in the general plan.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
materials, and construction personnel. By diverting construction traffic away from Frank Sinatra Drive, construction on the Project can proceed but residents and emergency vehicles can retain uninterrupted access to our community. Additionally, this proposed solution would help to minimize noise, dust, and debris in residential areas, preserving the peaceful environment we value. Finally, this solution would decrease the risk of accidents or delays associated with increased traffic on Frank Sinatra Drive.
There are additionally other means to address the above concerns as follows:
• Minimize unnecessary vehicular and machinery activities.
Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off -road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. • Ensure all construction equipment is properly tuned and maintained • Minimizing idling time to 5 minutes or beyond regulatory requirements — saves fuel and reduces emissions.
• Develop a traffic plan to minimize community impacts because of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours.
Minimize obstruction of through- traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. (2) PEDESTRIAN TRAFFIC ON FRANK SINATRA DRIVE
I am very concerned about pedestrian traffic coming up Frank Sinatra Road. As you undoubtedly know, there are no sidewalks that frame Frank Sinatra Road from Highway 111 to the Ritz -Carlton. Despite the absence of sidewalks on that artery, presently there are numerous pedestrians that utilize the road itself to walk and down its length. These pedestrians are often hotel guests unfamiliar with the dangers that await them down the circuitous and steep decline of the road in that area. This foot traffic is guaranteed to increase with the construction of the Project since more residents/visitors will translate to more pedestrians along Frank Sinatra Drive. This increased pedestrian traffic will, then, predictably result in more injuries and accidents in this area. I do not believe that the City, nor the applicant for the Project, has properly analyzed, let alone address, this serious safety concern.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
To address this concern, it is urged that a protected pedestrian sidewalk be constructed on either side of Frank Sinatra Drive.
(3) CONSTRUCTION NOISE
The construction of this Project will take place over months and years. The construction phase then will introduce substantial noise, dust, debris, and general disruption into the surrounding area which threaten the tranquility and environmental quality that residents currently enjoy.
In correspondence addressing problems with the Project, dated January 9, 2025, the group "Californians Allied for a Responsible Economy" ("CARE"), noted that City's analysis underestimates construction noise impacts for the Project. In that letter (p. 2), CARE noted that "[d]ue to the proximity of residences to the Project site, construction and operational noise impacts would also be significant. Construction noise would increase ambient noise levels by over 20 decibels, which the City acknowledges would be a significant impact2.
The problems with construction noise were also extensively highlighted by the letter submitted by 28 -page letter from Mitchell M. Tsai law firm, submitted on behalf of the Western States Regional Council of Carpenters ("WSRCC"). In that letter (at p. 19-21), WSRCC focused on problems with the City's analysis of ambient noise problems with the Project and its utilization of improper data to analyze the noise problems at the Project:
Meanwhile, as I understand it, no noise measurements have been taken along the southern border of the two parcels on the Project site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 6308932-06- and 630893-208) which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area.
In spite of these facts, however, the FMND continues to inaccurately claim that " The long-term noise level measurements were positioned as close to 2 And during operations, stationary equipment like HVAC systems would exceed the 45 decibel nighttime noise standards at the nearby residences." CARE highlighted evidence (at p. 6) that the highest construction noise would be 69.9 dBA, the Final IS/MND elsewhere states that the composite source noise level at 50 feet varies between 76.2 and 84.4 dBA.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
the nearest sensitive receiver locations as possible to assess the existing ambient hourly noise levels surrounding the project site." (FMND at p. 145.) The City's continuing failure and refusal to update the Project's noise studies to address these deficiencies is glaring, and the City's responses to comments fail to address the lack of study of the ambient noise levels at positions closest to the Project's nearby sensitive receptors. (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, pp.
RTC -839 - 840.) The City cannot be permitted to shirk the performance of proper environmental analysis for the Project in order to conceal the Project's true impacts.
The FMND has then continued to utilize this faulty and incomplete ambient noise survey data to conclude that there will be no significant impact to the surrounding sensitive receptors from the Project's construction noise. The FMND adopted the Criteria for Recommended Standard: Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH) as the threshold for whether the anticipated construction noise from the Project will have a significant impact upon the Project nearby sensitive receptors. (FMND at p. 149.) The FMND then concludes that the threshold of 85 dBA Leq qualifies as an " acceptable threshold for construction noise at the nearby sensitive receiver locations," and the noise sensitive residential receiver locations will satisfy the 85 dBA Leq significance threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.) WSRCC reiterates that the NIOSH Occupational Noise Exposure standard has no proper place in evaluating the significance of construction noise impacts on nearby sensitive receptors. Rather, the NIOSH standard is aimed at protecting workers/laborers exposed to noise during the course job duties and preventing occupational harm/injury from occurring. It has no bearing upon external noise levels that would be suitable for maintaining the quiet enjoyment of an individual's private property. In that regard, the selection of 85 dBA Leq by the MND, RMND, and now the FMND as an acceptable threshold of significant construction noise impact is not only arbitrary, but it is also entirely unfounded.
The Federal Transit Administration's ("FTA") Transit Noise and Vibration Impact Assessment provides superior source of federal regulatory authority regarding a project's noise impacts and their significance on sensitive receptors. To that end, the FTA guidance on noise level impacts notes that the impacts should be assessed as a function of their increase over existing noise exposure, and that any noise increase of 15 dBA or greater for a residence is considered a " severe impact." (See Exhibit D-FTA Transit Noise and Vibration Impact Assessment, pp. 17-18, 23-31.) The MND/RMND/FMND arbitrarily elected to use the inapplicable NIOSH
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair argument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations ( L1, L2, and L3) still have the potential to exceed an FTA guidance - based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment. (FMND at p. 146, Table 13-2; compare FMND at p. 149, Table 13-3.) Indeed, comparison of the dBA values set forth in Table 12-3 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
One does not need to be a scientist schooled in the above to know that there will be a large amount of construction noise attendant to the construction of the Project that is deleterious to the environment of my community. Because construction noise will undoubtedly exceed a significant threshold, it must be mitigated in some reasonable manner.
Construction work on the Project is also to occur (is also exempt from provisions in the City's noise code), within allowable hours of 7 am to 7 pm (and is prohibited to occur on Sundays and holidays.) To address this concern, it is urged that the City restrict the hours of construction by limiting the window under which construction is permitted by allowing construction to begin at 8:00 am, and end at 6:00 pm.
(4) THE PROJECT'S BUILDINGS WILL OBSTRUCT THE VIEW OF RESIDENTS...
Finally, I am concerned about the Project because construction of proposed buildings will undoubtedly impact the views of numerous residents in my community. In particular, I am concerned about the view of residents of dwellings located at the north-east corner of Mirada Estates along Mirada Circle and Grand View Court. It does not appear that the City property analyzed the impact of the Project on the view of those homeowners. If indeed, those homeowner's view are negatively impacted, then the City, and the applicant for the Project, should (1) make those impacts clear; (2) if so negatively impacted, determine whether or not alternative exists that would allay those impacts/obstructed views.
CONCLUSION
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
I want to again make clear that I not opposed to the Project, only that portions of the Project, and its impacts, need to be addressed as set forth above. Due to the Project's potentially significant impact on the areas described above, I urge the City not to recommend approval of the Project until the problems and impacts outlined above are properly addressed and are fully mitigated.
Sincerely,
CC: Isaiah Hagerman, City Manager ([email protected])
December 9, 2025
Via Email & U.S. Mail
Mayor Lynn Mallotto ([email protected])
City of Rancho Mirage
69-825 California Highway 111
Rancho Mirage, CA 92270
RE: Ritz Carlton Rancho Mirage - Environmental Assessment Case No. EA21- 0002, General Plan Zoning Map Amendment Case No. GPZMA21-0001, Development Agreement Amendment Case No. DA21-0002, Mayor Modification Case No. MOD21-0004, & Tentative Parcel Map Case Number TPM23-0002 (TPM38768).
Dear Mayor Lynn Mallotto:
I have been a resident for the past six years at the Mirada Estates (and Mirada Villas) community. Mirada Estates, also known as "The Mountain Sanctuary," is located in the Santa Rosa Mountains and is adjacent to the Ritz Carlton Resort. Our neighborhood is a small enclave of custom homes built by owners and developers and was inspired by the natural beauty of 272,000 acres of surrounding pristine wilderness. The residents of my community have selected this neighborhood because of the solitude that exists in our area.
This prized solitude is the one of chief reasons, among others, that I write this letter concerning problems with the below project that that is proposed in the City of Rancho Mirage ("City").
A. The Proposed Project.
I am writing to you concerning the proposed development project at the Ritz -Carlton Rancho Mirage. The proposed project involves construction described as the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.3 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 ("Project"). The Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/ commercial space, and approximately 5,510 -square feet of amenity space.
The overall Project site includes an existing hotel that opened as a Ritz -Carlton in 1988.
The Project would also provide a total of 499 vehicle parking spaces.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
As part of the proposed Project, the developer requested a General Plan Zoning Map Amendment to amend the City's Mountain Reserve (MR) designation for the Project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres.
B. The City's Analysis of the Project.
In March 2024, the City released the first Initial study result of the Project. That study resulted in a recommendation to adopt a Mitigated Negative Declaration (MND) for the Project. In July 2024, the City released a Recirculated Initial Study / Mitigated Negative Declaration ("RMND") for the Project. Thereafter, the City issued its December 2024 Final Initial Study / Mitigated Negative Declaration ("FMND") for the Project.
C. Planning Commission Approval of Project.
On January 9, 2025, as party of the proposed Project, the City's Planning Commission considered the following requests from the developer of the Project:
(1) General Plan Zoning Map Amendment to amend the Mountain Reserve (MR) designation for the project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres (APNs: 689-020-012 & 689-020-014). (2) A Tentative Parcel Map (TPM38768) to establish three parcels (excluding Sky Mesa area) with Parcel 3 of the map containing condo units (Ritz Carlton residences).
(3) Lastly, a 10th Amendment to the existing Development Agreement with Newage Rancho Mirage, LLC (the "10th Amendment") is proposed. Please note that the proposed project (excluding Sky Mesa) is a modification to the originally approved 2006 project entitlements that included residential villas and condominiums.
It is my understanding that the City's Planning Commission previously voted on January 9, 2025, to recommend that this Project move forward and approved the following resolutions and actions:
(1) A resolution approving the mitigation monitoring and reporting program and mitigated negative declaration (sch# 2024030267) for the Project based on environmental assessment case no. EA21- 0002.
(2) A resolution approving general plan zoning map amendment (GPZMA21- 0001), tentative parcel map case no.TPM23- 0002, and major modification case no.
MOD21- 0004.
(3) And ordinance approving development agreement amendment (DA21-0002).
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
D. Problems with the Project.
I am concerned that the City's Planning Commission has approved this Project without addressing numerous problems that will arise with the Project. Before I address those problems, I want to make it abundantly clear that I am not opposed the Project. The Ritz - Carlton has been a wonderful neighbor. I am not opposed to principal of development at all. However, there are a number of issues that I think the City, and the developer, need to address concerning the Project before it proceeds and that is the purpose of this letter.
The proposed Project will significantly impact my neighborhood. In particular, I am deeply concerned about the environmental and infrastructural impacts this Project may have on our neighborhood. I am concerned about this Project moving forward in the follow areas:
(1) Construction phase of the Project and impact on Frank Sinatra Drive; (2) Pedestrian traffic on Frank Sinatra Drive; and
(3) Construction noise; and,
(4) The Project buildings will obstruct resident's views.
I will address each of these points further below.
(1) CONSTRUCTION PHASE OF THE PROJECT AND IMPACT ON FRANK
SINATRA DRIVE
One of the primary problems with the Project will be the increased construction activity that will arise as a result of the construction necessary to bring about this enormous Project into fruition. Since Frank Sinatra Drive will be the main arterial for construction traffic into the Project, traffic will be enormously and negatively impacted in that area. This construction traffic will impact my neighborhood greatly since the visitor numbers are likely to significantly affect ingress and egress via Frank Sinatra Drive'. The chief entry point to the Project will be Frank Sinatra Drive. As this street is shared by both the existing Ritz - Carlton, and my neighborhood, this additional stress on that artery would overload its capabilities. This thoroughfare is crucial for daily commutes and, more importantly, for emergency vehicle access. Many of the residents in my community are elderly and rely on prompt emergency services. Obstructions or delays on this route could have serious consequences.
To address the above concerns, I would propose that the paved service road located behind the Ritz -Carlton be expanded and utilized for all construction -related activities. It is unused currently, and leads directly to the area where the planned Project will be built.
This would include the transportation of heavy equipment, steel girders, concrete, Frank Sinatra drive is an east west major collector running through the City. Most of Frank Sinatra drive is constructed to its ultimate design standards with 100 foot right of way. However, Frank Sinatra drive, West of Hwy 111, is designed as a two-lane roadway in the general plan.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
materials, and construction personnel. By diverting construction traffic away from Frank Sinatra Drive, construction on the Project can proceed but residents and emergency vehicles can retain uninterrupted access to our community. Additionally, this proposed solution would help to minimize noise, dust, and debris in residential areas, preserving the peaceful environment we value. Finally, this solution would decrease the risk of accidents or delays associated with increased traffic on Frank Sinatra Drive.
There are additionally other means to address the above concerns as follows:
• Minimize unnecessary vehicular and machinery activities.
Require contractors to assemble a comprehensive inventory list (i.e., make, model, engine year, horsepower, emission rates) of all heavy-duty off -road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. • Ensure all construction equipment is properly tuned and maintained • Minimizing idling time to 5 minutes or beyond regulatory requirements — saves fuel and reduces emissions.
• Develop a traffic plan to minimize community impacts because of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours.
Minimize obstruction of through- traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. (2) PEDESTRIAN TRAFFIC ON FRANK SINATRA DRIVE
I am very concerned about pedestrian traffic coming up Frank Sinatra Road. As you undoubtedly know, there are no sidewalks that frame Frank Sinatra Road from Highway 111 to the Ritz -Carlton. Despite the absence of sidewalks on that artery, presently there are numerous pedestrians that utilize the road itself to walk and down its length. These pedestrians are often hotel guests unfamiliar with the dangers that await them down the circuitous and steep decline of the road in that area. This foot traffic is guaranteed to increase with the construction of the Project since more residents/visitors will translate to more pedestrians along Frank Sinatra Drive. This increased pedestrian traffic will, then, predictably result in more injuries and accidents in this area. I do not believe that the City, nor the applicant for the Project, has properly analyzed, let alone address, this serious safety concern.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
To address this concern, it is urged that a protected pedestrian sidewalk be constructed on either side of Frank Sinatra Drive.
(3) CONSTRUCTION NOISE
The construction of this Project will take place over months and years. The construction phase then will introduce substantial noise, dust, debris, and general disruption into the surrounding area which threaten the tranquility and environmental quality that residents currently enjoy.
In correspondence addressing problems with the Project, dated January 9, 2025, the group "Californians Allied for a Responsible Economy" ("CARE"), noted that City's analysis underestimates construction noise impacts for the Project. In that letter (p. 2), CARE noted that "[d]ue to the proximity of residences to the Project site, construction and operational noise impacts would also be significant. Construction noise would increase ambient noise levels by over 20 decibels, which the City acknowledges would be a significant impact2.
The problems with construction noise were also extensively highlighted by the letter submitted by 28 -page letter from Mitchell M. Tsai law firm, submitted on behalf of the Western States Regional Council of Carpenters ("WSRCC"). In that letter (at p. 19-21), WSRCC focused on problems with the City's analysis of ambient noise problems with the Project and its utilization of improper data to analyze the noise problems at the Project:
Meanwhile, as I understand it, no noise measurements have been taken along the southern border of the two parcels on the Project site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 6308932-06- and 630893-208) which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area.
In spite of these facts, however, the FMND continues to inaccurately claim that " The Tong -term noise level measurements were positioned as close to 2 And during operations, stationary equipment like HVAC systems would exceed the 45 decibel nighttime noise standards at the nearby residences." CARE highlighted evidence (at p. 6) that the highest construction noise would be 69.9 dBA, the Final IS/MND elsewhere states that the composite source noise level at 50 feet varies between 76.2 and 84.4 dBA.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
the nearest sensitive receiver locations as possible to assess the existing ambient hourly noise levels surrounding the project site." (FMND at p. 145.) The City's continuing failure and refusal to update the Project's noise studies to address these deficiencies is glaring, and the City's responses to comments fail to address the lack of study of the ambient noise levels at positions closest to the Project's nearby sensitive receptors. (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, pp.
RTC -839 - 840.) The City cannot be permitted to shirk the performance of proper environmental analysis for the Project in order to conceal the Project's true impacts.
The FMND has then continued to utilize this faulty and incomplete ambient noise survey data to conclude that there will be no significant impact to the surrounding sensitive receptors from the Project's construction noise. The FMND adopted the Criteria for Recommended Standard: Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH) as the threshold for whether the anticipated construction noise from the Project will have a significant impact upon the Project nearby sensitive receptors. (FMND at p. 149.) The FMND then concludes that the threshold of 85 dBA Leq qualifies as an " acceptable threshold for construction noise at the nearby sensitive receiver locations," and the noise sensitive residential receiver locations will satisfy the 85 dBA Leq significance threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.) WSRCC reiterates that the NIOSH Occupational Noise Exposure standard has no proper place in evaluating the significance of construction noise impacts on nearby sensitive receptors. Rather, the NIOSH standard is aimed at protecting workers/laborers exposed to noise during the course job duties and preventing occupational harm/injury from occurring. It has no bearing upon external noise levels that would be suitable for maintaining the quiet enjoyment of an individual's private property. In that regard, the selection of 85 dBA Leq by the MND, RMND, and now the FMND as an acceptable threshold of significant construction noise impact is not only arbitrary, but it is also entirely unfounded.
The Federal Transit Administration's ("FTA") Transit Noise and Vibration Impact Assessment provides superior source of federal regulatory authority regarding a project's noise impacts and their significance on sensitive receptors. To that end, the FTA guidance on noise level impacts notes that the impacts should be assessed as a function of their increase over existing noise exposure, and that any noise increase of 15 dBA or greater for a residence is considered a " severe impact." (See Exhibit D-FTA Transit Noise and Vibration Impact Assessment, pp. 17-18, 23-31.) The MND/RMND/FMND arbitrarily elected to use the inapplicable NIOSH
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair argument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations ( L1, L2, and L3) still have the potential to exceed an FTA guidance - based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment. (FMND at p. 146, Table 13-2; compare FMND at p. 149, Table 13-3.) Indeed, comparison of the dBA values set forth in Table 12-3 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
One does not need to be a scientist schooled in the above to know that there will be a large amount of construction noise attendant to the construction of the Project that is deleterious to the environment of my community. Because construction noise will undoubtedly exceed a significant threshold, it must be mitigated in some reasonable manner.
Construction work on the Project is also to occur (is also exempt from provisions in the City's noise code), within allowable hours of 7 am to 7 pm (and is prohibited to occur on Sundays and holidays.) To address this concern, it is urged that the City restrict the hours of construction by limiting the window under which construction is permitted by allowing construction to begin at 8:00 am, and end at 6:00 pm.
(4) THE PROJECT'S BUILDINGS WILL OBSTRUCT THE VIEW OF RESIDENTS...
Finally, I am concerned about the Project because construction of proposed buildings will undoubtedly impact the views of numerous residents in my community. In particular, I am concerned about the view of residents of dwellings located at the north-east corner of Mirada Estates along Mirada Circle and Grand View Court. It does not appear that the City property analyzed the impact of the Project on the view of those homeowners. If indeed, those homeowner's view are negatively impacted, then the City, and the applicant for the Project, should (1) make those impacts clear; (2) if so negatively impacted, determine whether or not alternative exists that would allay those impacts/obstructed views.
CONCLUSION
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
I want to again make clear that I not opposed to the Project, only that portions of the Project, and its impacts, need to be addressed as set forth above. Due to the Project's potentially significant impact on the areas described above, I urge the City not to recommend approval of the Project until the problems and impacts outlined above are properly addressed and are fully mitigated.
Sincerely,
CC: Isaiah Hagerman, City Manager ([email protected]) Leslie Cooper
26 Grande View Court
Rancho Mirage, Ca 92270
December 9, 2025
Via Email & U.S. Mail
Mayor Lynn Mallotto ([email protected])
City of Rancho Mirage
69-825 California Highway 111
Rancho Mirage, CA 92270
RE: Ritz Carlton Rancho Mirage - Environmental Assessment Case No. EA21- 0002, General Plan Zoning Map Amendment Case No. GPZMA21-0001, Development Agreement Amendment Case No. DA21-0002, Ma'or Modification Case No. MOD21-0004, & Tentative Parcel Map Case Number TPM23-0002 (TPM38768).
Dear Mayor Lynn Mallotto:
I have been a resident for the past years at the Mirada Estates (and Mirada Villas) community. Mirada Estates, also known as "The Mountain Sanctuary," is located in the Santa Rosa Mountains and is adjacent to the Ritz Carlton Resort. Our neighborhood is a small enclave of custom homes built by owners and developers and was inspired by the natural beauty of 272,000 acres of surrounding pristine wilderness. The residents of my community have selected this neighborhood because of the solitude that exists in our area.
This prized solitude is the one of chief reasons, among others, that I write this letter concerning problems with the below project that that is proposed in the City of Rancho Mirage ("City").
A. The Proposed Project.
I am writing to you concerning the proposed development project at the Ritz -Carlton Rancho Mirage. The proposed project involves construction described as the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.3 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 ("Project"). The Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/ commercial space, and approximately 5,510 -square feet of amenity space.
The overall Project site includes an existing hotel that opened as a Ritz -Carlton in 1988.
The Project would also provide a total of 499 vehicle parking spaces.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
As part of the proposed Project, the developer requested a General Plan Zoning Map Amendment to amend the City's Mountain Reserve (MR) designation for the Project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres.
B. The City's Analysis of the Project.
In March 2024, the City released the first Initial study result of the Project. That study resulted in a recommendation to adopt a Mitigated Negative Declaration (MND) for the Project. In July 2024, the City released a Recirculated Initial Study / Mitigated Negative Declaration ("RMND") for the Project. Thereafter, the City issued its December 2024 Final Initial Study / Mitigated Negative Declaration ("FMND") for the Project.
C. Planning Commission Approval of Project.
On January 9, 2025, as party of the proposed Project, the City's Planning Commission considered the following requests from the developer of the Project:
(1) General Plan Zoning Map Amendment to amend the Mountain Reserve (MR) designation for the project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres (APNs: 689-020-012 & 689-020-014). (2) A Tentative Parcel Map (TPM38768) to establish three parcels (excluding Sky Mesa area) with Parcel 3 of the map containing condo units (Ritz Carlton residences).
(3) Lastly, a 10th Amendment to the existing Development Agreement with Newage Rancho Mirage, LLC (the "10th Amendment") is proposed. Please note that the proposed project (excluding Sky Mesa) is a modification to the originally approved 2006 project entitlements that included residential villas and condominiums.
It is my understanding that the City's Planning Commission previously voted on January 9, 2025, to recommend that this Project move forward and approved the following resolutions and actions:
(1) A resolution approving the mitigation monitoring and reporting program and mitigated negative declaration (sch# 2024030267) for the Project based on environmental assessment case no. EA21- 0002.
(2) A resolution approving general plan zoning map amendment (GPZMA21- 0001), tentative parcel map case no.TPM23- 0002, and major modification case no.
MOD21- 0004.
(3) And ordinance approving development agreement amendment (DA21-0002).
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
D. Problems with the Project.
I am concerned that the City's Planning Commission has approved this Project without addressing numerous problems that will arise with the Project. Before I address those problems, I want to make it abundantly clear that I am not opposed the Project. The Ritz - Carlton has been a wonderful neighbor. I am not opposed to principal of development at all. However, there are a number of issues that I think the City, and the developer, need to address concerning the Project before it proceeds and that is the purpose of this letter.
The proposed Project will significantly impact my neighborhood. In particular, I am deeply concerned about the environmental and infrastructural impacts this Project may have on our neighborhood. I am concerned about this Project moving forward in the follow areas:
(1) Construction phase of the Project and impact on Frank Sinatra Drive; (2) Pedestrian traffic on Frank Sinatra Drive; and
(3) Construction noise; and,
(4) The Project buildings will obstruct resident's views.
I will address each of these points further below.
(1) CONSTRUCTION PHASE OF THE PROJECT AND IMPACT ON FRANK
SINATRA DRIVE
One of the primary problems with the Project will be the increased construction activity that will arise as a result of the construction necessary to bring about this enormous Project into fruition. Since Frank Sinatra Drive will be the main arterial for construction traffic into the Project, traffic will be enormously and negatively impacted in that area. This construction traffic will impact my neighborhood greatly since the visitor numbers are likely to significantly affect ingress and egress via Frank Sinatra Drive'. The chief entry point to the Project will be Frank Sinatra Drive. As this street is shared by both the existing Ritz - Carlton, and my neighborhood, this additional stress on that artery would overload its capabilities. This thoroughfare is crucial for daily commutes and, more importantly, for emergency vehicle access. Many of the residents in my community are elderly and rely on prompt emergency services. Obstructions or delays on this route could have serious consequences.
To address the above concerns, I would propose that the paved service road located behind the Ritz -Carlton be expanded and utilized for all construction -related activities. It is unused currently, and leads directly to the area where the planned Project will be built.
This would include the transportation of heavy equipment, steel girders, concrete, Frank Sinatra drive is an east west major collector running through the City. Most of Frank Sinatra drive is constructed to its ultimate design standards with 100 foot right of way. However, Frank Sinatra drive, West of Hwy 111, is designed as a two-lane roadway in the general plan.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
materials, and construction personnel. By diverting construction traffic away from Frank Sinatra Drive, construction on the Project can proceed but residents and emergency vehicles can retain uninterrupted access to our community. Additionally, this proposed solution would help to minimize noise, dust, and debris in residential areas, preserving the peaceful environment we value. Finally, this solution would decrease the risk of accidents or delays associated with increased traffic on Frank Sinatra Drive.
There are additionally other means to address the above concerns as follows:
• Minimize unnecessary vehicular and machinery activities.
Require contractors to assemble a comprehensive inventory list (Le., make, model, engine year, horsepower, emission rates) of all heavy-duty off -road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. • Ensure all construction equipment is properly tuned and maintained • Minimizing idling time to 5 minutes or beyond regulatory requirements — saves fuel and reduces emissions.
• Develop a traffic plan to minimize community impacts because of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours.
Minimize obstruction of through- traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. (2) PEDESTRIAN TRAFFIC ON FRANK SINATRA DRIVE
I am very concerned about pedestrian traffic coming up Frank Sinatra Road. As you undoubtedly know, there are no sidewalks that frame Frank Sinatra Road from Highway 111 to the Ritz -Carlton. Despite the absence of sidewalks on that artery, presently there are numerous pedestrians that utilize the road itself to walk and down its length. These pedestrians are often hotel guests unfamiliar with the dangers that await them down the circuitous and steep decline of the road in that area. This foot traffic is guaranteed to increase with the construction of the Project since more residents/visitors will translate to more pedestrians along Frank Sinatra Drive. This increased pedestrian traffic will, then, predictably result in more injuries and accidents in this area. I do not believe that the City, nor the applicant for the Project, has properly analyzed, let alone address, this serious safety concern.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
To address this concern, it is urged that a protected pedestrian sidewalk be constructed on either side of Frank Sinatra Drive.
(3) CONSTRUCTION NOISE
The construction of this Project will take place over months and years. The construction phase then will introduce substantial noise, dust, debris, and general disruption into the surrounding area which threaten the tranquility and environmental quality that residents currently enjoy.
In correspondence addressing problems with the Project, dated January 9, 2025, the group "Californians Allied for a Responsible Economy" ("CARE"), noted that City's analysis underestimates construction noise impacts for the Project. In that letter (p. 2), CARE noted that "[d]ue to the proximity of residences to the Project site, construction and operational noise impacts would also be significant. Construction noise would increase ambient noise levels by over 20 decibels, which the City acknowledges would be a significant impact2.
The problems with construction noise were also extensively highlighted by the letter submitted by 28 -page letter from Mitchell M. Tsai law firm, submitted on behalf of the Western States Regional Council of Carpenters ("WSRCC"). In that letter (at p. 19-21), WSRCC focused on problems with the City's analysis of ambient noise problems with the Project and its utilization of improper data to analyze the noise problems at the Project:
Meanwhile, as I understand it, no noise measurements have been taken along the southern border of the two parcels on the Project site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 6308932-06- and 630893-208) which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area.
In spite of these facts, however, the FMND continues to inaccurately claim that " The long-term noise level measurements were positioned as close to 2 And during operations, stationary equipment Tike HVAC systems would exceed the 45 decibel nighttime noise standards at the nearby residences." CARE highlighted evidence (at p. 6) that the highest construction noise would be 69.9 dBA, the Final IS/MND elsewhere states that the composite source noise level at 50 feet varies between 76.2 and 84.4 dBA.
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
the nearest sensitive receiver locations as possible to assess the existing ambient hourly noise levels surrounding the project site." (FMND at p. 145.) The City's continuing failure and refusal to update the Project's noise studies to address these deficiencies is glaring, and the City's responses to comments fail to address the lack of study of the ambient noise levels at positions closest to the Project's nearby sensitive receptors. (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, pp.
RTC -839 - 840.) The City cannot be permitted to shirk the performance of proper environmental analysis for the Project in order to conceal the Project's true impacts.
The FMND has then continued to utilize this faulty and incomplete ambient noise survey data to conclude that there will be no significant impact to the surrounding sensitive receptors from the Project's construction noise. The FMND adopted the Criteria for Recommended Standard: Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH) as the threshold for whether the anticipated construction noise from the Project will have a significant impact upon the Project nearby sensitive receptors. (FMND at p. 149.) The FMND then concludes that the threshold of 85 dBA Leq qualifies as an " acceptable threshold for construction noise at the nearby sensitive receiver locations," and the noise sensitive residential receiver locations will satisfy the 85 dBA Leq significance threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.) WSRCC reiterates that the NIOSH Occupational Noise Exposure standard has no proper place in evaluating the significance of construction noise impacts on nearby sensitive receptors. Rather, the NIOSH standard is aimed at protecting workers/laborers exposed to noise during the course job duties and preventing occupational harm/injury from occurring. It has no bearing upon external noise levels that would be suitable for maintaining the quiet enjoyment of an individual's private property. In that regard, the selection of 85 dBA Leq by the MND, RMND, and now the FMND as an acceptable threshold of significant construction noise impact is not only arbitrary, but it is also entirely unfounded.
The Federal Transit Administration's ("FTA") Transit Noise and Vibration Impact Assessment provides superior source of federal regulatory authority regarding a project's noise impacts and their significance on sensitive receptors. To that end, the FTA guidance on noise level impacts notes that the impacts should be assessed as a function of their increase over existing noise exposure, and that any noise increase of 15 dBA or greater for a residence is considered a " severe impact." (See Exhibit D-FTA Transit Noise and Vibration Impact Assessment, pp. 17-18, 23-31.) The MND/RMND/FMND arbitrarily elected to use the inapplicable NIOSH
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair argument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations ( L1, L2, and L3) still have the potential to exceed an FTA guidance - based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment. (FMND at p. 146, Table 13-2; compare FMND at p. 149, Table 13-3.) Indeed, comparison of the dBA values set forth in Table 12-3 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
One does not need to be a scientist schooled in the above to know that there will be a large amount of construction noise attendant to the construction of the Project that is deleterious to the environment of my community. Because construction noise will undoubtedly exceed a significant threshold, it must be mitigated in some reasonable manner.
Construction work on the Project is also to occur (is also exempt from provisions in the City's noise code), within allowable hours of 7 am to 7 pm (and is prohibited to occur on Sundays and holidays.) To address this concern, it is urged that the City restrict the hours of construction by limiting the window under which construction is permitted by allowing construction to begin at 8:00 am, and end at 6:00 pm.
(4) THE PROJECT'S BUILDINGS WILL OBSTRUCT THE VIEW OF RESIDENTS...
Finally, I am concerned about the Project because construction of proposed buildings will undoubtedly impact the views of numerous residents in my community. In particular, I am concerned about the view of residents of dwellings located at the north-east corner of Mirada Estates along Mirada Circle and Grand View Court. It does not appear that the City property analyzed the impact of the Project on the view of those homeowners. If indeed, those homeowner's view are negatively impacted, then the City, and the applicant for the Project, should (1) make those impacts clear; (2) if so negatively impacted, determine whether or not alternative exists that would allay those impacts/obstructed views.
CONCLUSION
Mayor Weill and Honorable Members of the City Council
City of Rancho Mirage
I want to again make clear that I not opposed to the Project, only that portions of the Project, and its impacts, need to be addressed as set forth above. Due to the Project's potentially significant impact on the areas described above, I urge the City not to recommend approval of the Project until the problems and impacts outlined above are properly addressed and are fully mitigated.
Sincerely,
L$ iL RbsiQx6 GR,v-A-�
A'-#(
CC: Isaiah Hagerman, City Manager ([email protected])
December 9, 2025
Via Email & U.S. Mail
Councilmember Ted Weill ([email protected])
City of Rancho Mirage
69-825 California Highway 111
Rancho Mirage, CA 92270
RE: Ritz Carlton Rancho Mirage - Environmental Assessment Case No. EA21- 0002, General Plan Zoning Map Amendment Case No. GPZMA21-0001, Development Agreement Amendment Case No. DA21-0002, Ma'or Modification Case No. MOD21-0004, & Tentative Parcel Map Case Number TPM23-0002 (TPM38768).
Dear City Council Member, Ted Weil:
I am a resident at the Mirada Estates community. Mirada Estates, also known as "The Mountain Sanctuary," is located in the Santa Rosa Mountains and is adjacent to the Ritz Carlton Resort. Our neighborhood is a small enclave of custom homes built by owners and developers and was inspired by the natural beauty of 272,000 acres of surrounding pristine wilderness. The residents of my community have selected this neighborhood because of the solitude that exists in our area. This prized solitude is the one of chief reasons, among others, that I write this letter concerning problems with the below project that that is proposed in the City of Rancho Mirage ("City").
A. The Proposed Project.
I am writing to you concerning the proposed development project at the Ritz -Carlton Rancho Mirage. The proposed project involves construction described as the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.3 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 ("Project"). The Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/ commercial space, and approximately 5,510 -square feet of amenity space.
The overall Project site includes an existing hotel that opened as a Ritz -Carlton in 1988.
The Project would also provide a total of 499 vehicle parking spaces.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
As part of the proposed Project, the developer requested a General Plan Zoning Map Amendment to amend the City's Mountain Reserve (MR) designation for the Project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres.
B. The City's Analysis of the Project.
In March 2024, the City released the first Initial study result of the Project. That study resulted in a recommendation to adopt a Mitigated Negative Declaration (MND) for the Project. In July 2024, the City released a Recirculated Initial Study / Mitigated Negative Declaration ("RMND") for the Project. Thereafter, the City issued its December 2024 Final Initial Study / Mitigated Negative Declaration ("FMND") for the Project.
C. Planninc Commission Approval of Project.
On January 9, 2025, as party of the proposed Project, the City's Planning Commission considered the following requests from the developer of the Project:
(1) General Plan Zoning Map Amendment to amend the Mountain Reserve (MR) designation for the project's Sky Mesa Recreational area to Resort Hotel (Rs -H) on approximately 3.88 acres (APNs: 689-020-012 & 689-020-014). (2) A Tentative Parcel Map (TPM38768) to establish three parcels (excluding Sky Mesa area) with Parcel 3 of the map containing condo units (Ritz Carlton residences).
(3) Lastly, a 10th Amendment to the existing Development Agreement with Newage Rancho Mirage, LLC (the "10th Amendment") is proposed. Please note that the proposed project (excluding Sky Mesa) is a modification to the originally approved 2006 project entitlements that included residential villas and condominiums.
It is my understanding that the City's Planning Commission previously voted on January 9, 2025, to recommend that this Project move forward and approved the following resolutions and actions:
(1) A resolution approving the mitigation monitoring and reporting program and mitigated negative declaration (sch# 2024030267) for the Project based on environmental assessment case no. EA21- 0002.
(2) A resolution approving general plan zoning map amendment (GPZMA21- 0001), tentative parcel map case no.TPM23- 0002, and major modification case no.
MOD21- 0004.
(3) And ordinance approving development agreement amendment (DA21-0002).
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
D. Problems with the Project.
I am concerned that the City's Planning Commission has approved this Project without addressing numerous problems that will arise with the Project. Before I address those problems, I want to make it abundantly clear that I am not opposed the Project. The Ritz - Carlton has been a wonderful neighbor. I am not opposed to principal of development at all. However, there are a number of issues that I think the City, and the developer, need to address concerning the Project before it proceeds and that is the purpose of this letter.
The proposed Project will significantly impact my neighborhood. In particular, I am deeply concerned about the environmental and infrastructural impacts this Project may have on our neighborhood. I am concerned about this Project moving forward in the follow areas:
(1) Construction phase of the Project and impact on Frank Sinatra Drive; (2) Pedestrian traffic on Frank Sinatra Drive; and
(3) Construction noise; and,
(4) The Project buildings will obstruct resident's views.
I will address each of these points further below.
(1) CONSTRUCTION PHASE OF THE PROJECT AND IMPACT ON FRANK
SINATRA DRIVE
One of the primary problems with the Project will be the increased construction activity that will arise as a result of the construction necessary to bring about this enormous Project into fruition. Since Frank Sinatra Drive will be the main arterial for construction traffic into the Project, traffic will be enormously and negatively impacted in that area. This construction traffic will impact my neighborhood greatly since the visitor numbers are likely to significantly affect ingress and egress via Frank Sinatra Drive'. The chief entry point to the Project will be Frank Sinatra Drive. As this street is shared by both the existing Ritz - Carlton, and my neighborhood, this additional stress on that artery would overload its capabilities. This thoroughfare is crucial for daily commutes and, more importantly, for emergency vehicle access. Many of the residents in my community are elderly and rely on prompt emergency services. Obstructions or delays on this route could have serious consequences.
To address the above concerns, I would propose that the paved service road located behind the Ritz -Carlton be expanded and utilized for all construction -related activities. It is unused currently, and leads directly to the area where the planned Project will be built.
This would include the transportation of heavy equipment, steel girders, concrete, ' Frank Sinatra drive is an east west major collector running through the City. Most of Frank Sinatra drive is constructed to its ultimate design standards with 100 foot right of way. However, Frank Sinatra drive, West of Hwy 111, is designed as a two-lane roadway in the general plan.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
materials, and construction personnel. By diverting construction traffic away from Frank Sinatra Drive, construction on the Project can proceed but residents and emergency vehicles can retain uninterrupted access to our community. Additionally, this proposed solution would help to minimize noise, dust, and debris in residential areas, preserving the peaceful environment we value. Finally, this solution would decrease the risk of accidents or delays associated with increased traffic on Frank Sinatra Drive.
There are additionally other means to address the above concerns as follows:
• Minimize unnecessary vehicular and machinery activities.
Require contractors to assemble a comprehensive inventory list (Le., make, model, engine year, horsepower, emission rates) of all heavy-duty off -road (portable and mobile) equipment (50 horsepower and greater) that could be used an aggregate of 40 or more hours for the construction project. • Ensure all construction equipment is properly tuned and maintained • Minimizing idling time to 5 minutes or beyond regulatory requirements — saves fuel and reduces emissions.
• Develop a traffic plan to minimize community impacts because of traffic flow interference from construction activities. The plan may include advance public notice of routing, use of public transportation, and satellite parking areas with a shuttle service. Schedule operations affecting traffic for off-peak hours.
Minimize obstruction of through- traffic lanes. Provide a flag person to guide traffic properly and ensure safety at construction sites. Project sponsors should consider developing a goal for the minimization of community impacts. (2) PEDESTRIAN TRAFFIC ON FRANK SINATRA DRIVE
I am very concerned about pedestrian traffic coming up Frank Sinatra Road. As you undoubtedly know, there are no sidewalks that frame Frank Sinatra Road from Highway 111 to the Ritz -Carlton. Despite the absence of sidewalks on that artery, presently there are numerous pedestrians that utilize the road itself to walk and down its length. These pedestrians are often hotel guests unfamiliar with the dangers that await them down the circuitous and steep decline of the road in that area. This foot traffic is guaranteed to increase with the construction of the Project since more residents/visitors will translate to more pedestrians along Frank Sinatra Drive. This increased pedestrian traffic will, then, predictably result in more injuries and accidents in this area. I do not believe that the City, nor the applicant for the Project, has properly analyzed, let alone address, this serious safety concern.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
To address this concern, it is urged that a protected pedestrian sidewalk be constructed on either side of Frank Sinatra Drive.
(3) CONSTRUCTION NOISE
The construction of this Project will take place over months and years. The construction phase then will introduce substantial noise, dust, debris, and general disruption into the surrounding area which threaten the tranquility and environmental quality that residents currently enjoy.
In correspondence addressing problems with the Project, dated January 9, 2025, the group "Californians Allied for a Responsible Economy" ("CARE"), noted that City's analysis underestimates construction noise impacts for the Project. In that letter (p. 2), CARE noted that "[d]ue to the proximity of residences to the Project site, construction and operational noise impacts would also be significant. Construction noise would increase ambient noise levels by over 20 decibels, which the City acknowledges would be a significant impact2.
The problems with construction noise were also extensively highlighted by the letter submitted by 28 -page letter from Mitchell M. Tsai law firm, submitted on behalf of the Western States Regional Council of Carpenters ("WSRCC"). In that letter (at p. 19-21), WSRCC focused on problems with the City's analysis of ambient noise problems with the Project and its utilization of improper data to analyze the noise problems at the Project:
Meanwhile, as I understand it, no noise measurements have been taken along the southern border of the two parcels on the Project site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 6308932-06- and 630893-208) which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area.
In spite of these facts, however, the FMND continues to inaccurately claim that " The Tong -term noise level measurements were positioned as close to 2 And during operations, stationary equipment Tike HVAC systems would exceed the 45 decibel nighttime noise standards at the nearby residences." CARE highlighted evidence (at p. 6) that the highest construction noise would be 69.9 dBA, the Final IS/MND elsewhere states that the composite source noise level at 50 feet varies between 76.2 and 84.4 dBA.
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair argument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations ( L1, L2, and L3) still have the potential to exceed an FTA guidance - based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment. (FMND at p. 146, Table 13-2; compare FMND at p. 149, Table 13-3.) Indeed, comparison of the dBA values set forth in Table 12-3 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
One does not need to be a scientist schooled in the above to know that there will be a large amount of construction noise attendant to the construction of the Project that is deleterious to the environment of my community. Because construction noise will undoubtedly exceed a significant threshold, it must be mitigated in some reasonable manner.
Construction work on the Project is also to occur (is also exempt from provisions in the City's noise code), within allowable hours of 7 am to 7 pm (and is prohibited to occur on Sundays and holidays.) To address this concern, it is urged that the City restrict the hours of construction by limiting the window under which construction is permitted by allowing construction to begin at 8:00 am, and end at 6:00 pm.
(4) THE PROJECT'S BUILDINGS WILL OBSTRUCT THE VIEW OF RESIDENTS...
Finally, I am concerned about the Project because construction of proposed buildings will undoubtedly impact the views of numerous residents in my community. In particular, I am concerned about the view of residents of dwellings located at the north-east corner of Mirada Estates along Mirada Circle and Grand View Court. It does not appear that the City property analyzed the impact of the Project on the view of those homeowners. If indeed, those homeowner's view are negatively impacted, then the City, and the applicant for the Project, should (1) make those impacts clear; (2) if so negatively impacted, determine whether or not alternative exists that would allay those impacts/obstructed views.
CONCLUSION
Mayor Mallotto and Honorable Members of the City Council City of Rancho Mirage
I want to again make clear that I not opposed to the Project, only that portions of the Project, and its impacts, need to be addressed as set forth above. Due to the Project's potentially significant impact on the areas described above, I urge the City not to recommend approval of the Project until the problems and impacts outlined above are properly addressed and are fully mitigated.
laliolZj
CC: Isaiah Hagerman, City Manager ([email protected])
From:
To:
Cc:
Subject:
Date:
Nabil Ali
City Clerk
Planning Division
Public Hearing Notice
Wednesday, December 17, 2025 9:14:41 PM
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Dear Councilmembers
Thank you for giving us the opportunity to express our thoughts regarding the announcement we received from you about the new condominium project. We are residents of Villas at Mirada and have a great concern with this additional community.
Apart from adding congestion to the area, the Frank Sinatra access to all of these communities is not adequate and cannot handle the traffic in standard urban planning. Not to mention, the safety and risk during a natural disaster(such as earthquake, fire, etc.). Unfortunately, we experienced it first hand with our Pacific Palisades home.
We respectfully ask the City Council to reconsider this project and add an additional access road dedicated for that community; thus redirecting the traffic this new project will bring into the area.
Regards,
Nabil Ali & Jeff Volkman
18 Santa Rosa Mountain Lane
Rancho Mirage, Ca. 92270
From:
To:
Subject:
Date:
Brad Anderson
City Clerk
Public Comment - City of Rancho Mirage Council meeting of December 18, 2025 (1:PM) PUBLIC HEARING TOPIC - 6.A.
Wednesday, December 17, 2025 2:00:23 PM
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December 17, 2025
City of Rancho Mirage
City Council / City Hall
69825 Hwy 111
Rancho Mirage, CA. 92270
Attention: Clerk of the Board
Re: Written testimony in regards to Agenda Item: 6.A. (PUBLIC HEARING - City titled:
Environmental Assessment Case No. EA21-0002, General Plan Zoning Map Amendment Case No. GPZMA21-0001, Major Modification Case No. MOD21-0004, & Tentative Parcel Map Case No. TPM23-0002 (TPM38768) - Ritz Carlton (Rancho Mirage). APN's: 689-330- 026, -028, -031, -032, -034; 689-020-012, -014; & 689-331-001 -018).
Dear current elected and appointed City Council members, Please review my written statements listed below prior to the consideration of agenda Item
6.A. (PUBLIC HEARING)
Position: In Opposition (as presented)
It's critical that future action of potential nullification of this body's decisions related to this and other governing action (PUBLIC HEARING topics) be conducted appropriately. Please be advised that prior public hearings conducted under the city's authority over the past year have been compromised by radical political maneuvers of city officials.
Unusual methods conducted by city officials of censorship techniques of city controlled written meeting minutes (Official Public Record) have removed critical information - such as a brief description (summary) of concerns and opinions expressed by public testimony along with abandonment of recording if any stances (In opposition or support or other) were indicated during public comment(s) and those verbal statements were not recorded within the official public record (written meeting minutes) of city controlled proceedings.
It's crystal clear that city of Rancho Mirage has exceed their authority with their operation of censorship techniques in regards to recording verbalize public testimony (written meeting minutes/official public record) in an accurate fashion of (Public Hearing topics) held under it's authority.
Please be aware that aspects of the citys constructed staff report (Page 209 - Planning Commission) deceived the reader. It was mentioned that "multiple public comments were received during the public hearing. As sumarized in the meeting minutes" - Please be advised that the citys constructed written recorded meeting minutes of those proceedings DIDN'T SUMARIZED any of the public comments received. ONLY the
speakers names were recorded within the official public record.
Contacted work for the proposed development may be unfavourable for a fair and high quality workforce. (Organized labor) appears to be an element that the developer wishes to sidestep.
The development accepted federal government resources during the recent COVID-19 narrative event, and apparently will be unwilling to employ properly trained and compensated workforce (organized labor) that would mirror the development desired public impression of an elite level of service and accommodation.
It's reasonable to consider that the encroachment of the proposed development on undeveloped land (hillside) will cause an environmental experiment to wildlife (animals/flora ect...) that is currently unaffected and undisturbed. Drainage (water run-off) would be increased if desired construction of the underlying development encroachment towards the desert floor is granted.
Public appreciation of Rancho Mirages undisturbed natural hillsides should be perserved for future generations. Pollutes such as building and night time unnatural light sources will be an unprecedented destruction of a natural resource.
It's reasonable to consider that recent traffic signal pattern modification that placed limitation on high traffic volumes to allow east bound (down hill) traffic of Frank Sinatra Drive to enter the intersection (Frank Sinatra Dr. / Hwy 111) before other traditional traffic flows is intentional and puposely Imposed possibility by city officials and Coachella Valley Association of Government (CVAG) administrators. It's highly recommended to abandon modifying traffic signals to accommodate special Interests.
Please don't take any reprisal actions against my private property or person for reporting this true and accurate summary of concerns and opinions.
Sincerely,
Brad Anderson
Cc:
37043 Ferber Dr. Rancho Mirage, CA. 92270
From: Michael Harrington
To: Kristie Ramos, CMC
Subject: Agenda item 6a Dec 18 2025
Date: Wednesday, December 17, 2025 10:29:12 AM
Attachments: Harrincton Ritz Carlton SkyMesa Comment 6a.pdf CAUTION: This email originated from outside The City of Rancho Mirage. DO NOT CLICK links or open attachments unless you recognize the sender and know the content is safe.
Public Comment ITEM 6a OPPOSE
Mike Harrington
Written Public Comment — Ritz -Carlton Residences / Sky Mesa — December 18, 2025, Agenda Item 6a Dear Mayor and City Council Members,
I submit this written comment regarding Agenda Item 6a for the December 18, 2025 City Council meeting concerning the proposed modifications to the Ritz -Carlton Residences project, including the Sky Mesa recreational area and the related General Plan/Zoning Map Amendment converting approximately 3.88 acres from Mountain Reserve (MR) to Resort Hotel (Rs -H). I am unable to attend the meeting in person and respectfully request that this comment be included in the official record.
While the Staff Report emphasizes visual integration, additional parking, open space, and buffering of nearby residential homes, I respectfully request that the City Council fully consider the following environmental and wildlife concerns:
1. New Sky Mesa Development and Human Disturbance:
The Sky Mesa recreational area includes a 6,273 square foot restaurant, event lawns, and a restroom building.
This is a new discretionary component not included in the 2006 entitlements. The proposed Venue event space allows two simultaneous events, significantly increasing noise, lighting, and human activity in adjacent foothill areas.
2. Critical Wildlife Impacts — Peninsular Desert Bighorn Sheep:
The project site and surrounding foothills are known habitat and movement corridors for Peninsular Desert Bighorn Sheep, a federally and state -listed endangered species. Increased nighttime lighting, construction activity, and ongoing human presence from Sky Mesa recreational uses, restaurant operations, and event capacity may disrupt movement corridors, foraging, and breeding behavior, threatening the viability of this sensitive population.
3. CEQA Requirements and Concerns:
The project currently relies on a 2024 Initial Study / Mitigated Negative Declaration (IS/MND). Under CEQA Guidelines §§15162-15163, new or modified discretionary project components —such as Sky Mesa —require independent evaluation to determine whether a Supplemental EIR or full EIR is warranted. Staff has not presented a detailed, species -specific analysis of cumulative and indirect impacts on Peninsular Desert Bighorn Sheep or adequately addressed mitigation measures sufficient to prevent significant impacts.
4. Request for Full CEQA Review Prior to Vote:
Because the Sky Mesa recreational area represents new development on Mountain Reserve land with substantial potential environmental impacts, I respectfully request that the City Council defer approval until a full CEQA review, preferably a Supplemental or full EIR, has been completed and publicly circulated, including rigorous analysis of:
Bighorn sheep habitat and movement corridors Noise, lighting, and human disturbance impacts Cumulative impacts from Parcels 3 condos, hotel operations, and Sky Mesa recreational uses Enforceable mitigation measures to protect sensitive species and habitat
Thank you for including this comment in the official record and for carefully considering these environmental and wildlife concerns prior to the Council vote.
Respectfully submitted,
Michael Harrington
Rancho Mirage Resident
Frank Sinatra / Davall Neighborhood
Submitted electronically
Opposition Comment — Agenda Item 6a
From:
To:
Subject:
Date:
tr008Caaol.com
Kristie Ramos, CMC
HOA Meeting December 18th request
Wednesday, December 17, 2025 8:19:17 PM
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Ms Kristie Ramos,
I am writing to you about the possible impact of the new Ritz Carlton development on our sight views. We are located right next to the proposed building site at 31 Mirada Circle on the North East corner of the proposed construction site.
After close examination of both the building and landscaping plans I believe that our property may be the most impacted. Our main concern is that the development may inhibit both our mountain views and our valley view .We purchased our home two years ago with expectation that these natural views would not be altered.
My proposal is to request that the developer erect some inexpensive "Story Poles" at key locations (a vertical wooden or metal post with a flag set to the height of a proposed building or landcaping tree ) that depict both heights for the trees on the plan across from our house, as well as on the "curve" to address the landscape plan.
In addition, as to the actual proposed building the story poles will show any loss of valley views. This way the impact of these plans through the "Story poles" could be adequately assessed by all Mirada neighbors.
Any loss of views could be then analyzed and possibly mitigated before final landscaping or building heights have been approved As you may or may not know "Story poles" are commonly used in construction and site development .I will be attending the meeting tomorrow and would greatly appreciate your consideration to this proposal.
Respectfully
Tom Richards
31 Mirada Circle
Rancho Mirage (630-485-1054)
From: Jonathan Montano
To: City Clerk; [email protected]; Ben Torres; Planning Division Cc: Mitchell M. Tsai Attorney at Law. P.C.; Jeremy Herwitt Subject: Comment submission: City of Rancho Mirage December 18, 2025, City Council Meeting — Agenda Item No. 6.A:
Ritz -Carlton Phase II Expansion Project
Date: Thursday, December 18, 2025 9:58:12 AM
Attachments: 20251218 WSRCC RanchoMiraae RitzCarlton CCHearing CL Final.pdf CAUTION: This email originated from outside The City of Rancho Mirage. DO NOT CLICK (inks or open attachments unless you recognize the sender and know the content is safe.
Good morning,
Please find attached our comment letter submission for item 6A on today's City Council meeting agenda, concerning the Ritz -Carlton Phase II Expansion Project.
Please confirm receipt of the attached letter.
Thank you,
Jonathan Montano
Paralegal
Mitchell M. Tsai Law Firm - Environmental & Land Use Litigation 139 South Hudson Avenue Suite 200
Pasadena, CA 91101
Phone: (626) 314-3821
Fax: (626) 389-5414
Email: [email protected]
Web site: att--)s: // www.mitchtsailaw.com
CONFIDENTIALITY NOTICE: This e-mail transmission, and any documents, files or previous e-mail messages accompanying it, may contain confidential information that is legally privileged. If you are not the intended recipient, or a person responsible for delivering it to the intended recipient, you are hereby notified that any disclosure, copying, distribution or use of any of the information contained in or attached to this message is STRICTLY PROHIBITED and may violate applicable laws including the Electronic Communications Privacy Act. If you have received this transmission in error, please immediately notify us by reply e-mail at [email protected] or by telephone at (626) 314-3821 and destroy the original transmission and its attachments without reading them or saving them to disk. Thank you.
P: (626) 314-3821
E: [email protected]
Mitchell M. Tsai
Law Firm
139 S. Hudson Ave., Suite 200
Pasadena, California 91101
VIA EMAIL
December 18, 2025
City Council
City of Rancho Mirage
Rancho Mirage City Hall
69-825 Highway 111
Rancho Mirage, California, 92270
Em: [email protected]
Em: kristier@,ranchmirageca.gov
Ben Torres
Planning Manager
69-825 Highway 111
Rancho Mirage, California, 92270
Em: [email protected]
Em: [email protected]
RE: City of Rancho Mirage December 18, 2025, City Council Meeting — Agenda Item No. 6.A: Ritz -Carlton Phase II Expansion Project.
Dear Mayor Mallotto, Honorable Councilmembers, and Ben Torres:
On behalf of the Western States Regional Council of Carpenters ("WSRCC"), our firm is submitting these comments in connection with the City of Rancho Mirage's ("City" or "Lead Agency") December 18, 2025, City Council hearing (Agenda Item No. 6.A) pertaining to the Ritz -Carlton Phase II Expansion Project (Case Nos. EA21- 0002, GPZMA21-0001, DA21-0002, MOD21-0004) ("Project") and the December 2024 Final Initial Study / Mitigated Negative Declaration ("FMND") published in connection therewith.
The Project involves the construction of the Ritz -Carlton Residences Rancho Mirage and the Sky Mesa Recreation Center on a 16.13 -acre site located at 68900 Frank Sinatra Drive, Rancho Mirage, CA 92270 (APNs: 689-330-026, -028, -031, -032, -034; 689-020-012, -014; 689-331-001, -018) in Riverside County. Nestled in the foothills of the Santa Rosa Mountains 650 feet above the Coachella Valley below, the 236,748 - square -foot Project will consist of 106 residential suites and hotel villas (totaling approximately 200,474 -square feet), approximately 23,840 -square feet of event space, approximately 6,273 -square feet of restaurant/commercial space, and approximately 5,510 -square feet of amenity space. The overall Project Site includes an existing hotel that opened as a Ritz -Carlton in 1988. The Project would provide a total of 106 new units and 499 vehicle parking spaces.
City of Rancho Mirage — Ritz -Carlton Phase II Expansion December 18, 2025
In March 2024, the City released the first Initial Study / Mitigated Negative Declaration ("MND") for the Project. On April 9, 2024, WSRCC submitted written comments to the MND during the comment period specified by the City, and raised various concerns as to deficiencies noted in the Project's environmental review.
Purportedly based on certain comments raised during the MND's comment period, in July 2024, the City released a Recirculated Initial Study / Mitigated Negative Declaration ("RMINTD") for the Project. On August 20, 2024, WSRCC submitted written comments to the RMND during the comment period specified by the City, which again highlighted ongoing deficiencies in the RMND and Project's environmental review. On January 9, 2025, the City's Planning Commission held a hearing on the Project, in connection with which WSRCC submitted further written comments noting the ongoing deficiencies in the Project's environmental review.
Notwithstanding WSRCC's prior meritorious comments and concerns, the Project's FMND and the City's Sept. 2025 Responses to Comments still do not address and resolve any of the concerns previously raised by WSRCC in its prior comments, including issues related to the Project's impacts on biological resources, cultural resources, noise, GHG emissions, energy use, land use. WSRCC expressly reiterates and incorporates its prior comments in the foregoing correspondence, and urges the City to give them full consideration as part of the CEQA environmental review process.
WSRCC is a labor union representing over 63,000 union carpenters in 10 states, including California, and has a strong interest in well -ordered land use planning and in addressing the environmental impacts of development projects. Some WSRCC members live, work, and recreate in the City and the surrounding communities and would be directly affected by the Project's environmental impacts.
WSRCC expressly reserves the right to supplement these comments at or prior to hearings on the Project, and at any later hearing and proceeding related to this Project.
Gov. Code, § 65009(b); PRC, § 21177(a); see Bakersfield CitkensforLocal Control v.
Bakersfield (2004) 124 Ca1.App.4th 1184, 1199-1203; see also Galante Vineyards v.
Monterey Water Dist. (1997) 60 Ca1.App.4th 1109, 1121.
WSRCC incorporates by reference all comments raising issues regarding the Project and its environmental review and associated documents and reports (including the City's Staff Report), or lack thereof. See Citizens for Clean Energy v. City of Woodland (2014) 225 Cal.App.4th 173, 191 (finding that any party who has objected to the
City of Rancho Mirage — Ritz -Carlton Phase II Expansion December 18, 2025
project's environmental documentation may assert any issue timely raised by other parties).
Moreover, WSRCC requests that the City provide notice for any and all notices referring or related to the Project issued under the California Environmental Quality Act ("CEQA") (Public Resources Code, § 21000 et seq.), and the California Planning and Zoning Law ("Planning and Zoning Law") (Gov. Code, §§ 65000-65010).
California Public Resources Code, sections 21092.2 and 21167, subsection (f) and California Government Code, section 65092 require agencies to mail such notices to any person who has filed a written request for them with the clerk of the agency's governing body.
I. THE CITY SHOULD REQUIRE THE USE OF A LOCAL
WORKFORCE TO BENEFIT THE COMMUNITY'S ECONOMIC
DEVELOPMENT AND ENVIRONMENT.
The City should require that the Project be built using local workers who have graduated from a Joint Labor -Management Apprenticeship Program approved by the State of California, have at least as many hours of on-the-job experience in the applicable craft which would be required to graduate from such a program, or are registered apprentices in such a program.
Community benefits such as local hire can also be helpful to reduce environmental impacts and improve the positive economic impacts of the Project. Local hire provisions requiring that a certain percentage of workers reside within 10 miles or less of the Project site can reduce the length of vendor trips, reduce greenhouse gas emissions, and provide localized economic benefits. As environmental consultants Matt Hagemann and Paul E. Rosenfeld note:
[A]ny local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction -related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.
March 8, 2021, SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling.
Workforce requirements promote the development of skilled trades that yield sustainable economic development. As the California Workforce Development Board
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and the University of California, Berkeley Center for Labor Research and Education concluded:
[L]abor should be considered an investment rather than a cost —and investments in growing, diversifying, and upskilling California's workforce can positively affect returns on climate mitigation efforts. In other words, well -trained workers are key to delivering emissions reductions and moving California closer to its climate targets.'
Furthermore, workforce policies have significant environmental benefits given that they improve an area's jobs -housing balance, decreasing the amount and length of job commutes and the associated greenhouse gas ("GHG") emissions. In fact, on May 7, 2021, the South Coast Air Quality Management District found that that the "[u] se of a local state -certified apprenticeship program" can result in air pollutant reductions.2 Locating jobs closer to residential areas can have significant environmental benefits.
As the California Planning Roundtable noted in 2008:
People who live and work in the same jurisdiction would be more likely to take transit, walk, or bicycle to work than residents of less balanced communities and their vehicle trips would be shorter. Benefits would include potential reductions in both vehicle miles traveled and vehicle hours traveled.'
Moreover, local hire mandates and skill -training are critical facets of a strategy to reduce vehicle miles traveled ("VMT"). As planning experts Robert Cervero and Michael Duncan have noted, simply placing jobs near housing stock is insufficient to achieve VMT reductions given that the skill requirements of available local jobs must 1 California Workforce Development Board (2020) Putting California on the High Road: A Jobs and Climate Action Plan 2030 at p. ii, available at https://laborcenter.berkeley.edu/ wp-content/u?loads /2020 /09 /Putting-California-on-the-High-Road.'Ddf. 2 South Coast Air Quality Management District (May 7, 2021) Certify Final Environmental Assessment and Adopt Proposed Rule 2305 — Warehouse Indirect Source Rule — Warehouse Actions and Investments to Reduce Emissions Program, and Proposed Rule 316 — Fees for Rule 2305, Submit Rule 2305 for Inclusion Into the SIP, and Approve Supporting Budget Actions, available at http://www.acmd.gov/dots/default- source/Agendas /Governing-Board/2021 /2021-May7-027.pdf?sfvrsn=10. 3 California Planning Roundtable (2008) Deconstructing Jobs -Housing Balance at p. 6, available at https://croundtable.org/static/media/u?loads/?ublications/cr-jobs- housing.2df
City of Rancho Mirage — Ritz -Carlton Phase II Expansion December 18, 2025
match those held by local residents.4 Some municipalities have even tied local hire and other workforce policies to local development permits to address transportation issues. Cervero and Duncan note that:
In nearly built -out Berkeley, CA, the approach to balancing jobs and housing is to create local jobs rather than to develop new housing. The city's First Source program encourages businesses to hire local residents, especially for entry- and intermediate -level jobs, and sponsors vocational training to ensure residents are employment -ready. While the program is voluntary, some 300 businesses have used it to date, placing more than 3,000 city residents in local jobs since it was launched in 1986. When needed, these carrots are matched by sticks, since the city is not shy about negotiating corporate participation in First Source as a condition of approval for development permits.
Recently, the State of California verified its commitment towards workforce development through the Affordable Housing and High Road Jobs Act of 2022, otherwise known as Assembly Bill No. 2011 (AB2011). AB2011 amended the Planning and Zoning Law to allow ministerial, by -right approval for projects being built alongside commercial corridors that meet affordability and labor requirements.
The City should consider utilizing local workforce policies and requirements to benefit the local area economically and to mitigate GHG emissions, improve air quality, and reduce transportation impacts.
II. THE CITY SHOULD INCORPORATE LANGUAGE IMPOSING
TRAINING REQUIREMENTS FOR CONSTRUCTION ACTIVITIES
TO PREVENT COMMUNITY SPREAD OF COVID-19 AND OTHER
INFECTIOUS DISEASES INTO THE DEVELOPMENT
AGREEMENT.
Construction work has been defined as a Lower to High -risk activity for COVID-19 spread by the Occupations Safety and Health Administration. Recently, several Cervero, Robert and Duncan, Michael (2006) Which Reduces Vehicle Travel More: Jobs - Housing Balance or Retail -Housing Mixing? Journal of the American Planning Association 72 (4), 475-490, 482, available at http://reconnectingamerica.org/assets/Uploads/UTCT- 825.t,df.
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construction sites have been identified as sources of community spread of COVID-
19. 5
Western Carpenters recommend that the City adopt additional requirements to mitigate public health risks from various residential, commercial and mixed -use development construction activities. Western Carpenters requests that the City require safe on -site construction work practices as well as training and certification for any construction workers on residential, commercial and mixed -use developments within the City's General Plan Area.
In particular, based upon Western Carpenters' experience with safe construction site work practices, Western Carpenters recommends that the City require that while construction activities are being conducted at the proposed Project ("Project Site"):
Construction Site Design:
• The Project Site will be limited to two controlled entry points. • Entry points will have temperature screening technicians taking temperature readings when the entry point is open.
• The Temperature Screening Site Plan shows details regarding access to the Project Site and Project Site logistics for conducting temperature screening.
• A 48 -hour advance notice will be provided to all trades prior to the first day of temperature screening.
• The perimeter fence directly adjacent to the entry points will be clearly marked indicating the appropriate 6 -foot social distancing position for when you approach the screening area. Please reference the Apex temperature screening site map for additional details.
• There will be clear signage posted at the project site directing you through temperature screening.
5 Santa Clara County Public Health (June 12, 2020) COVID-19 CASES AT
CONSTRUCTION SITES HIGHLIGHT NEED FOR CONTINUED VIGILANCE IN SECTORS THAT HAVE REOPENED, available athtt?s:// www.sccgov.org/sites/ covidl9 /Pages /Dress-release-06-12-2020-cases-at-construction-sites.as?x.
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• Provide hand washing stations throughout the construction site.
Testing Procedures:
• The temperature screening being used are non -contact devices. • Temperature readings will not be recorded.
• Personnel will be screened upon entering the testing center and should only take 1-2 seconds per individual.
• Hard hats, head coverings, sweat, dirt, sunscreen or any other cosmetics must be removed on the forehead before temperature screening.
• Anyone who refuses to submit to a temperature screening or does not answer the health screening questions will be refused access to the Project Site.
• Screening will be performed at both entrances from 5:30 am to 7:30 am.; main gate [ZONE 1] and personnel gate [ZONE 2]
• After 7:30 am only the main gate entrance [ZONE 1] will continue to be used for temperature testing for anybody gaining entry to the project site such as returning personnel, deliveries, and visitors. • If the digital thermometer displays a temperature reading above 100.0 degrees Fahrenheit, a second reading will be taken to verify an accurate reading.
• If the second reading confirms an elevated temperature, DHS will instruct the individual that he/she will not be allowed to enter the Project Site. DHS will also instruct the individual to promptly notify his/her supervisor and his/her human resources (HR) representative and provide them with a copy of Annex A.
Planning
• Require the development of an Infectious Disease Preparedness and Response Plan that will include basic infection prevention measures (requiring the use of personal protection equipment), policies and procedures for prompt identification and isolation of sick individuals, social distancing (prohibiting gatherings of no
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more than 10 people including all -hands meetings and all -hands lunches) communication and training and workplace controls that meet standards that may be promulgated by the Center for Disease Control, Occupational Safety and Health Administration, Cal/OSHA, California Department of Public Health or applicable local public health agencies.'
The United Brotherhood of Carpenters and Carpenters International Training Fund has developed COVID-19 Training and Certification to ensure that Carpenter union members and apprentices conduct safe work practices. The City should require that all construction workers undergo COVID-19 Training and Certification before being allowed to conduct construction activities at the Project Site.
Western Carpenters has also developed a rigorous Infection Control Risk Assessment ("ICRA") training program to ensure it delivers a workforce that understands how to identify and control infection risks by implementing protocols to protect themselves and all others during renovation and construction projects in healthcare environments.'
ICRA protocols are intended to contain pathogens, control airflow, and protect patients during the construction, maintenance and renovation of healthcare facilities.
ICRA protocols prevent cross contamination, minimizing the risk of secondary infections in patients at hospital facilities.
The City should incorporate language in the Development Agreement requiring that the Project be built using a workforce trained in ICRA protocols.
III. THE CITY'S RESPONSES TO COMMENTS INCORRECTLY AND
CONCLUSORILY CLAIM THAT ULTIMATE APPROVAL OF THE
PROJECT WOULD NOT REQUIRE A TWO-THIRDS VOTE BY
THE RANCHO MIRAGE ELECTORATE.
6 See also The Center for Construction Research and Training, North America's Building Trades Unions (April 27 2020) NABTU and CPWR COVIC-19 Standards for U.S Constructions Sites, available at https://www.c?wr.com/sites/default/files/NABTU_ CPWR Standards COVID-19.?df; Los Angeles County Department of Public Works (2020) Guidelines for Construction Sites During COVID-19 Pandemic, available at https://chw.lacounty.gov/building-and-safety/docs/-Dw guidelines-construction-sites..Ddf. ' For details concerning Western Carpenters' ICRA training program, see https://icrahealthcare.com/ .
City of Rancho Mirage — Ritz -Carlton Phase II Expansion December 18, 2025
Based on the City's Responses to Comments in connection with the FMND and its September 2025 Responses to Comments ("Sept. 2025 Responses to Comments") that responded to WSRCC's prior January 9, 2025, correspondence concerning the Project, the City remains under the mistaken impression that approval of the Project, based on its proposed rezoning and development of lands currently zoned as Mountain Reserve, would not be required to be authorized by a two-thirds vote of the Rancho Mirage electorate. (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, p. RTC -842; see also City's Sept. 2025 Responses to Comments, pp. RTC -3 — RTC -4.) Indeed, the City's Responses to Comments baldly state and then re -state that "[t]he project site is not considered mountainous lands and would not require the project to be approved by a two-thirds vote of the electorate," without providing any further justification for how lands zoned as "Mountain Reserve (MR)" should not be "considered mountainous lands." (Id.) In taking this incorrect conclusory position without offering any substantive basis for support whatsoever, the City appears to be charting a course toward directly violating its own Code of Ordinances in pursuing the approval of the Project and its entitlements.
Notably, and as previously indicated by WSRCC, the City's Code of Ordinances §
7.06.010 provides as follows:
All discretionary approvals, including but not limited to development agreements, general plan amendments, zone changes, development permits, grading permits and use permits approved by the city council on or after July 3, 1992 and having no building permit issued, shall require the approval of the city council, and thereafter a two-thirds vote of the electorate of the city to be considered an approved application, if the approval is an application on property located within the city "mountainous lands" area of the Santa Rosa and San Jacinto Mountains, as described within the Coachella Valley Mountains Conservancy legislative map, as of November 3, 1992.
(Rancho Mirage Code of Ordinances § 7.06.010.) Again, the Project site sits within the boundary of the Coachella Valley Mountains Conservancy territory map. (Exhibit E — Coachella Valley Mountains Conservancy Territory Map.) As confirmed in the MND, the RMDN, and the FMND, the portion of the Project proposed for parcels 689-020-012 and 689-020-014 (the Sky Mesa Recreational Area) unequivocally has a General Plan Land Use designation of "Open Space: Mountain Reserve (MR)." (See
City of Rancho Mirage — Ritz -Carlton Phase II Expansion December 18, 2025
FMND, Figure 1-12, at p. 49; See also Exhibit F — Rancho Mirage Land Use and Zoning Map.) Moreover, the Rancho Mirage General Plan sets forth the following stated goal for the land use(s) applicable to the Mountain Reserve (MR) zone:
This designation is assigned to public lands or property subject to conservation easements in the Santa Rosa Mountains. Uses are limited to recreational activities, such as hiking or equestrian and non - motorized bike trails and facilities consistent with the need to protect sensitive biological resources. Vehicular access is not permitted in this designation.
(See Rancho Mirage 2017 General Plan, p. 10.)
Accordingly, given the location of the Project site, coupled with the established boundaries of the Coachella Valley Mountains Conservancy and the site's land use designation under the City's General Plan, and the Project's pursuit of both a General Plan Zoning Map Amendment and a Development Agreement Amendment, the site falls within the definition of the "city `mountainous lands' area of the Santa Rosa...Mountains" and the Project's requested entitlements fall within the scope of discretionary approvals covered by Code of Ordinances § 7.06.010. Therefore, the Project is unquestionably subject to the approval proscriptions of Code of Ordinances § 7.06.010, including the required 2/3 vote of the City's electorate in order to ultimately approve the Project's application. The City's apparent attempts to circumvent a conservation easement in the Santa Rosa Mountains located on the Project Site cannot be countenanced, and the City's general public cannot be denied its statutory right to vote on the proposed development contemplated by the Project.
As such, the Project as contemplated must ultimately be approved by a two-thirds vote of the Rancho Mirage electorate. WSRCC's comments in this regard should not be construed as a waiver of its other arguments regarding the inadequacies identified in the FMND and the need for the City to complete a legally -compliant EIR, nor should it be construed as a recommendation that the Project be approved via the FMND by the Planning Commission and the City Council. Rather, WSRCC is providing comments on this particular issue out of an abundance of caution to ensure that the City's proper approval procedures are followed, particularly given the Project's stated intention to re -zone and develop mountainous lands within the Santa Rosa Mountains that are currently zoned as Mountain Reserve, located within the boundaries of the Coachella Valley Mountains Conservancy, and subject to a
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conservation easement. WSRCC's concerns in this regard have been heightened by the ongoing flippant and unsupported refusal by the City's planning staff to acknowledge the applicability of Code of Ordinances § 7.06.010 to the Project as presently proposed.
IV. THE CALIFORNIA ENVIRONMENTAL QUALITY ACT.
A. Background Concerning Environmental Impacts Reports Under CEQA.
CEQA is a California statute designed to inform decision -makers and the public about the potential significant environmental effects of a project. 14 Cal. Code of Regulations ("CEQA Guidelines"), § 15002(a)(1).8 At its core, its purpose is to "inform the public and its responsible officials of the environmental consequences of their decisions before they are made." Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Ca1.3d 553, 564.
CEQA directs public agencies to avoid or reduce environmental damage, when possible, by requiring alternatives or mitigation measures. CEQA Guidelines, § 15002(a) (2)-(3); see also Berkeley Keep Jets Over the Bay Committee v. Board of Port Comes (2001) 91 Cal.App.4th 1344, 1354; Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Ca1.3d 553; Laurel Heights Improvement Assn., 47 Ca1.3d at p. 400. The Environmental Impact Report ("EIR") serves to provide public agencies and the public in general with information about the effect that a proposed project is likely to have on the environment and to "identify ways that environmental damage can be avoided or significantly reduced." CEQA Guidelines, § 15002, subd. (a)(2). If the project has a significant effect on the environment, the agency may approve the project only upon finding that it has "eliminated or substantially lessened all significant effects on the environment where feasible" and that any unavoidable significant effects on the environment are "acceptable due to overriding concerns" specified in Public Resources Code section 21081. See CEQA Guidelines, §§ 15092, subds. (b)(2)(A)-(B).
While the courts review an EIR using an `abuse of discretion' standard, the reviewing court is not to uncritically rely on every study or analysis presented by a project proponent in support of its position. Berkeley Jets, 91 Ca1.App.4th at p. 1355 (quoting 8 The CEQA Guidelines, codified in Title 14 of the California Code of Regulations, section 15000 et seq., are regulatory guidelines promulgated by the state Natural Resources Agency for the implementation of CEQA. PRC, § 21083. The CEQA Guidelines are given "great weight in interpreting CEQA except when . . . clearly unauthorized or erroneous" Center for Biological Diversity v. Dept. of Fish & Wildlife (2015) 62 Ca1.4th 204, 217.
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Laurel Heights Improvement Assn., 47 Ca1.3d at pp. 391, 409 fn. 12) (internal quotations omitted). A clearly inadequate or unsupported study is entitled to no judicial deference. Id. Drawing this line and determining whether the EIR complies with CEQA's information disclosure requirements presents a question of law subject to independent review by the courts. Sierra Club v. County of Fresno (2018) 6 Ca1.5th 502, 515; Madera Oversight Coalition, Inc. v. County ofMadera (2011) 199 Ca1.App.4th 48, 102, 131. As the court stated in Berkeley Jets, prejudicial abuse of discretion occurs if the failure to include relevant information precludes informed decision -making and informed public participation, thereby thwarting the statutory goals of the EIR process. 91 Ca1.App.4th at p. 1355 (internal quotations omitted).
The preparation and circulation of an EIR is more than a set of technical hurdles for agencies and developers to overcome. Communities for a Better Environment v. Richmond (2010) 184 Cal.App.4th 70, 80 (quoting Vineyard Area Citizens for Responsible Growth, Inc. v. City of Rancho Cordova (2007) 40 Ca1.4th 412, 449-450). The EIR's function is to ensure that government officials who decide to build or approve a project do so with a full understanding of the environmental consequences and, equally important, that the public is assured those consequences have been considered. Id. For the EIR to serve these goals it must present information so that the foreseeable impacts of pursuing the project can be understood and weighed, and the public must be given an adequate opportunity to comment on that presentation before the decision to go forward is made. Id. The EIR requirement "is the heart of CEQA." CEQA Guidelines, § 15003(a).
Thus, a strong presumption in favor of requiring preparation of an EIR is built into CEQA. This presumption is reflected in what is known as the "fair argument" standard under which an EIR must be prepared whenever substantial evidence in the record supports a fair argument that a project may have a significant effect on the environment. Quail Botanical Gardens Found., Inc. v. City of Encinitas (1994) 29 Ca1.App.4th 1597, 1602; Friends of `B" St. v. City of Hayward (1980) 106 Ca1.3d 988, 1002.
The fair argument test stems from the statutory mandate that an EIR be prepared for any project that "may have a significant effect on the environment." PRC, § 21151; see No Oil, Inc. v. City of Los Angeles (1974) 13 Ca1.App.3d 68, 75; accord Jensen v. City of Santa Rosa (2018) 23 Cal.App.5th 877, 884. Under this test, if a proposed project is not exempt and may cause a significant effect on the environment, the lead agency must
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prepare an EIR. PRC, §§ 21100, subd. (a), 21151; CEQA Guidelines, §§ 15064, subds. (a)(1), (f)(1). An EIR may be dispensed with only if the lead agency finds no substantial evidence in the initial study or elsewhere in the record that the project may have a significant effect on the environment. Parker Shattuck Neighbors v. Berkeley City Council (2013) 222 Ca1.App.4th 768, 785. In such a situation, the agency must adopt a negative declaration. PRC, § 21080, subd. (c)(1); CEQA Guidelines, §§ 15063, subd. (b) (2), 15064, subd. (f) (3).
"Significant effect upon the environment" is defined as "a substantial or potentially substantial adverse change in the environment." PRC, § 21068; CEQA Guidelines, § 15382. A project "may" have a significant effect on the environment if there is a "reasonable probability" that it will result in a significant impact. No Oil, Inc., 13 Ca1.3d at p. 83 fn. 16; see Sundstrom v. County of Mendocino (1988) 202 Ca1.App.3d 296, 309. If any aspect of the project may result in a significant impact on the environment, an EIR must be prepared even if the overa effect of the project is beneficial. CEQA Guidelines, § 15063(b)(1); see County Sanitation Dist. No. 2 v. County of Kern (2005) 127 Ca1.App.4th 1544, 1580.
This standard sets a "low threshold" for preparation of an EIR. Consolidated Irrigation Dist. v. City of Selma (2012) 204 Ca1.App.4th 187, 207; Nelson v. County of Kern (2010) 190 Ca1.App.4th 252; Pocket Protectors v. City of Sacramento (2004) 124 Ca1.App.4th 903, 928; Bowman v. City of Berkeley (2004) 122 Ca1.App.4th 572, 580; Citizen Action to Serve All Students v. Thornley (1990) 222 Ca1.App.3d 748, 754; Sundstrom, 202 Ca1.App.3d at p. 310. If substantial evidence in the record supports a fair argument that the project may have a significant environmental effect, the lead agency must prepare an EIR even if other substantial evidence before it indicates the project will have no significant effect. See Jensen, 23 Ca1.App.5th at p. 886; Clews Land & Livestock v. City of San Diego (2017) 19 Cal.App.5th 161, 183; Stanislaus Audubon Society, Inc. v. County of Stanislaus (1995) 33 Ca1.App.4th 144, 150; Brentwood Assn. for No Drilling, Inc. v. City of Los Angeles (1982) 134 Ca1.App.3d 491; Friends of `B"St., 106 Ca1.App.3d 988; CEQA Guidelines, § 15064(f)(1). Substantial evidence includes "enough relevant information and reasonable inferences from this information that a fair argument can be made to support a conclusion, even though other conclusions might also be reached." CEQA Guidelines, § 15384(a).
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B. Background Concerning Initial Studies, Negative Declarations, and Mitigated Negative Declarations.
CEQA and CEQA Guidelines are strict and unambiguous about when an MND may be used. A lead agency may adopt an MND only if "there is no substantial evidence that the project will have a significant effect on the environment" CEQA Guidelines, § 15074(b).
Evidence supporting a fair argument of a significant environmental impact triggers preparation of an EIR regardless of whether the record contains contrary evidence.
League for Protection of Oakland's Architectural and Historical Resources v. City of Oakland (1997) 52 Cal.App.4th 896, 904-905. "Where the question is the sufficiency of the evidence to support a fair argument, deference to the agency's determination is not appropriate[.]" County Sanitation, 127 Cal.App.4th at 1579 (quoting Sierra Club v. County of Sonoma (1992) 6 Ca1.App.4th 1307, 1317-1318).
Further, it is the duty of the lead agency, not the public, to conduct the proper environmental studies. "The agency should not be allowed to hide behind its own failure to gather relevant data." Sundstrom, 202 Ca1.App.3d at p. 311. "Deficiencies in the record may actually enlarge the scope of fair argument by lending a logical plausibility to a wider range of inferences." Id; see also Gentry v. City of Murrieta (1995) 36 Ca1.App.4th 1359, 1382 (lack of study enlarges the scope of the fair argument which may be made based on the limited facts in the record).
Thus, refusal to complete recommended studies lowers the already low threshold to establish a fair argument. The court may not exercise its independent judgment on the omitted material by determining whether the ultimate decision of the lead agency would have been affected had the law been followed. Environmental Protection Information Center v. Cal. Dept. of Forestry (2008) 44 Ca1.4th 459, 486 (internal citations and quotations omitted). The remedy for this deficiency would be for the trial court to issue a writ of mandate. Id.
Both the review for failure to follow CEQA's procedures and the fair argument test are questions of law, thus, the de novo standard of review applies. Vineyard Area Citizens for Responsible Growth v. City of Rancho Cordova (2007) 40 Ca1.4th 412, 435. 'Whether the agency's record contains substantial evidence that would support a fair argument that the project may have a significant effect on the environment is treated
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as a question of law. Consolidated Irrigation Dist., 204 Ca1.App.4th at p. 207; Kostka and Zischke, Practice Under the Environmental Quality Act (2017, 2d ed.) at § 6.76.
In the MND context, courts give no deference to the agency. The agency or the court should not weigh expert testimony or decide on the credibility of such evidence —this is the EIR's responsibility. As stated in Pocket Protectors v. City of Sacramento:
Unlike the situation where an EIR has been prepared, neither the lead agency nor a court may "weigh" conflicting substantial evidence to determine whether an EIR must be prepared in the first instance.
Guidelines section 15064, subdivision (f)(1) provides in pertinent part: if a lead agency is presented with a fair argument that a project may have a significant effect on the environment, the lead agency shall prepare an EIR even though it may also be presented with other substantial evidence that the project will not have a significant effect. Thus, as Claremont itself recognized, [c]onsideration is not to be given contrary evidence supporting the preparation of a negative declaration.
(2004) 124 Ca1.App.4th 903, 935 (internal citations and quotations omitted).
In cases where it is not clear whether there is substantial evidence of significant environmental impacts, CEQA requires erring on the side of a "preference for resolving doubts in favor of environmental review." M jia v. City of Los Angeles (2005) 130 Ca1.App.4th 322, 332. "The foremost principle under CEQA is that the Legislature intended the act to be interpreted in such manner as to afford the fullest possible protection to the environment within the reasonable scope of the statutory language. Friends of Mammoth v. Bd. of Supervisors (1972) 8 Ca1.3d 247, 259.
IV. THE PROJECT WOULD BE APPROVED IN VIOLATION OF THE
CALIFORNIA ENVIRONMENTAL QUALITY ACT
A. The City Must Prepare an Environmental Impact Report for the Project.
WSRCC reiterates that it would be unlawful for the City to approve the Project in reliance on the incomplete and flawed FMND. As explained below, the FMND continues its failure to support all of its findings with sufficient analysis and substantial evidence and fails to incorporate adequate mitigation measures. Moreover, there is substantial evidence on the face of the FMND that the Project will, in fact, have a
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significant impact on the surrounding environment. Indeed, the Project involves the new construction, use, and maintenance of a 150,000 -square -foot structure with 106 units, subterranean parking for 381 automobiles, 28,843 square feet of event space, 6,273 square feet of restaurant space, and 5,513 square feet for amenities, and the alteration and removal of existing landscaping on a 35.07 -acre site, a significant portion of which is currently zoned as protected Mountain Reserve land. Considering these details, along with the pristine and natural surroundings of the Site, the City must prepare and circulate a thorough, Project -specific EIR. As set forth in greater detail below, there is a fair argument that the Project will have a significant effect on the environment, triggering the "low threshold" standard for the City's preparation and circulation of an EIR for the Project.
1. The FMND Perpetuates the City's Failure to Adequately Analyze the Project and Omits Information
If a project has a significant effect on the environment, an agency may approve the project only upon finding that it has "eliminated or substantially lessened all significant effects on the environment where feasible" and that any unavoidable significant effects on the environment are "acceptable due to overriding concerns." CEQA Guidelines § 15092(b)(2)(A—B).
CEQA mitigation measures proposed and adopted are required to describe what actions will be taken to reduce or avoid an environmental impact. (CEQA Guidelines 15126.4(a)(1)(B) [providing "[f]ormulation of mitigation measures should not be deferred until some future time."1.) While the same Guidelines section 15126.5(a)(1)(B) acknowledges an exception to the rule against deferrals, such exception is narrowly proscribed to situations where it is impractical or infeasible to include those details during the project's environmental review.
Here, the FMND's mitigation measures still fail to adequately analyze and/or mitigate the Project's impacts and are improperly deferred, such that an EIR is required. i. Biological Resources
CEQA requires that an environmental document identify and discuss the significant effects of a Project, alternatives and how those significant effects can be mitigated or avoided. CEQA Guidelines § 15126.2; PRC §§ 21100(b)(1), 21002.1(a). An environmental document's discussion of potentially significant effects must "provide an adequate analysis to inform the public how its bare numbers translate to create
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potential adverse impacts, or it must adequately explain what the agency does know and why, given existing scientific constraints, it cannot translate potential [environmental] impacts further." Sierra Club v. County of Fresno (2018) 6 Cal. 5th 502, 521; see also citing Laurel Heights Improvement Assn. v. Regents of University of California (1988) 47 Ca1.3d 376, 405; see also PRC §§ 21002.1(e), 21003(b). An EIR may not set an impermissibly narrow threshold of significance for biological impacts. Endangered Habitats League, Inc. v. County of Orange (2005) 131 Ca1.App.4th 777.
Here, the FMND and the City's responses to comments have still failed to provide analysis on the Project's biological resource impacts in accordance with the above, and continues to admit that, despite the documented potential for occurrence of special -status wildlife species within the vicinity of the Project Site, no focused special -status wik ife surveys were conducted. (Appendix B to FMND, p. 9, Attachment F, pp. 1-3.) Indeed, the FMND's biological resources study found potential for the occurrence of several special status species, including Peninsular bighorn sheep (moderate potential to occur), red diamondback rattlesnake (moderate potential to occur), burrowing owl (low potential to occur), loggerhead shrike (low potential to occur), LeConte's thrasher (moderate potential to forage), and pocketed free -tailed bat (moderate potential to forage within Project site). (Appendix B to FMND, pp. 14-15.) Despite this likelihood of occurrence, the FMND s`i 1 makes no provision for specific studies to confirm whether any special -status species are inhabiting the proposed Project Area. Moreover, the City's responses to comments incorrectly assert, without any legal authority or other evidence, that "...focused species surveys are not required by CEQA to assess the impacts to species with the potential to occur." (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, p. RTC -838 - 839.)
The City's own consultants have indicated the likelihood of special status species to occur on the Project Site, and they have further fashioned mitigation measures to address the potential discovery of such special -status species during the construction process. The fact that these mitigation measures have already been crafted for certain special -status species that were not identified in the initial biological survey conducted for the Project directly contradicts the position the City has now taken in its responses to comments that additional mitigation efforts (in the form of focused surveys) need not be undertaken as to species that were not identified in the that initial biological survey. The City's position on this issue is logically inconsistent and wholly
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unsupported. WSRCC resubmits that FMND cannot properly conclude that its proposed mitigation measures will reduce biological resource impacts to less than significant levels without first conducting field surveys and subsequent comprehensive analysis regarding these special status species.
Given the overall potential for the occurrence of special -status species in the proposed Project area, WSRCC maintains that the Project should be subject to more comprehensive EIR review. Again, under California law, the threshold for requiring preparation of an EIR for a project is low, and here, there is a fair argument, based on the anticipated presence of special status species on the Project Site (as documented by the City's own consultant), that the Project as proposed will have significant environmental impacts. In the alternative, and at a minimum, the pre -construction biological survey specifications that WSRCC contends should be incorporated are necessary to ensure the overall adequacy of the FMND's proposed mitigation measures. Absent inclusion of such specifications in the Project's mitigation measures, there is a fair argument that the Project may have a significant environmental impact. ii. Cultural Resources
In order to mitigate impacts related to the inadvertent discovery of yet unknown historical/cultural resources, the FMND requires implementation of MM-CUL-1 and MM-CUL-2. (FMND at 96-97.) However, and despite other revisions made to the mitigation measures in response to other comments concerning the Project, the FMND's proposed mitigation measures sti do not provide for any pre -construction training for the Project's construction workers that will otherwise permit laborers on the Project to properly identify and address any sensitive cultural resources or human remains that may be encountered during course of construction. Moreover, in response to WSRCC's prior comments on this issue, the City continues to mistakenly assert that the Project's construction workers and the archaeological and tribal consultants should not be tasked with developing any plans for the handling of any human remains that may be discovered on the Project Site during the course of construction. Again, WSRCC is not advocating for any such action by the Project's construction workers to be incorporated into the mitigation measures. This discussion by the City in its response to comments misses the point, which is that the Project's construction workers must be adequately trained prior to construction in order to be able to initially identify sensitive cultural resources and/or human remains so they are not inadvertently destroyed during the construction process. As it stands, the Project's
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mitigation measures still fail to take this essential step, without which the efficacy of the existing mitigation measures are substantially impaired.
Accordingly, the scope of the FMND's contemplated mitigation measures is inadequate. The proposed mitigation measures MM-CUL-1 and MM-CUL-2 remain deficient in their current form and must, at a minimum, be revised to adequately mitigate against any potentially significant impacts to cultural resources. iii. Noise
WSRCC resubmits that there is also a fair argument that the Project may have a significant noise impact, such that an EIR must be prepared for the Project. To that end, the FMND has maintained its failure to measure ambient noise levels near the proposed Project's most sensitive uses/receptors at the southern edge of the proposed Project Site, and no additional noise study has been performed. (See FMND, Figure 13-1, p. 156; see also FMND, p. 145-48, Table 13-2.) Instead, the FMND only measured ambient noise levels at three locations: L1 - located in a graded area where no construction work is being contemplated for the project; L2 — at the southeastern corner of the existing Ritz -Carlton hotel property; and L3 — on the central west edge of the primary villa/residences development site and adjacent to the primary roadway for the development. (Id.) Meanwhile, sti no noise measurements have been taken along the southern border of the two parcels on the Project site designated for the resort villa development identified as the Ritz -Carlton Residences (APN 689-330-026 and 689-330-028), which are directly adjacent to numerous private residences. Thus, the FMND has inexplicably declined to measure the ambient noise levels in the area adjacent to the most sensitive uses abutting the Project area, namely, numerous private residences. (Id.) Further, the City's Sept. 2025 Responses to Comments fail to further address this concern in any substantive way, and simply dismiss them in conclusory fashion. (Sept. 2025 Responses to Comments, pp. RTC -4 — RTC -5.) Based on the current land -uses proximate to this sensitive residential area, it is exceedingly likely that this zone at the southern edge of the proposed Project site would have the lowest ambient noise levels of any Project -adjacent area. In spite of these facts, however, the FMND continues to inaccurately claim that "The long-term noise level measurements were positioned as close to the nearest sensitive receiver locations as possible to assess the existing ambient hourly noise levels surrounding the project site." (FMND at p. 145.) The City's continuing failure and refusal to update the Project's noise studies to address these deficiencies is glaring, and the City's responses
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to comments fail to address the lack of study of the ambient noise levels at positions closest to the Project's nearby sensitive receptors. (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, pp. RTC -839 - 840.) The City cannot be permitted to shirk the performance of proper environmental analysis for the Project in order to conceal the Project's true impacts.
The FMND has then continued to use this faulty and incomplete ambient noise survey data to conclude that there will be no significant impact to the surrounding sensitive receptors from the Project's construction noise. In that regard, the FMND adopts the Criteria for Recommended Standard: Occupational Noise Exposure prepared by the National Institute for Occupational Safety and Health (NIOSH) as the threshold for whether the anticipated construction noise from the Project will have a significant impact upon the Project nearby sensitive receptors. (FMND at p. 149.) The FMND then concludes that the threshold of 85 dBA Leq qualifies as an "acceptable thresholdU for construction noise at the nearby sensitive receiver locations," and the "noise sensitive residential receiver locations will satisfy the 85 dBA Leq significance threshold," such that the Project will have a less than significant construction noise impact upon the sensitive receiver locations. (Id.)
WSRCC again reiterates that the NIOSH Occupational Noise Exposure standard has no proper place in evaluating the significance of construction noise impacts on nearby sensitive receptors. Rather, the NIOSH standard is aimed at protecting workers/laborers exposed to noise during the course job duties and preventing occupational harm/injury from occurring. It has no bearing upon external noise levels that would be suitable for maintaining the quiet enjoyment of an individual's private property. In that regard, the selection of 85 dBA Leq by the MND, RMND, and now the FMND as an acceptable threshold of significant construction noise impact is not only arbitrary, but it is also entirely unfounded.
The Federal Transit Administration's ("FTA") Transit Noise and Vibration Impact Assessment provides a superior source of federal regulatory authority regarding a project's noise impacts and their significance on sensitive receptors. To that end, the FTA guidance on noise level impacts notes that the impacts should be assessed as a function of their increase over existing noise exposure, and that any noise increase of 15 dBA or greater for a residence is considered a "severe impact." (See Exhibit D - FTA Transit Noise and Vibration Impact Assessment, pp. 17-18, 23-31.) The MND/RMND/FMND have arbitrarily elected to use the inapplicable NIOSH
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standard to assess the noise impacts of the Project, without considering the widely accepted guidance on noise impacts put forth by the FTA. This added lack of study and analysis enlarges the scope of the fair argument that the Project may have significant noise impacts on the environment.
Applying the FTA noise impact guidance, WSRCC maintains that the FMND's dBA estimates for anticipated Project -attributed construction noise exposure levels at the inadequately selected survey locations (L1, L2, and L3) still have the potential to exceed an FTA guidance -based threshold of "severe impact" and thereby cause a significant noise impact in the surrounding environment. (FMND at p. 146, Table 13- 2; compare FMND at p. 149, Table 13-3.) Indeed, comparison of the dBA values set forth in Table 13-2 and Table 13-3 confirm that the construction noise levels nearest to the vast majority of the Project's adjacent sensitive residential receptors are anticipated to increase by greater than 15 dBA from the ambient levels detected at L1, L2, and L3. (See id.) Put simply, after applying the FTA guidance to the FMND noise data, there is a fair argument that the Project will have a significant noise impact on nearby sensitive residential receptors.
Notwithstanding these demonstrable noise impacts posed by the Project, the FMND's only mitigation measure in this category pertains to vibration, requiring that large - loaded trucks and dozers not be used within 50 feet of the southern edge of the property line, substituting instead "small rubber -tired or alternative equipment...to reduce vibration effects." The mitigation measure, on its face, appears to address primarily vibration concerns, and would have little to no mitigating effect on the exposure of nearby sensitive receptors to overall project construction noise. Indeed, the southern border of the two parcels designated for the resort villa development identified as the Ritz -Carlton Residences (APN 689-330-026 and 689-330-028) are directly adjacent to numerous private residences.
As such, the FMND provides no tangible accommodation for the burden of construction noise exposure to be borne by the Project's adjacent residential properties. In cases where construction noise impacts are anticipated to affect nearby sensitive uses (i.e., residents, schools, hospitals, etc.) noise barriers are routinely implemented as a CEQA mitigation measure during construction in order to minimize the impingement on nearby residents' use and enjoyment of their property. The Project in this case necessitates, at a minimum, the same level of consideration and accommodation for the property owners adjacent to the Project site's southern edge.
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Currently, however, MM-NOI-1 makes no provision for the placement of noise barriers of any kind at any location, and the FMND and the City's responses to comments fail to advance any discussion or analysis as to why such measures would not be otherwise feasible and appropriate for the Project. The failure of the FMND to consider and incorporate the sensitive residential use into the scope of its noise mitigation measures is a critical deficiency that undermines any potential efficacy it may otherwise have in mitigating the Project's noise impacts, and the FMND's conclusion that the Project will have no significant noise impacts remains flawed and invalid for the reasons set forth at length above regarding the inadequate baseline study of these issues. Absent inclusion of an appropriate noise mitigation provision, the FMND remains legally inadequate as it cannot support a finding that the Project's noise impacts will not be significant.
The FMND's current lack of proper analysis and mitigation regarding construction noise impacts violates CEQA and warrants full environmental review via the preparation of an EIR. Alternatively, and at a minimum, the FMND must be further revised and supplemented to include noise mitigation measures that will in fact protect nearby residents from the impacts of the Project's construction noise. iv. Greenhouse Gas Emissions and Energy Use
The Project requires additional measures aimed at reducing operational GHG emissions and energy use that are not specified in the FMND. Specifically, the Project is slated to develop the second of two hotel buildings with 106 rooms and 499 vehicle parking spaces, yet the FMND still provides no specification or associated mitigation measures identifying how many or which of those parking spaces must be capable of supporting electric vehicle charging stations ("EVCS") and ready to be compliant with the 2022 Green Building Code ("GBC"). In fact, the FMND provides no specifics regarding any electric vehicle ("EV") accommodations to be constructed in connection with the Project. In its response to comments, the City takes the position that the Project is more akin to "commercial hotel use," such that the CARB Scoping Plan recommendations "are not appropriate." (See FMND, Appendix J, Responses to Comments, Response to Comment Letter O1, pp. RTC -841.) However, this position fails to consider, and is contradicted by, the fact that the Project, by its own proposed plans, identifies the new units to be built as "residences" and a "condominium project." (See FMND at pp. 41, 48.) Despite this legitimate concern, the FMND and the City's responses to comments fail to explain in any level of detail or provide any
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analysis as to how the "residences" and "condominium" units proposed by the Project would be utilized by their occupants in a manner that more resembles a "commercial hotel," and how those usage patterns would thereby alleviate the Project's obligations to comply with these aspects of the GBC. The City's responses to comments also still do not otherwise address whether any EVCS will be constructed in connection with the Project, and if so, how many.
The GBC, which became effective January 1, 2023, requires new buildings to designate 20% of the total number of parking spaces as EV-capable. See GBC
5.106.5.31. Therefore, if the Project develops 499 additional parking spaces, approximately 100 of those spaces must have electrical panel space and load capacity to support EV charging. Additionally, this must all be set forth in sufficient detail for the City and the public to thoroughly review, assess, and provide comments thereon.
Further, the GBC requires new buildings to designate 25% of the total number of EV-capable parking spaces as EV spaces with level 2 EV supply equipment ("EVSE"). Ibid. Hence, if the Project develops 499 additional parking spaces, 124 of those spaces must be equipped with a 208/240 volt 40 -ampere branch circuit with the electric vehicle charging connectors, attachment plugs, and all other fittings, devices, and power outlets installed. The GBC also requires that new residential construction with more than nine units be GPR certified at minimum 50 points, hold LEED Silver certification, or have Alternate Reference Standard per Section 101.10.2.
The foregoing analysis was entirely absent from the MND, was also not performed for the RMIND, and remains omitted from the FMND and the City's responses to comments, thereby exposing the inherent flaws in the FMND's conclusions that the Project's will have a "less than significant impact" with regard to (1) the Project's generation of GHG emissions, either directly or indirectly, that may have a significant impact on the environment, (2) the Project's conflict with an applicable plan, policy or 9 According to Section 101.10.2 of the GBC, Applicant may request to apply an alternate green building standard for the Project in lieu of the minimum standards per Table 101.10.
In making a determination in response to an application under this section, the Building Official may allow an alternate standard if they find that the proposed alternative standard complies with all of the following: (A) Addresses a comprehensive scope of green building issues including energy efficiency, water efficiency, resource efficient materials, and healthy building practices; (B) applies standards that are, when taken as a whole, as stringent as the GPR and LEED standards; (C) includes a formalized certification process that incorporates third party verification; and, (D) the project will advance the purposes of this Chapter. See Ord. 22-2245, part, 2022; Ord. 19-2193, §, 2 (part), 2019.
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regulation adopted for the purpose of reducing the emission of GHGs (e.g., the 2022 GBC), (3) the Project's potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during project operation, and (4) the Project's conflict with or obstruction of a state plan for renewable energy/energy efficiency. (See FMND, pp. 98, 111.) Indeed, the FMND states only in vague and inconclusive fashion that (1) the "project will be required to provide compliant . . . electric vehicle charging spaces" (pursuant to CAL Green Code §§
5.106.4, 5.106.5.2, and 5.106.5.3), and (2) "[t]he Project would provide EV charging infrastructure that, meets the California Green Building Standards Code," while simultaneously concluding without justification or analysis that the Project's use will be more akin to a commercial hotel than traditional residential housing. (See Appendix A to RMND at 64; see also FMND at 120.) Upon reaching this factually and legally unsupported conclusion regarding the Project's future use, the FMND and the City's responses to comments adhere to the flawed prior determination that the EVCS guidance set forth in Appendix D to CARB's 2022 Scoping Plan is therefore "not appropriate" for the Project, and the Project should be relieved of the residential development requirements for EVCS under the GCB. (FMND at 120; Sept. 2025 Responses to Comments, p. RTC -7.)
These alleged findings in the FMND and the City's later responses, and the grossly deficient information and analysis underpinning them, leave other stakeholder agencies and the general public with virtua y no ability to assess the adequacy of the EVCS measures to be implemented in connection with the Project, and the City's responses to comments do nothing to address these concerns. Under the current framework in the FMND, the Applicant could very well construct no EVCS's whatsoever in connection with the Project while proclaiming it has provided "compliant... electric vehicle charging spaces" and met the Green Building Standards Code. While the City's responses to comments on this issue contend that WSRCC is incorrect in this conclusion, those responses continue to decline to make any clear commitment to EVCS for the Project or explain how the Project's compliance with the GBC on this issue would result in any EVCS being implemented for the Project and approximately how many. (Sept. 2025 Responses to Comments, p. RTC -7.) The City's evasive responses and lack of commitment to inclusion of EVCS underscore that the Project has clear potential to result in significant impacts on the environment in the form of generating GHG emissions and conflict with the 2022 CARB Scoping Plan and the GBC.
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Additionally, the FMND and the City's responses to comments sti provide no comparative analysis of the energy use and GHG emissions impacts of the inclusion and operation of the EVCS infrastructure in the completed Project relative to the operational energy use and GHG emissions that would arise from the omission of the EVCS infrastructure from the project. As such, and absent revision of the Project to incorporate an impact analysis of the inclusion and omission of the EVCS infrastructure, the Project as currently proposed violates the 2022 GBC and therefore result in a potentially significant impact on the issue of GHG emissions. In that regard, an EIR for the Project is currently required to be prepared and circulated before any approval by the City can ultimately be granted.
In sum, allowing the Project to commence without consideration and analysis of the EVCS issue and its associated energy use and GHG emissions considerations would result in significant and unavoidable impacts on the local community and environment as well as on global climate change due to cumulative GHG emissions from vehicle exhaust. Further, the Project would be out of compliance with the 2022 GBC and could provoke extensive litigation and unnecessary turbulence for both the Applicant and the City.
v. Land Use and Planning
Each California city and county must adopt a comprehensive, long-term general plan governing development. Napa Citizens for Honest Gov. v. Napa County Bd, of Supervisors (2001) 91 Ca1.App.4th 342, 352, citing Gov. Code §§ 65030, 65300. The general plan sits at the top of the land use planning hierarchy and serves as a "constitution" or "charter" for all future development. DeVita v. County of Napa (1995) 9 Ca1.4th 763, 773; Lesher Communications, Inc. v. City of Walnut Creek (1990) 52 Ca1.3d 531, 540.
General plan consistency is "the linchpin of California's land use and development laws; it is the principle which infused the concept of planned growth with the force of law." Debottari v. Norco City Council (1985) 171 Ca1.App.3d 1204, 1213. It is well established that development projects may not be approved if they interfere with, or frustrate, the general plan's policies and objectives. See Napa Citizens, 91 Ca1.App.4th at 378-79; see also Lesher, 52 Ca1.3d at 544.
Here, the FMND continues to admit the Project's direct conflict with the land use consistency prescribed by the City's General plan, in that the Project continues to call for approximately 4.5 acres of dedicated Mountain Reserve Land to be re -zoned and
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re -purposed for Resort/Hotel use. (FMND at p. 139-140.) Despite that, the FMND then maintains the perfunctory conclusion that the proposed development's conflict with the existing land use plan will not have significant environmental impacts because of the biological resources mitigation measures already proposed in the FMND and the Project proposes to re -zone the existing Mountain Reserve lands. This conclusion is wholly unsupported, the analysis underpinning it is irreparably flawed, and the City's responses to comments wholly fail to dispose of this concern.
The FMND's rationale is misplaced and unsupported for purposes of CEQA analysis, as the City cannot properly justify the repurposing and destruction of natural reserve lands by claiming that its biological mitigation measures and its requested rezoning entitlement have already ameliorated any environmental impacts such that the land use impacts are "less than significant." By taking this position in the MND, RMND, and FMND, the City is acknowledging that, in fact, the re -zoning does have a significant impact that requires EIR review and substantial mitigation. Moreover, the City cannot permissibly conflate its mitigation measures aimed at limiting destruction of biological resources with preservation and/or creation of additional mountain reserve lands. Rather, the FMND cannot support a claim of no significant impact without the Project first creating protections for other comparable natural lands multiple times larger than the Mountain Reserve lands being targeted for development. Only then could the land use planning impacts of the development of the Mountain Reserve lands in question be properly mitigated to a less than significant level.
B. The City Must, at a Minimum, Further Revise and Recirculate the FMND.
Section 15073.5 of the CEQA Guidelines provides that a negative declaration must be recirculated whenever the document must be substantially revised. A substantial revision includes the identification of new, avoidable significant effects requiring mitigation measures or project revisions to be added to reduce the effect to less than significant levels or upon the agency determining that a proposed mitigation measure or project change would not reduce a potential impact to insignificance. Id.
Additionally, when new information is brought to light showing that an impact previously discussed in an MND and found to be insignificant with or without mitigation in the MND's analysis has the potential for a significant environmental impact supported by substantial evidence, the MND must consider and resolve the
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conflict in the evidence. See Visalia Retail, L.P. v. City of Visalia (2018) 20 Cal. App. 5th 1, 13, 17; see also Protect the Historic Amador Waterways v. Amador WaterAgency (2004) 116 Cal. App. 4th 1099, 1109.
Considering the FMND's ongoing failure to substantiate all of its findings, provide adequate mitigation measures, and fully analyze and assess all relevant factors as discussed in detail above, WSRCC reiterates that, at a minimum, the Project requires significant revisions and resolution of conflicts in evidence. Moreover, the FMND, which purports to have been prepared in December 2024, contains significant changes to the Project's proposed mitigation measures and adds incorporates new and additional impact studies in furtherance of the mitigation measures currently listed in the FMND. Meanwhile, and despite these significant changes, the City never circulated the FMND for further public review and comment, as required by CEQA. Therefore, even if the City refuses to prepare an EIR for the Project against WSRCC's objections, the City must at least further revise and recirculate the FMND if it does not prepare an EIR for the Project.
V. THE PROJECT APPLICATION MATERIALS MUST INCLUDE AN
ADEQUATE DESCRIPTION OF THE PROJECT.
A project description must be stable and finite in order to afford a lead agency and the public an adequate opportunity to assess and comment on the project and its impacts. "[A]n accurate, stable and finite project description is the sine qua non of an informative and legally sufficient" environmental document. County of Inyo v. City of Los Angeles (1977) 71 Ca1.App.3d 185, 200. "A curtailed or distorted project description may stultify the objectives of the reporting process" as an accurate, stable, and finite project description is necessary to allow "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 (i.e., the "no project" alternative) and weigh other alternatives in the balance. Ibid. at pp. 192-93.
CEQA Guidelines, § 15124 requires that a description describe the project in enough detail to allow for evaluation of its potential environmental impacts: (a) the project's precise location and boundaries; (b) a clearly written statement of objectives sought by the proposed project; (c) a description of the project's technical, economic, and environmental characteristics; and, (d) a statement describing a list of agencies, permits, and approval which the project expects to use.
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Here, WSRCC respectfully resubmits that the Project application must include an adequate and compliant Project description with the details listed above. Should the materials fail to comply with the CEQA Guidelines, the City should demand that the Applicant resubmit its application materials with CEQA-compliant parameters.
VI. CONCLUSION.
In sum, WSRCC reiterates its requests that the City require a local workforce, that the City impose training requirements for the Project's construction activities to prevent community spread of COVID-19 and other infectious diseases, and that the City prepare and circulate a thorough EIR for the Project or, at a minimum, further revise and recirculate the RMND for the Project to address the aforementioned concerns.
Should the City have any questions regarding this correspondence, please do not hesitate to contact our office.
Sincerely,
Jeremy Herwitt
Attorneys for Western States
Regional Council of Carpenters
Attached:
March 8, 2021, SWAPE Letter to Mitchell M. Tsai re Local Hire Requirements and Considerations for Greenhouse Gas Modeling (Exhibit A); Air Quality and GHG Expert Paul Rosenfeld CV (Exhibit B); Air Quality and GHG Expert Matt Hagemann CV (Exhibit C); FTA Transit Noise and Vibration Impact Assessment (Exhibit D); Coachella Valley Mountains Conservancy Territory Map (Exhibit E); and City of Rancho Mirage Land Use and Zoning Map (Exhibit F).
EXHIBIT A
SWAPE
Technical Consultation, Data Analysis and
Litigation Support for the Environment
2656 29th Street, Suite 201
Santa Monica, CA 90405
Matt Hagemann, P.G, C.Hg.
(949) 887-9013
[email protected]
Paul E. Rosenfeld, PhD
(310) 795-2335
[email protected]
March 8, 2021
Mitchell M. Tsai
155 South El Molino, Suite 104
Pasadena, CA 91101
Subject: Local Hire Requirements and Considerations for Greenhouse Gas Modeling Dear Mr. Tsai,
Soil Water Air Protection Enterprise ("SWAPE") is pleased to provide the following draft technical report explaining the significance of worker trips required for construction of land use development projects with respect to the estimation of greenhouse gas ("GHG") emissions. The report will also discuss the potential for local hire requirements to reduce the length of worker trips, and consequently, reduced or mitigate the potential GHG impacts.
Worker Trips and Greenhouse Gas Calculations
The California Emissions Estimator Model ("CaIEEMod") is a "statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions associated with both construction and operations from a variety of land use projects."1 CaIEEMod quantifies construction -related emissions associated with land use projects resulting from off -road construction equipment; on -road mobile equipment associated with workers, vendors, and hauling; fugitive dust associated with grading, demolition, truck loading, and on -road vehicles traveling along paved and unpaved roads; and architectural coating activities; and paving?
The number, length, and vehicle class of worker trips are utilized by CaIEEMod to calculate emissions associated with the on -road vehicle trips required to transport workers to and from the Project site during construction.3 "California Emissions Estimator Model." CAPCOA, 2017, available at: http://www.agmd.gov/caleemod/home . 2 "California Emissions Estimator Model." CAPCOA, 2017, available at: http://www.agmd.gov/caleemod/home . "CaIEEMod User's Guide." CAPCOA, November 2017, available at: http://www.acmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34. 1 Specifically, the number and length of vehicle trips is utilized to estimate the vehicle miles travelled ("VMT") associated with construction. Then, utilizing vehicle -class specific EMFAC 2014 emission factors, CaIEEMod calculates the vehicle exhaust, evaporative, and dust emissions resulting from construction -related VMT, including personal vehicles for worker commuting.'
Specifically, in order to calculate VMT, CaIEEMod multiplies the average daily trip rate by the average overall trip length (see excerpt below):
"VMTd = 1(Average Daily Trip Rate i * Average Overall Trip Length i) n Where:
n = Number of land uses being modeled."5
Furthermore, to calculate the on -road emissions associated with worker trips, CaIEEMod utilizes the following equation (see excerpt below):
"EmISSlonspollutant = VMT * EFrunning,pollutant
Where:
Emissionspollutant = emissions from vehicle running for each pollutant VMT = vehicle miles traveled
EFrunning,pollutant = emission factor for running emissions."6 Thus, there is a direct relationship between trip length and VMT, as well as a direct relationship between VMT and vehicle running emissions. In other words, when the trip length is increased, the VMT and vehicle running emissions increase as a result. Thus, vehicle running emissions can be reduced by decreasing the average overall trip length, by way of a local hire requirement or otherwise.
Default Worker Trip Parameters and Potential Local Hire Requirements As previously discussed, the number, length, and vehicle class of worker trips are utilized by CaIEEMod to calculate emissions associated with the on -road vehicle trips required to transport workers to and from the Project site during construction.' In order to understand how local hire requirements and associated worker trip length reductions impact GHG emissions calculations, it is important to consider the CaIEEMod default worker trip parameters. CaIEEMod provides recommended default values based on site -specific information, such as land use type, meteorological data, total lot acreage, project type and typical equipment associated with project type. If more specific project information is known, the user can change the default values and input project - specific values, but the California Environmental Quality Act ("CEQA") requires that such changes be justified by substantial evidence.' The default number of construction -related worker trips is calculated by multiplying the "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 14-15. 5 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at: http://www.aqmd.gov/docs/default- source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 23. 6 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at: http://www.agmd.gov/docs/default- source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 7 "CaIEEMod User's Guide." CAPCOA, November 2017, available at: http://www.agmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34. $ CaIEEMod User Guide, available at: http://www.caleemod.com/ , p. 1, 9. 2 number of pieces of equipment for all phases by 1.25, with the exception of worker trips required for the building construction and architectural coating phases.' Furthermore, the worker trip vehicle class is a 50/25/25 percent mix of light duty autos, light duty truck class 1 and light duty truck class 2, respectively."10 Finally, the default worker trip length is consistent with the length of the operational home -to -work vehicle trips.' The operational home -to -work vehicle trip lengths are:
"[B]ased on the location and urbanization selected on the project characteristic screen. These values were supplied by the air districts or use a default average for the state. Each district (or county) also assigns trip lengths for urban and rural settings" (emphasis added). 12 Thus, the default worker trip length is based on the location and urbanization level selected by the User when modeling emissions. The below table shows the CaIEEMod default rural and urban worker trip lengths by air basin (see excerpt below and Attachment A).13
Worker Trip Length by Air Basin
Air Basin
Rural (miles)
Urban (miles)
Great Basin Valleys
16.8 10.8
Lake County
16.8 10.8
Lake Tahoe
16.8 10.8
Mojave Desert
16.8 10.8
Mountain Counties
16.8 10.8
North Central Coast
17.1 12.3
North Coast
16.8 10.8
Northeast Plateau
16.8 10.8
Sacramento Valley
16.8 10.8
Salton Sea
14.6 11
San Diego
16.8 10.8
San Francisco Bay Area
10.8 10.8
San Joaquin Valley
16.8 10.8
South Central Coast
16.8 10.8
South Coast
19.8 14.7
Average
16.47 11.17
Minimum
10.80 10.80
Maximum
19.80 14.70
Range
9.00 3.90
"CaIEEMod User's Guide." CAPCOA, November 2017, available at: http://www.acmd.gov/docs/default- source/caleemod/01 user-39-s-guide2016-3-2 15november2017.pdf?sfvrsn=4, p. 34. 1° "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at:
http://www.acmd.gov/docs/default-source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 15. 11 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at:
http://www.acmd.gov/docs/default-source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 14. 12 "Appendix A Calculation Details for CaIEEMod." CAPCOA, October 2017, available at:
http://www.acmd.gov/docs/default-source/caleemod/02 appendix-a2016-3-2.pdf?sfvrsn=6, p. 21. 13 "Appendix D Default Data Tables." CAPCOA, October 2017, available at: http://www.acmd.gov/docs/default- source/caleemod/05 appendix-d2016-3-2.pdf?sfvrsn=4, p. D-84 — D-86. 3 As demonstrated above, default rural worker trip lengths for air basins in California vary from 10.8- to 19.8 - miles, with an average of 16.47 miles. Furthermore, default urban worker trip lengths vary from 10.8- to 14.7 - miles, with an average of 11.17 miles. Thus, while default worker trip lengths vary by location, default urban worker trip lengths tend to be shorter in length. Based on these trends evident in the CaIEEMod default worker trip lengths, we can reasonably assume that the efficacy of a local hire requirement is especially dependent upon the urbanization of the project site, as well as the project location.
Practical Application of a Local Hire Requirement and Associated Impact To provide an example of the potential impact of a local hire provision on construction -related GHG emissions, we estimated the significance of a local hire provision for the Village South Specific Plan ("Project") located in the City of Claremont ("City"). The Project proposed to construct 1,000 residential units, 100,000 -SF of retail space, 45,000 -SF of office space, as well as a 50 -room hotel, on the 24 -acre site. The Project location is classified as Urban and lies within the Los Angeles -South Coast County. As a result, the Project has a default worker trip length of 14.7 miles.14 In an effort to evaluate the potential for a local hire provision to reduce the Project's construction -related GHG emissions, we prepared an updated model, reducing all worker trip lengths to 10 miles (see Attachment B). Our analysis estimates that if a local hire provision with a 10 -mile radius were to be implemented, the GHG emissions associated with Project construction would decrease by approximately 17% (see table below and Attachment C).
Local Hire Provision Net Change
Without Local Hire Provision
Total Construction GHG Emissions (MT CO2e)
3,623
Amortized Construction GHG Emissions (MT CO2e/year)
120.77
With Local Hire Provision
Total Construction GHG Emissions (MT CO2e)
3,024
Amortized Construction GHG Emissions (MT CO2e/year)
Decrease in Construction -related GHG Emissions
100.80
17%
As demonstrated above, by implementing a local hire provision requiring 10 mile worker trip lengths, the Project could reduce potential GHG emissions associated with construction worker trips. More broadly, any local hire requirement that results in a decreased worker trip length from the default value has the potential to result in a reduction of construction -related GHG emissions, though the significance of the reduction would vary based on the location and urbanization level of the project site.
This serves as an example of the potential impacts of local hire requirements on estimated project -level GHG emissions, though it does not indicate that local hire requirements would result in reduced construction -related GHG emission for all projects. As previously described, the significance of a local hire requirement depends on the worker trip length enforced and the default worker trip length for the project's urbanization level and location.
i4 "Appendix D Default Data Tables." CAPCOA, October 2017, available at: http://www.acmd.gov/docs/default- source/caleemod/05 appendix-d2016-3-2.pdf?sfvrsn=4, p. D-85. 4 Disclaimer
SWAPE has received limited discovery. Additional information may become available in the future; thus, we retain the right to revise or amend this report when additional information becomes available. Our professional services have been performed using that degree of care and skill ordinarily exercised, under similar circumstances, by reputable environmental consultants practicing in this or similar localities at the time of service. No other warranty, expressed or implied, is made as to the scope of work, work methodologies and protocols, site conditions, analytical testing results, and findings presented. This report reflects efforts which were limited to information that was reasonably accessible at the time of the work, and may contain informational gaps, inconsistencies, or otherwise be incomplete due to the unavailability or uncertainty of information obtained or provided by third parties.
Sincerely,
Matt Hagemann, P.G., C.Hg.
Paul E. Rosenfeld, Ph.D.
5 Attachment A
Rural H -W Urban H -W
Location Type Location Name
(miles) (miles)
Air Basin Great Basin 16.8 10.8
Air Basin Lake County 16.8 10.8
Air Basin Lake Tahoe 16.8 10.8
Air Basin Mojave Desert 16.8 10.8
Air Basin Mountain 16.8 10.8
Air Basin North Central 17.1 12.3
Air Basin North Coast 16.8 10.8
Air Basin Northeast 16.8 10.8
Air Basin Sacramento 16.8 10.8
Air Basin Salton Sea 14.6 11
Air Basin San Diego 16.8 10.8
Air Basin San Francisco 10.8 10.8
Air Basin San Joaquin 16.8 10.8
Air Basin South Central 16.8 10.8
Air Basin South Coast 19.8 14.7
Air District Amador County 16.8 10.8
Air District Antelope Valley 16.8 10.8
Air District Bay Area AQMD 10.8 10.8
Air District Butte County 12.54 12.54
Air District Calaveras 16.8 10.8
Air District Colusa County 16.8 10.8
Air District El Dorado 16.8 10.8
Air District Feather River 16.8 10.8
Air District Glenn County 16.8 10.8
Air District Great Basin 16.8 10.8
Air District Imperial County 10.2 7.3
Air District Kern County 16.8 10.8
Air District Lake County 16.8 10.8
Air District Lassen County 16.8 10.8
Air District Mariposa 16.8 10.8
Air District Mendocino 16.8 10.8
Air District Modoc County 16.8 10.8
Air District Mojave Desert 16.8 10.8
Air District Monterey Bay 16.8 10.8
Air District North Coast 16.8 10.8
Air District Northern Sierra 16.8 10.8
Air District Northern 16.8 10.8
Air District Placer County 16.8 10.8
Air District Sacramento 15 10
Air District San Diego 16.8 10.8
Air District San Joaquin 16.8 10.8
Air District San Luis Obispo 13 13
Air District Santa Barbara 8.3 8.3
Air District Shasta County 16.8 10.8
Air District Siskiyou County 16.8 10.8
Air District South Coast 19.8 14.7
Air District Tehama County 16.8 10.8
Air District Tuolumne 16.8 10.8
Air District Ventura County 16.8 10.8
Air District Yolo/Solano 15 10
County Alameda 10.8 10.8
County Alpine 16.8 10.8
County Amador 16.8 10.8
County Butte 12.54 12.54
County Calaveras 16.8 10.8
County Colusa 16.8 10.8
County Contra Costa 10.8 10.8
County Del Norte 16.8 10.8
County El Dorado -Lake 16.8 10.8
County El Dorado- 16.8 10.8
County Fresno 16.8 10.8
County Glenn 16.8 10.8
County Humboldt 16.8 10.8
County Imperial 10.2 7.3
County I nyo 16.8 10.8
County Kern -Mojave 16.8 10.8
County Kern -San 16.8 10.8
County Kings 16.8 10.8
County Lake 16.8 10.8
County Lassen 16.8 10.8
County Los Angeles- 16.8 10.8
County Los Angeles- 19.8 14.7
County Madera 16.8 10.8
County Marin 10.8 10.8
County Mariposa 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Mendocino- 16.8 10.8
County Merced 16.8 10.8
County Modoc 16.8 10.8
County Mono 16.8 10.8
County Monterey 16.8 10.8
County Napa 10.8 10.8
County Nevada 16.8 10.8
County Orange 19.8 14.7
County Placer -Lake 16.8 10.8
County Placer -Mountain 16.8 10.8
County Placer- 16.8 10.8
County Plumas 16.8 10.8
County Riverside- 16.8 10.8
County Riverside- 19.8 14.7
County Riverside -Salton 14.6 11
County Riverside -South 19.8 14.7
County Sacramento 15 10
County San Benito 16.8 10.8
County San Bernardino- 16.8 10.8
County San Bernardino- 19.8 14.7
County San Diego 16.8 10.8
County San Francisco 10.8 10.8
County San Joaquin 16.8 10.8
County San Luis Obispo 13 13
County San Mateo 10.8 10.8
County Santa Barbara- 8.3 8.3
County Santa Barbara- 8.3 8.3
County Santa Clara 10.8 10.8
County Santa Cruz 16.8 10.8
County Shasta 16.8 10.8
County Sierra 16.8 10.8
County Siskiyou 16.8 10.8
County Solano- 15 10
County Solano-San 16.8 10.8
County Sonoma -North 16.8 10.8
County Sonoma -San 10.8 10.8
County Stanislaus 16.8 10.8
County Sutter 16.8 10.8
County Tehama 16.8 10.8
County Trinity 16.8 10.8
County Tulare 16.8 10.8
County Tuolumne 16.8 10.8
County Ventura 16.8 10.8
County Yolo 15 10
County Yuba 16.8 10.8
Statewide Statewide 16.8 10.8
Worker Trip Length by Air Basin
Air Basin
Rural (miles)
Urban (miles)
Great Basin Valleys
16.8 10.8
Lake County
16.8 10.8
Lake Tahoe
16.8 10.8
Mojave Desert
16.8 10.8
Mountain Counties
16.8 10.8
North Central Coast
17.1 12.3
North Coast
16.8 10.8
Northeast Plateau
16.8 10.8
Sacramento Valley
16.8 10.8
Salton Sea
14.6 11
San Diego
16.8 10.8
San Francisco Bay Area
10.8 10.8
San Joaquin Valley
16.8 10.8
South Central Coast
16.8 10.8
South Coast
19.8 14.7
Average
16.47 11.17
Mininum
10.80 10.80
Maximum
19.80 14.70
Range
9.00 3.90
Attachment B
CaIEEMod Version: CaIEEMod.2016.3.2
1.0 Project Characteristics
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual Village South Specific Plan (Proposed)
Los Angeles -South Coast County, Annual
1.1 Land Usage
Land Uses
Size
Metric
Lot Acreage
Floor Surface Area
Population
General Office Building
High Turnover (Sit Down Restaurant)
Hotel
Quality Restaurant
Apartments Low Rise
Apartments Mid Rise
Regional Shopping Center
4 •
45.00 36.00
50.00 8.00
25.00 975.00
56.00 1000sgft
1000sgft
Room
1000sgft
Dwelling Unit
•
•
•
T
•
Dwelling Unit
1.03 0.83
1.67 45,000.00
36,000.00
0 0
72,600.00 0
0.18 8,000.00 0
1.56 25,000.00 72
j s r
25.66 975,000.00 i 2789
1 T T -
1000sgft 1.29
56,000.00 0
1.2 Other Project Characteristics
Urbanization Urban
Climate Zone 9
Utility Company Southern California Edison
CO2 Intensity 702.44
(Ib/MWhr)
Wind Speed (m/s) 2.2
CH4 Intensity
(Ib/MWhr)
1.3 User Entered Comments & Non -Default Data
0.029
Precipitation Freq (Days) 33
Operational Year 2028
N2O Intensity
(Ib/MWhr)
0.006
CaIEEMod Version: CaIEEMod.2016.3.2
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual Project Characteristics - Consistent with the DEIR's model.
Land Use - See SWAPE comment regarding residential and retail land uses.
Construction Phase - See SWAPE comment regarding individual construction phase lengths.
Demolition - Consistent with the DEIR's model. See SWAPE comment regarding demolition.
Vehicle Trips - Saturday trips consistent with the DEIR's model. See SWAPE comment regarding weekday and Sunday trips.
Woodstoves - Woodstoves and wood -burning fireplaces consistent with the DEIR's model. See SWAPE comment regarding gas fireplaces.
Energy Use
Construction Off -road Equipment Mitigation - See SWAPE comment on construction -related mitigation.
Area Mitigation - See SWAPE comment regarding operational mitigation measures.
Water Mitigation - See SWAPE comment regarding operational mitigation measures.
Table Name
Column Name
Default Value
New Value
tblFireplaces
tblFireplaces
tblFireplaces
tblFireplaces
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
• FireplaceWoodMass • 1,019.20 0.00
FireplaceWoodMass • 1,019.20 0.00
r
NumberWood 1.25 f 0.00
NumberWood r 48.75 0.00
ST_TR • 7.16 6.17
r
•
ST_TR 6.39 E 3.87
ST_TR • 2.46 1.39
ST_TR 158.37 79.82
ST_TR 8.19 3.75
ST_TR • 94.36 63.99
r
ST_TR 49.97 10.74
Y
SU_TR 6.07 6.16
SU TR • 5.86 f 4.18
i
SU TR •r 1.05 i 0.69
i
-4
SU_TR • 131.84 78.27
CalEEMod Version: CalEEMod.2016.3.2
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual Date: 1/6/2021 1:52 PM
tblVehicleTrips SU_TR
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblVehicleTrips
tblWoodstoves
tblWoodstoves
tblWoodstoves
tblWoodstoves
tblWoodstoves
tblWoodstoves
tblWoodstoves
tblWoodstoves
4 Y
•
•
•
•
•
•
•
•
•
Y
•
•
•
•
•
•
•
Y
•
•
•
•
Y
•
•
SU_TR
SU_TR
WD_TR
WD_TR
WD_TR
WD_TR
WD_TR
WD_TR
WD_TR
NumberCatalytic
NumberCatalytic
NumberNoncatalytic
NumberNoncatalytic
WoodstoveDayYear
WoodstoveDayYear
WoodstoveWoodMass
WoodstoveWoodMass
4 •
•
•
•
•
•
•
Y
•
•
5.95 72.16
25.24 6.59
6.65 11.03
127.15
8.17 89.95
42.70 1.25
48.75 1.25
48.75 25.00
25.00 999.60
i
4 i
1i
i
i
4 1i
i
4 1i
1e
i
1•
4 4
3.20 57.65
6.39 5.83
4.13 6.41
65.80 3.84
62.64 9.43
0.00 0.00
0.00 0.00
0.00 0.00
0.00 999.60 0.00
2.0 Emissions Summary
CalEEMod Version: CalEEMod.2016.3.2 Page 4 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
2.1 Overall Construction
Unmitigated Construction
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
tons/yr
MT/yr
2021 0.1713 • 1.8242 • 1.1662 • 2.4000e- • 0.4169
003
2022 0.6904 • ▪ 4.1142 • ▪ 6.1625 • ▪ 0.0189 • ▪ 1.3058 MI
2023 0.6148 • 3.3649 • 5.6747 • 0.0178 • 1.1963
2024 •• 4.1619 • 0.1335 • 0.2810 • 5.9000e- • 0.0325
004
0.0817 • 0.4986 • 0.1795 • 0.0754
0.1201 • • 1.4259 • 0.3460 • • 0.1128 • 0.4588
r
0.0996 • • 1.2959 • 0.3203 • • 0.0935 •
6.4700e- • • 0.0390 • 8.6300e- • • 6.0400e- •
003 003 003
0.2549
0.4138
0.0147
0.0000
0.0000
0.0000
0.0000
213.1969 • 213.1969
0.0601
•
1,721.682 • 1,721.682 • • 0.1294 • 0.0000 • 1,724.918
6 6 7
1,627.529 • 1,627.529 • • 0.1185 • 0.0000 • 1,630.492
5 5 5
•
52.9078 • 52.9078 • • 8.0200e- • 0.0000 • 53.1082
• 003 •
0.0000 214.6993
Maximum I 4.1619
4.1142
6.1625
0.0189
1.3058
0.1201
1.4259
0.3460
0.1128
0.4588
0.0000
1,721.682
6 1,721.682
6 0.1294
0.0000
1,724.918
7 CalEEMod Version: CalEEMod.2016.3.2 Page 5 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
2.1 Overall Construction
Mitigated Construction
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Year
tons/yr
MT/yr
2021 0.1713 • 1.8242 • 1.1662 • 2.4000e- • 0.4169
003
2022 0.6904 • ▪ 4.1142 • ▪ 6.1625 • ▪ 0.0189 • ▪ 1.3058 MI
2023 0.6148 • 3.3648 • 5.6747 • 0.0178 • 1.1963
2024 •• 4.1619 • 0.1335 • 0.2810 • 5.9000e- • 0.0325
004
Maximum
•
•
0.0817 : 0.4986
0.1201 • ▪ 1.4259
0.0996 • ▪ 1.2959
6.4700e- • 0.0390 •
003 •
0.1795
• 0.0754 •
0.3460 • ▪ 0.1128 •
0.3203 • ▪ 0.0935 •
8.6300e- • ▪ 6.0400e- •
003 003
0.2549
0.4588
0.4138
0.0147
0.0000
0.0000
0.0000
0.0000
213.1967 : 213.1967 •
0.0601
,
1,721.682 • 1,721.682 • 0.1294 • 0.0000 • 1,724.918
3 3 3
1,627.529 • 1,627.529 • ▪ 0.1185 • 0.0000 • 1,630.492
1 1 1
,
0.0000
214.6991
52.9077 • 52.9077 • 8.0200e- • 0.0000 • 53.1082
• 003
4.1142
6.1625
0.0189
1.3058
0.1201
1.4259
0.3460
0.1128
0.4588
0.0000
1,721.682
3 1,721.682
3 0.1294
0.0000
1,724.918
3 ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
Quarter
Start Date
End Date
Maximum Unmitigated ROG + NOX (tons/quarter)
Maximum Mitigated ROG + NOX (tons/quarter)
1 9-1-2021
11-30-2021
1.4103
1.4103
2 12-1-2021
2-28-2022
1.3613
1.3613
3 3-1-2022
5-31-2022
1.1985
1.1985
4 6-1-2022
8-31-2022
1.1921
1.1921
5 9-1-2022
11-30-2022
1.1918
1.1918
6 12-1-2022
2-28-2023
1.0774
1.0774
7 3-1-2023
5-31-2023
1.0320
1.0320
8 6-1-2023
8-31-2023
1.0260
1.0260
CalEEMod Version: CalEEMod.2016.3.2
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual Date: 1/6/2021 1:52 PM
9 9-1-2023
11-30-2023
1.0265
1.0265
10 12-1-2023
2-29-2024
2.8857
2.8857
11 3-1-2024
5-31-2024
1.6207
1.6207
Highest
2.8857
2.8857
2.2 Overall Operational
Unmitigated Operational
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
.
Area
. 5.1437 • 0.2950 . 10.3804 • 1.6700e- 0.0714 0.0714 0.0714 0.0714 i 0.0000 220.9670 220.9670 0.0201 3.7400e- 222.5835 003 003
S.
r * ,
Energy
. 0.1398 • 1.2312 . 0.7770 • 7.6200e- • • 0.0966 • 0.0966 . • 0.0966 • 0.0966 0.0000 • 3,896.073 . 3,896.073 • 0.1303 . 0.0468 ? 3,913.283 003 2 2 3
Mobile
. 1.5857 • 7.9962 . 19.1834 • 0.0821 • 7.7979 • 0.0580 • 7.8559 . 2.0895 • 0.0539 T 2.1434 0.0000 • 7,620.498 . 7,620.498 • 0.3407 . 0.0000 T 7,629.016 6 6 : ; 2
r * ,
Waste
: 0.0000 : 0.0000 : : 0.0000 : 0.0000 207.8079 : 0.0000 : 207.8079 : 12.2811 : 0.0000 ? 514.8354 Water
:
0.0000 :
0.0000
: :
0.0000
T 0.0000 1 29.1632 :
556.6420
: 585.8052 :
3.0183
: 0.0755 T 683.7567
Total
6.8692
9.5223
30.3407
0.0914
7.7979
0.2260
8.0240
2.0895
0.2219
2.3114
236.9712
12,294.18
12,531.15
15.7904
0.1260
12,963.47
II
07 19
51 CaIEEMod Version: CaIEEMod.2016.3.2 Page 7 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
2.2 Overall Operational
Mitigated Operational
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5 Bio- CO2
Total
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Area
Energy
Mobile
Waste
Water
MI
•
MI
MI
•
M▪ I
MI
5.1437
0.1398
1.5857
0.2950 : 10.3804 : 1.6700e-
003
▪ 1.2312 . ▪ 0.7770 • ▪ 7.6200e-
003
7.9962 . ▪ 19.1834 I 0.0821 • 7.7979 •
0.0714
0.0966
0.0580
0.0000
0.0000
0.0714
0.0966
7.8559
0.0000
0.0000
2.0895
0.0714
0.0966
0.0539
0.0000
0.0000
0.0714 i 0.0000
0.0966 A 0.0000
2.1434 + 0.0000
0.0000
207.8079
0.0000 s 29.1632
220.9670 220.9670 • 0.0201 3.7400e- • 222.5835
003
3,896.073 3,896.073 ' • 0.1303 0.0468 T 3,913.283
2 2 3
7,620.498 7,620.498 • • 0.3407 0.0000 T 7,629.016
6 6 2
0.0000 207.8079 I • 12.2811 i 0.0000 T 514.8354
556.6420 585.8052 • • 3.0183 ' 0.0755 ? 683.7567
Total
Il 6.8692
9.5223
30.3407
0.0914
7.7979
0.2260
8.0240
2.0895
0.2219
2.3114
236.9712
12,294.18
07 12,531.15
19 15.7904
0.1260
12,963.47
51 ROG
NOx
CO
SO2
Fug'tive
PM10
Exhaust
PM10
PM10
Total
Fug'tive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio-CO2
Total CO2
CH4
N20
CO2e
Percent
Reduction
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
0.00 0.00
3.0 Construction Detail
Construction Phase
CaIEEMod Version: CaIEEMod.2016.3.2
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual Date: 1/6/2021 1:52 PM
Phase
Number
Phase Name
Phase Type
Start Date
End Date
Num Days
Week
Num Days
Phase Description
:Demolition
2 :Site Preparation
3 -Grading
:Demolition
:Site Preparation
:9/1/2021
10/13/2021
10/12/2021
:11/9/2021
Grading •11/10/2021 :1/11/2022
4 5'
5'
4 5'
30:
207,
45:
4 4 t
4 :Building Construction :Building Construction !1/12/2022 :12/12/2023 , 5: 500:
i 4 i 4 t
5 :Paving :Paving :•12/13/2023 :1 /30/2024 : 5: 35
} 4- +- I- r I- I
6 :Architectural Coating :Architectural Coating '1/31/2024 '3/19/2024 5: 35:
Acres of Grading (Site Preparation Phase): 0
Acres of Grading (Grading Phase): 112.5
Acres of Paving: 0
Residential Indoor: 2,025,000; Residential Outdoor: 675,000; Non -Residential Indoor: 326,400; Non -Residential Outdoor: 108,800; Striped Parking Area: 0 (Architectural Coating — sqft)
OffRoad Equipment
CalEEMod Version: CalEEMod.2016.3.2
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual Date: 1/6/2021 1:52 PM
Phase Name
Offroad Equipment Type
Amount
Usage Hours
Horse Power
Load Factor
Demolition :Concrete/Industrial Saws : 1 8.00:
I I a I.
Demolition :Excavators 3 8.00'
I , F
Demolition :Rubber Tired Dozers 2 8.00
: F
Site Preparation :Rubber Tired Dozers 3 8.00' 247
: I , F
Site Preparation •Tractors/Loaders/Backhoes : 4 8.00
: I a
Grading
81:
158:
247:
Grading
:Excavators
: Graders
Grading :Rubber Tired Dozers
Grading
: Scrapers
Grading :Tractors/Loaders/Backhoes
Building Construction
Building Construction
Building Construction
Building Construction
Building Construction
Paving
Paving
Paving
: Cranes
:Forklifts
: Generator Sets
2 2
2 a
1 3�
1-I
a
:Tractors/Loaders/Backhoes : 3
Welders
• Pavers : 2
:Paving Equipment 2
1�
:Rollers
Architectural Coating :Air Compressors
a
0.73 0.38
0.40 0.40
97: 0.37
8.00' 158: 0.38
8.00' 187: 0.41
8.00' 247: 0.40
8.00' 367;
8.00 7.00
8.00'
8.00'
7.00'
8.00'
8.00'
8.00 a F
2 8.00
1:
4-
6.00 0.48
97: 0.37
231: 0.29
89: 0.20
84: 0.74
97: 0.37
46: 0.45
130: 0.42
132'
0.36 80: 0.38
78: 0.48
Trips and VMT
CaIEEMod Version: CaIEEMod.2016.3.2
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual Date: 1/6/2021 1:52 PM
Phase Name
Offroad Equipment
Count
Worker Trip
Number
Vendor Trip
Number
Hauling Trip
Number
Worker Trip
Length
Vendor Trip
Length
Hauling Trip
Length
Worker Vehicle
Class
Vendor
Vehicle Class
Hauling
Vehicle Class
Demolition 6: 15.00' 0.00 i 458.00' 14.70: 6.90' 20.00' LD_Mix i HDT_Mix 'HHDT �- : -I 4 I
Site Preparation 7' 18.00' 0.00 i 0.00' 14.70: 6.90: 20.00: LD_Mix ' HDT_Mix ! HHDT Grading 8' 20.00' 0.001 0.00'- - 14.70: 6.90' 20.00: LD_Mix :HDT_Mix 'HHDT ' r
Building Construction : 91- 801.00' 143.00 i 0.00' - 14.70: 6.90: 20.00! LD_Mix : HDT_Mix : HHDT . ' I I I. ----------I I
Paving • 6' 15.00' 0.00: 0.00'- 14.70: 6.90: 20.00: LD_Mix : HDT_Mix : HHDT • + + I- a- +- 4
Architectural Coating
1: 160.00' 0.00' 0.00' 14.70' 6.90' 20.00' LD_Mix ' HDT_Mix ' HHDT
3.1 Mitigation Measures Construction
3.2 Demolition - 2021
Unmitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust •
. 0.0496 . 0.0000 ' 0.0496 ' 7.5100e- ' 0.0000 ' 7.5100e- ' 0.0000
0.0000 • 0.0000 ' 0.0000 ' 0.0000 ' 0.0000
003 : 003
:
T l l 1 l l l 7 l *
l , ,
Off -Road
. 0.0475 • 0.4716 • 0.3235 • 5.8000e- • . 0.0233 ' 0.0233 • . 0.0216 • 0.0216 i 0.0000
51.0012 . 51.0012 • 0.0144 • 0.0000 ? 51.3601
004
Total
0.0475
0.4716
0.3235
5.8000e-
0.0496
0.0233
0.0729
7.5100e-
0.0216
0.0291
0.0000
51.0012
51.0012
0.0144
0.0000
51.3601
II
004
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 11 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.2 Demolition - 2021
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling •.
1.9300e- • 0.0634 • 0.0148 . 1.8000e- . 3.9400e- . 1.9000e- • 4.1300e- • 1.0800e- . 1.8000e- • 1.2600e- ; 0.0000
17.4566 • 17.4566 • 1.2100e- • 0.0000 . 17.4869
003 004 003 004 003 003 004 003
003
r
Vendor
. 0.0000 : 0.0000 : 0.0000 . 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 } 0.0000
0.0000 . 0.0000 : 0.0000 : 0.0000 ? 0.0000
r
Worker •.
9.7000e- • 7.5000e- • 8.5100e- . 2.0000e- . 2.4700e- . 2.0000e- • 2.4900e- • 6.5000e- . 2.0000e- • 6.7000e- ; 0.0000
2.2251 , 2.2251 • 7.0000e- • 0.0000
004
004
003
005
003
005
003
004
005
004
005
Total
2.9000e-
0.0641
0.0233
2.0000e-
6.4100e-
2.1000e-
6.6200e-
1.7300e-
2.0000e-
1.9300e-
0.0000
19.6816
19.6816
1.2800e-
0.0000
19.7136
II
003
004
003
004
003
003
004
003
003
Mitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust • • 0.0496 • 0.0000 • 0.0496 • 7.5100e- • 0.0000 • 7.5100e- ; 0.0000 • 0.0000 • 0.0000 • 0.0000 • 0.0000 • 0.0000
003 003
E
.. 7 7 4 7 1 4 7 4 T 1
d
7 4 7 T
Off -Road •. 0.0475 • 0.4716 • 0.3235 • 5.8000e- • • 0.0233 • 0.0233 • • 0.0216 • 0.0216 ; 0.0000 • 51.0011 • 51.0011 • 0.0144 • 0.0000 • 51.3600 004 :
Z
Total
0.0475
0.4716
0.3235
5.8000e-
0.0496
0.0233
0.0729
7.5100e-
0.0216
0.0291
0.0000
51.0011
51.0011
0.0144
0.0000
51.3600
004
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 12 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.2 Demolition - 2021
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling •.
1.9300e- • 0.0634 • 0.0148 . 1.8000e- . 3.9400e- . 1.9000e- • 4.1300e- • 1.0800e- . 1.8000e- • 1.2600e- ; 0.0000
17.4566 • 17.4566 • 1.2100e- • 0.0000 . 17.4869
003 004 003 004 003 003 004 003
003
7. r
Vendor
0.0000 : 0.0000 : 0.0000 . 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 . 0.0000 : 0.0000 : 0.0000 ? 0.0000
r
Worker •.
9.7000e- • 7.5000e- • 8.5100e- . 2.0000e- . 2.4700e- . 2.0000e- • 2.4900e- , 6.5000e- . 2.0000e- • 6.7000e- ; 0.0000
2.2251 , 2.2251 • 7.0000e- • 0.0000
004
004
003
005
003
005
003
004
005
004
005
Total
2.9000e-
0.0641
0.0233
2.0000e-
6.4100e-
2.1000e-
6.6200e-
1.7300e-
2.0000e-
1.9300e-
0.0000
19.6816
19.6816
1.2800e-
0.0000
19.7136
II
003
004
003
004
003
003
004
003
003
3.3 Site Preparation - 2021
Unmitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust : 0.1807 : 0.0000 : 0.1807 : 0.0993 : 0.0000 : 0.0993 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
f. 7 7 1 7 7 7 1 T 1
7 1 7 T
Off -Road •. 0.0389 • 0.4050 • 0.2115 • 3.8000e- • • 0.0204 • 0.0204 • • 0.0188 • 0.0188 ; 0.0000 • 33.4357 • 33.4357 • 0.0108 • 0.0000 • 33.7061 004 :
Z
A
Total
0.0389
0.4050
0.2115
3.8000e-
0.1807
0.0204
0.2011
0.0993
0.0188
0.1181
0.0000
33.4357
33.4357
0.0108
0.0000
33.7061
004
CaIEEMod Version: CaIEEMod.2016.3.2 Page 13 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.3 Site Preparation - 2021
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
7,
r
Vendor
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 ; 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker •,
7.7000e- • 6.0000e- , 6.8100e- , 2.0000e- , 1.9700e- , 2.0000e- • 1.9900e- , 5.2000e- , 1.0000e- • 5.4000e- ; 0.0000
1.7801 , 1.7801 • 5.0000e- • 0.0000
004
004
003
005
003
005
003
004
005
004
005
Total
7.7000e-
6.0000e-
6.8100e-
2.0000e-
1.9700e-
2.0000e-
1.9900e-
5.2000e-
1.0000e-
5.4000e-
0.0000
1.7801
1.7801
5.0000e-
0.0000
1.7814
II
004
004
003
005
003
005
003
004
005
004
005
Mitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust : 0.1807 : 0.0000 : 0.1807 : 0.0993 : 0.0000 : 0.0993 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
f. 7 7 1 7 7 1 -r 1
7 -1 7 T
Off -Road •, 0.0389 • 0.4050 • 0.2115 • 3.8000e- • , 0.0204 • 0.0204 • , 0.0188 • 0.0188 ; 0.0000 • 33.4357 • 33.4357 • 0.0108 • 0.0000 , 33.7060 004 :
Z
A
Total
0.0389
0.4050
0.2115
3.8000e-
0.1807
0.0204
0.2011
0.0993
0.0188
0.1181
0.0000
33.4357
33.4357
0.0108
0.0000
33.7060
004
CaIEEMod Version: CaIEEMod.2016.3.2 Page 14 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.3 Site Preparation - 2021
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
r
Vendor
, 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker •,
7.7000e- • 6.0000e- , 6.8100e- , 2.0000e- , 1.9700e- , 2.0000e- • 1.9900e- • 5.2000e- , 1.0000e- • 5.4000e- ; 0.0000
1.7801 , 1.7801 • 5.0000e- , 0.0000
004
004
003
005
003
005
003
004
005
004
005
Total
7.7000e-
6.0000e-
6.8100e-
2.0000e-
1.9700e-
2.0000e-
1.9900e-
5.2000e-
1.0000e-
5.4000e-
0.0000
1.7801
1.7801
5.0000e-
0.0000
1.7814
II
004
004
003
005
003
005
003
004
005
004
005
3.4 Grading - 2021
Unmitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust : 0.1741 : 0.0000 : 0.1741 : 0.0693 : 0.0000 : 0.0693 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
.. 7 t 1 7 1 7 1 T 1
d
7 1 7 T
Off -Road •, 0.0796 • 0.8816 • 0.5867 • 1.1800e- • • 0.0377 • 0.0377 • • 0.0347 • 0.0347 7 0.0000 • 103.5405 • 103.5405 • 0.0335 • 0.0000 • 104.3776 003 :
Z
A
Total
0.0796
0.8816
0.5867
1.1800e-
0.1741
0.0377
0.2118
0.0693
0.0347
0.1040
0.0000
103.5405
103.5405
0.0335
0.0000
104.3776
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 15 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.4 Grading - 2021
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
r
Vendor
, 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
,-
Worker •,
1.6400e- • 1.2700e- , 0.0144 , 4.0000e- , 4.1600e- , 3.0000e- • 4.2000e- • 1.1100e- , 3.0000e- • 1.1400e- ; 0.0000
3.7579 , 3.7579 • 1.1000e- , 0.0000
003
003
005
003
005
003
003
005
003
004
Total
1.6400e-
1.2700e-
0.0144
4.0000e-
4.1600e-
3.0000e-
4.2000e-
1.1100e-
3.0000e-
1.1400e-
0.0000
3.7579
3.7579
1.1000e-
0.0000
3.7607
II
003
003
005
003
005
003
003
005
003
004
Mitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust : 0.1741 : 0.0000 : 0.1741 : 0.0693 : 0.0000 : 0.0693 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
.. 7 t 1 7 1 7 1 T 1
d
7 1 7 T
Off -Road •, 0.0796 • 0.8816 • 0.5867 • 1.1800e- • , 0.0377 • 0.0377 • , 0.0347 • 0.0347 7 0.0000 • 103.5403 • 103.5403 • 0.0335 • 0.0000 , 104.3775 003 :
Z
A
Total
0.0796
0.8816
0.5867
1.1800e-
0.1741
0.0377
0.2118
0.0693
0.0347
0.1040
0.0000
103.5403
103.5403
0.0335
0.0000
104.3775
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 16 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.4 Grading - 2021
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
r
Vendor
, 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
,-
Worker •,
1.6400e- • 1.2700e- , 0.0144 , 4.0000e- , 4.1600e- , 3.0000e- • 4.2000e- • 1.1100e- , 3.0000e- • 1.1400e- ; 0.0000
3.7579 , 3.7579 • 1.1000e- , 0.0000
003
003
005
003
005
003
003
005
003
004
Total
1.6400e-
1.2700e-
0.0144
4.0000e-
4.1600e-
3.0000e-
4.2000e-
1.1100e-
3.0000e-
1.1400e-
0.0000
3.7579
3.7579
1.1000e-
0.0000
3.7607
II
003
003
005
003
005
003
003
005
003
004
3.4 Grading - 2022
Unmitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust : 0.0807 : 0.0000 : 0.0807 : 0.0180 : 0.0000 : 0.0180 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
.. 7 t 1 7 7 1 T 1
d
7 1 7 T
Off -Road •, 0.0127 • 0.1360 • 0.1017 • 2.2000e- • , 5.7200e- • 5.7200e- • , 5.2600e- • 5.2600e- ; 0.0000 • 19.0871 • 19.0871 • 6.1700e- • 0.0000 , 19.2414 004 ; ; 003 ; 003 ; ; 003 ; 003
Z ; ; 003 ;
A
Total
0.0127
0.1360
0.1017
2.2000e-
0.0807
5.7200e-
0.0865
0.0180
5.2600e-
0.0233
0.0000
19.0871
19.0871
6.1700e-
0.0000
19.2414
004
003
003
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 17 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.4 Grading - 2022
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
r
Vendor
, 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker •,
2.8000e- • 2.1000e- , 2.4400e- , 1.0000e- , 7.7000e- , 1.0000e- • 7.7000e- , 2.0000e- , 1.0000e- • 2.1000e- ; 0.0000
0.6679 , 0.6679 • 2.0000e- , 0.0000
004
004
003
005
004
005
004
004
005
004
005
Total
2.8000e-
2.1000e-
2.4400e-
1.0000e-
7.7000e-
1.0000e-
7.7000e-
2.0000e-
1.0000e-
2.1000e-
0.0000
0.6679
0.6679
2.0000e-
0.0000
0.6684
II
004
004
003
005
004
005
004
004
005
004
005
Mitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Fugitive Dust : 0.0807 : 0.0000 : 0.0807 : 0.0180 : 0.0000 : 0.0180 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
.. 7 t 1 7 7 1 T 1
d
7 1 7 T
Off -Road •, 0.0127 • 0.1360 • 0.1017 • 2.2000e- • • 5.7200e- • 5.7200e- • • 5.2600e- • 5.2600e- ; 0.0000 • 19.0871 • 19.0871 • 6.1700e- • 0.0000 • 19.2414 004 ; ; 003 ; 003 ; ; 003 ; 003
Z ; ; 003 ;
A
Total
0.0127
0.1360
0.1017
2.2000e-
0.0807
5.7200e-
0.0865
0.0180
5.2600e-
0.0233
0.0000
19.0871
19.0871
6.1700e-
0.0000
19.2414
004
003
003
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 18 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.4 Grading - 2022
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling
, 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
r
Vendor .,
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker •,
2.8000e- • 2.1000e- , 2.4400e- , 1.0000e- , 7.7000e- , 1.0000e- • 7.7000e- , 2.0000e- , 1.0000e- • 2.1000e- ; 0.0000
0.6679 , 0.6679 • 2.0000e- , 0.0000
004
004
003
005
004
005
004
004
005
004
005
Total
2.8000e-
2.1000e-
2.4400e-
1.0000e-
7.7000e-
1.0000e-
7.7000e-
2.0000e-
1.0000e-
2.1000e-
0.0000
0.6679
0.6679
2.0000e-
0.0000
0.6684
II
004
004
003
005
004
005
004
004
005
004
005
3.5 Building Construction - 2022
Unmitigated Construction On -Site
i ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
-
tons/yr
MT/yr
Off -Road
, 0.2158 •
1.9754 •
2.0700
, 3.4100e- •
003 :
: 0.1023 •
;
0.1023 •
:
:
0.0963 •
:
0.0963
; 0.0000 •
i
d
293.1324
: 293.1324 •
0.0702 •
0.0000 : 294.8881
Total
0.2158
1.9754
2.0700
3.4100e-
003
0.1023
I 0.1023 I
0.0963
0.0963
0.0000
293.1324
293.1324
0.0702
0.0000
294.8881
CaIEEMod Version: CaIEEMod.2016.3.2 Page 19 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.5 Building Construction - 2022
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling
Vendor .,
Worker .,
, 0.0000 :
0.0527 •
0.4088 •
0.0000 :
1.6961 ,
0.3066 ,
0.0000
0.4580 ,
3.5305
: 0.0000 :
4.5500e- •
003
, 0.0107 ,
0.0000
0.1140
1.1103
: 0.0000 :
, 3.1800e- •
003
, 8.8700e- •
003
0.0000 :
0.1171 •
1.1192 ,
0.0000
0.0329
0.2949
: 0.0000 :
, 3.0400e- ,
003
, 8.1700e- •
003
0.0000
i 0.0000
; 0.0000
i 0.0000
0.0000 :
441.9835 ,
966.8117 ,
0.0000 :
441.9835 •
966.8117 •
0.0000 :
0.0264 •
0.0266 •
0.0000 : 0.0000
0.0000 , 442.6435
0.0000 T 967.4773
Total II
0.4616
2.0027
3.9885
0.0152
1.2243
0.0121
1.2363
0.3278
0.0112
0.3390
0.0000
1,408.795
2 1,408.795
2 0.0530
0.0000
1,410.120
8 Mitigated Construction On -Site
i ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
-
tons/yr
MT/yr
Off -Road
, 0.2158 •
1.9754 •
2.0700
, 3.4100e- •
003 :
: 0.1023 •
;
0.1023 •
:
:
0.0963 •
:
0.0963
; 0.0000 •
E
I
293.1321
: 293.1321
: 0.0702 •
0.0000 : 294.8877
Total
0.2158
1.9754
2.0700
3.4100e-
003
0.1023
I 0.1023 I
0.0963
0.0963
0.0000
293.1321
293.1321
0.0702
0.0000
294.8877
CaIEEMod Version: CaIEEMod.2016.3.2 Page 20 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.5 Building Construction - 2022
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling
Vendor .,
Worker .,
, 0.0000 :
0.0527 •
0.4088 •
0.0000 :
1.6961 ,
0.3066 ,
0.0000
0.4580 ,
3.5305
: 0.0000 :
4.5500e- •
003
, 0.0107 ,
0.0000
0.1140
1.1103
: 0.0000 :
, 3.1800e- •
003
, 8.8700e- •
003
0.0000 :
0.1171 •
1.1192 ,
0.0000
0.0329
0.2949
: 0.0000 :
, 3.0400e- ,
003
, 8.1700e- •
003
0.0000
i 0.0000
; 0.0000
i 0.0000
0.0000 :
441.9835 ,
966.8117 ,
0.0000 :
441.9835 •
966.8117 •
0.0000 :
0.0264 •
0.0266 •
0.0000 : 0.0000
0.0000 , 442.6435
0.0000 T 967.4773
Total II
0.4616
2.0027
3.9885
0.0152
1.2243
0.0121
1.2363
0.3278
0.0112
0.3390
0.0000
1,408.795
2 1,408.795
2 0.0530
0.0000
1,410.120
8 3.5 Building Construction - 2023
Unmitigated Construction On -Site
i ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
,
MT/yr
Off -Road
, 0.1942 •
1.7765 •
2.0061
, 3.33000- •
003
: 0.0864 •
0.0864 •
:
0.0813 •
0.0813
; 0.0000 • 286.2789 : 286.2789 •
s
0.0681 •
0.0000 : 287.9814
Total
0.1942
1.7765
2.0061
. 30 e-
3.3300e-
0.0864
0.0864
0.0813
0.0813
0.0000
1286.2789
1286.2789
0.0681
0.0000
287.9814
CalEEMod Version: CalEEMod.2016.3.2 Page 21 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.5 Building Construction - 2023
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling
, 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 i 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
•,
r
Vendor
0.0382 • 1.2511 , 0.4011 • 4.3000e- • 0.1113 , 1.4600e- • 0.1127 • 0.0321 , 1.4000e- , 0.0335 ; 0.0000 417.9930 , 417.9930 • 0.0228 • 0.0000 , 418.5624
003 003 003
•,
r
Worker
0.3753 • 0.2708 , 3.1696 , 0.0101 , 1.0840 , 8.4100e- • 1.0924 , 0.2879 , 7.7400e- • 0.2957 ; 0.0000 909.3439 , 909.3439 • 0.0234 • 0.0000
003
003
Total
0.4135
1.5218
3.5707
0.0144
1.1953
9.8700e-
1.2051
0.3200
9.1400e-
0.3292
0.0000
1,327.336
1,327.336
0.0462
0.0000
1,328.491
II
003
003
9 9
6 Mitigated Construction On -Site
i ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
,
MT/yr
Off -Road
, 0.1942 •
1.7765 •
2.0061
13.3300e- •
003
I 0.0864 •
0.0864 •
I
0.0813 •
0.0813
; 0.0000 • 286.2785 1286.2785
s
I 0.0681 •
0.0000 1287.9811
Total
0.1942 I
1.7765 I
2.0061
. 30 e-
3.3300e-
0.0864
0.0864
0.0813
0.0813
0.0000
1286.2785
1286.2785
0.0681
0.0000
287.9811
CaIEEMod Version: CaIEEMod.2016.3.2 Page 22 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.5 Building Construction - 2023
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 i 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
7,
r
Vendor
0.0382 • 1.2511 , 0.4011 • 4.3000e- • 0.1113 , 1.4600e- • 0.1127 • 0.0321 , 1.4000e- , 0.0335 i 0.0000 417.9930 , 417.9930 • 0.0228 • 0.0000 , 418.5624
003 003 003
7,
r
Worker
0.3753 • 0.2708 , 3.1696 , 0.0101 , 1.0840 , 8.4100e- • 1.0924 , 0.2879 , 7.7400e- • 0.2957 i 0.0000 909.3439 , 909.3439 • 0.0234 • 0.0000
003
003
Total
0.4135
1.5218
3.5707
0.0144
1.1953
9.8700e-
1.2051
0.3200
9.1400e-
0.3292
0.0000
1,327.336
1,327.336
0.0462
0.0000
1,328.491
II
003
003
9 9
6 3.6 Paving - 2023
Unmitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off -Road -, 6.7100e- , 0.0663 : 0.0948 , 1.5000e- , , 3.3200e- , 3.3200e- , , 3.0500e- , 3.0500e- i 0.0000 13.0175 , 13.0175 , 4.2100e- , 0.0000 , 13.1227 003 004 003 003 003 003
E 003 ;
r. -1 i -, -. -, -r *
-6 -i -, t
Paving , 0.0000 , , 0.0000 , 0.0000 , , 0.0000 , 0.0000 i 0.0000 : 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
I
Total
6.7100e-
0.0663
0.0948
1.5000e-
3.3200e-
3.3200e-
3.0500e-
3.0500e-
0.0000
13.0175
13.0175
4.2100e-
0.0000
13.1227
003
004
003
003
003
003
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 23 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.6 Paving - 2023
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 i 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
7,
r
Vendor
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker •,
3.7000e- • 2.7000e- , 3.1200e- , 1.0000e- , 1.0700e- , 1.0000e- • 1.0800e- , 2.8000e- , 1.0000e- • 2.9000e- } 0.0000
0.8963 , 0.8963 • 2.0000e- • 0.0000 , 0.8968
004
004
003
005
003
005
003
004
005
004
005
Total
3.7000e-
2.7000e-
3.1200e-
1.0000e-
1.0700e-
1.0000e-
1.0800e-
2.8000e-
1.0000e-
2.9000e-
0.0000
0.8963
0.8963
2.0000e-
0.0000
0.8968
II
004
004
003
005
003
005
003
004
005
004
005
Mitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off -Road •, 6.7100e- , 0.0663 : 0.0948 , 1.5000e- , , 3.3200e- , 3.3200e- , , 3.0500e- , 3.0500e- ; 0.0000 13.0175 , 13.0175 , 4.2100e- , 0.0000 , 13.1227 003 004 003 003 003 003
E 003 ;
r. -1 i -, -. -, -r *
-6 -i -, t
Paving , 0.0000 , , 0.0000 , 0.0000 , , 0.0000 , 0.0000 $ 0.0000 : 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
I
Total
6.7100e-
0.0663
0.0948
1.5000e-
3.3200e-
3.3200e-
3.0500e-
3.0500e-
0.0000
13.0175
13.0175
4.2100e-
0.0000
13.1227
003
004
003
003
003
003
003
CalEEMod Version: CalEEMod.2016.3.2 Page 24 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.6 Paving - 2023
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 ; 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
f
T 7 1 l l l l 7 l 4
1 1 l
Vendor 7,
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 ; 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
T
Worker •,
3.7000e- • 2.7000e- , 3.1200e- , 1.0000e- , 1.0700e- , 1.0000e- • 1.0800e- , 2.8000e- , 1.0000e- • 2.9000e- ; 0.0000
0.8963 ' 0.8963 • 2.0000e- • 0.0000
004
004
003
005
003
005
003
004
005
004
005
Total
3.7000e-
2.7000e-
3.1200e-
1.0000e-
1.0700e-
1.0000e-
1.0800e-
2.8000e-
1.0000e-
2.9000e-
0.0000
0.8963
0.8963
2.0000e-
0.0000
0.8968
II
004
004
003
005
003
005
003
004
005
004
005
3.6 Paving - 2024
Unmitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off -Road 7, 0.0109 : 0.1048 : 0.1609 : 2.5000e- , , 5.1500e- , 5.1500e- , , 4.7400e- , 4.7400e- ; 0.0000 22.0292 : 22.0292 : 7.1200e- , 0.0000 : 22.2073 III 1 004 003 003 003 003
E 003 :
al
I
Cl 1 1 1 1 1 1 1 1 T 11
1 1 T
Paving , 0.0000 , , 0.0000 , 0.0000 , , 0.0000 , 0.0000 ; 0.0000 : 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
i
Total
0.0109
0.1048
0.1609
2.5000e-
5.1500e-
5.1500e-
4.7400e-
4.7400e-
0.0000
22.0292
22.0292
7.1200e-
0.0000
22.2073
004
003
003
003
003
003
CalEEMod Version: CalEEMod.2016.3.2 Page 25 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.6 Paving - 2024
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 i 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
•
7 1 l l l l 7 l T *
1 , l
Vendor 7,
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
T
Worker •,
5.9000e- • 4.1000e- , 4.9200e- , 2.0000e- , 1.8100e- , 1.0000e- • 1.8200e- , 4.8000e- , 1.0000e- • 4.9000e- } 0.0000
1.4697 ' 1.4697 • 4.0000e- • 0.0000 , 1.4706
004
004
003
005
003
005
003
004
005
004
005
Total
5.9000e-
4.1000e-
4.9200e-
2.0000e-
1.8100e-
1.0000e-
1.8200e-
4.8000e-
1.0000e-
4.9000e-
0.0000
1.4697
1.4697
4.0000e-
0.0000
1.4706
II
004
004
003
005
003
005
003
004
005
004
005
Mitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Off -Road 7, 0.0109 : 0.1048 : 0.1609 : 2.5000e- , , 5.1500e- , 5.1500e- , , 4.7400e- , 4.7400e- ; 0.0000 22.0292 : 22.0292 : 7.1200e- , 0.0000 : 22.2073 III i 004 003 003 003 003
E 003 :
Cl 1 1 1 -: 1 1 1 T 11
d
1 1 T
Paving , 0.0000 ,, 0.0000 , 0.0000 , , 0.0000 , 0.0000
; 0.0000 : 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
i
Total
0.0109
0.1048
0.1609
2.5000e-
5.1500e-
5.1500e-
4.7400e-
4.7400e-
0.0000
22.0292
22.0292
7.1200e-
0.0000
22.2073
004
003
003
003
003
003
CaIEEMod Version: CaIEEMod.2016.3.2 Page 26 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.6 Paving - 2024
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling 7,
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 } 0.0000
0.0000 : 0.0000 • 0.0000 : 0.0000 : 0.0000
Vendor
, 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker •,
5.9000e- • 4.1000e- , 4.9200e- , 2.0000e- , 1.8100e- , 1.0000e- • 1.8200e- • 4.8000e- , 1.0000e- • 4.9000e- } 0.0000
1.4697 , 1.4697 • 4.0000e- • 0.0000
004
004
003
005
003
005
003
004
005
004
005
Total
5.9000e-
4.1000e-
4.9200e-
2.0000e-
1.8100e-
1.0000e-
1.8200e-
4.8000e-
1.0000e-
4.9000e-
0.0000
1.4697
1.4697
4.0000e-
0.0000
1.4706
II
004
004
003
005
003
005
003
004
005
004
005
3.7 Architectural Coating - 2024
Unmitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Archit. Coating -: 4.1372 : : 0.0000 : 0.0000 : : 0.0000 : 0.0000 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
d
d
Off -Road •, 3.1600e- • 0.0213 • 0.0317 • 5.0000e- • • 1.0700e- • 1.0700e- • • 1.0700e- • 1.0700e- ; 0.0000 • 4.4682 • 4.4682 • 2.5000e- • 0.0000 • 4.4745 003 ;
;
; 005 ;
; 003 ;
003 ;
; 003 ;
003
Z
; ;
004 ;
Total
4.1404
0.0213
0.0317
5.0000e-
1.0700e-
1.0700e-
1.0700e-
1.0700e-
0.0000
4.4682
4.4682
2.5000e-
0.0000
4.4745
005
003
003
003
003
004
CaIEEMod Version: CaIEEMod.2016.3.2 Page 27 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.7 Architectural Coating - 2024
Unmitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling
, 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 i 0.0000
0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
Vendor .,
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 ; 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker .,
0.0101 • 6.9900e- , 0.0835 , 2.8000e- , 0.0307 , 2.3000e- • 0.0309 , 8.1500e- , 2.2000e- • 8.3700e- ; 0.0000
24.9407 , 24.9407 • 6.1000e- • 0.0000
003
004
004
003
004
003
004
Total
0.0101
6.9900e-
0.0835
2.8000e-
0.0307
2.3000e-
0.0309
8.1500e-
2.2000e-
8.3700e-
0.0000
24.9407
24.9407
6.1000e-
0.0000
24.9558
II
003
004
004
003
004
003
004
Mitigated Construction On -Site
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Archit. Coating •: 4.1372 : : 0.0000 : 0.0000 : : 0.0000 : 0.0000 ; 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000
d
d
Off -Road •, 3.1600e- • 0.0213 • 0.0317 • 5.0000e- • • 1.0700e- • 1.0700e- • • 1.0700e- • 1.0700e- ; 0.0000 • 4.4682 • 4.4682 • 2.5000e- • 0.0000 • 4.4745 003 ;
;
; 005 ;
; 003 ;
003 ;
; 003 ;
003
Z
; ;
004 ;
Total
4.1404
0.0213
0.0317
5.0000e-
1.0700e-
1.0700e-
1.0700e-
1.0700e-
0.0000
4.4682
4.4682
2.5000e-
0.0000
4.4745
005
003
003
003
003
004
CaIEEMod Version: CaIEEMod.2016.3.2 Page 28 of 44
Village South Specific Plan (Proposed) - Los Angeles -South Coast County, Annual
3.7 Architectural Coating - 2024
Mitigated Construction Off -Site
Date: 1/6/2021 1:52 PM
ROG
NOx
CO
SO2
Fugitive
PM10
Exhaust
PM10
PM10
Total
Fugitive
PM2.5
Exhaust
PM2.5
PM2.5
Total
Bio- CO2
NBio- CO2
Total CO2
CH4
N2O
CO2e
Category
tons/yr
MT/yr
Hauling
, 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 : 0.0000 } 0.0000
0.0000 : 0.0000 • 0.0000 : 0.0000 : 0.0000
r
Vendor .,
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000 } 0.0000
0.0000 , 0.0000 , 0.0000 , 0.0000 , 0.0000
r
Worker .,
0.0101 • 6.9900e- , 0.0835 , 2.8000e- , 0.0307 , 2.3000e- • 0.0309 • 8.1500e- , 2.2000e- • 8.3700e- } 0.0000
24.9407 , 24.9407 • 6.1000e- • 0.0000
003
004
004
003
004
003
004
Total
0.0101
6.9900e-
0.0835
2.8000e-
0.0307
2.3000e-
0.0309
8.1500e-
2.2000e-
8.3700e-
0.0000
24.9407
24.9407
6.1000e-
0.0000
24.9558
II
003
004
004
003
004
003
004
4.0 Operational Detail - Mobile
4.1 Mitigation Measures Mobile
CaIEEMod Version: CaIEEMod.2016.3.2