Dear community and friends of #saveflamingoheights,

THE DEADLINE TO SUBMIT YOUR 2ND ROUND OF COMMENTS AGAINST THIS DEVELOPMENT IS RAPIDLY APPROACHING. They are due April 21 at 4:30PM!! Thank you for taking the time to submit these comments and participate in this important effort! This email should help you construct your own email to Jim Morrissey, the Contract Planner for this project with SB County. And of course, please SPREAD THE WORD! 

Make sure to include the following information in your response to Jim Morrissey

email: jim.morrissey@lus.sbcounty.gov
Subject: Project # PROJ-2020-00191, Assessor Parcel Number (APN) 0629-181-01

HERE ARE SOME OF THE TALKING POINTS YOU CAN INCLUDE!!! Express your own and feel free to borrow from the below, a mix of those drafted by us, neighbors adjacent to the property as well as the ever helpful Chris Clarke.

OPENING STATEMENTS:
- I hope you have had time to thoughtfully read through all the emails you are receiving about this project.
- I am deeply disheartened to find that this project is being moved forward without a proper and diligent Environmental Impact Report. After reading through the Draft study, I was shocked by the outright flimsy and dishonest work done to hastily try to pass this project through backchannels without the support or consultation with the surrounding community and with blatant disregard of the local ecological environment. I write here to impress upon you the disastrous effect this project will have on our lands as proposed, and hope that my voice along with the others of our community will manage to at the very least persuade the county to require a thorough and unbiased Environmental Impact Report before this project moves along any further.

GENERAL POINTS:
- this project should be abandoned but if proceeds we DEMAND a full Environmental Impact Report (EIR); an EIR actually gives us a hook to get into court to block this gross development
- after every instance of you pointing out insufficient information - or discussion of a topic, it would be good to include a sentence to the effect of “This information should be provided in a full Environmental Impact Report.”

ENVIRONMENTAL HAZARD
- Mojave Desert Land Trust and the Center for Biological Diversity have both deemed this a wildlife corridor
- the project would block the entire width of an important wildlife connectivity corridor between the San Bernardino Mountains, Joshua Tree National Park, and the central Mojave
- On page 27, the Initial Study claims that the project won’t contribute to habitat fragmentation because permanent structures would not physically block wildlife migration. But building and human presence on the rim of the wash may very well dissuade wildlife species from migrating through Pipes Canyon if those species are wary of any contact with humans. Examples could include desert bighorn sheep and mountain lion. Fuller discussion is needed.
- There are hundreds of western Joshua trees (Yucca brevifolia) on the developable section of the property. Joshua trees are a state protected species being considered for listing as Threatened under the California Endangered Species Act. At this time, the County cannot issue a permit to take (by removal or transplanting any individual) western Joshua trees.
- Joshua trees may still be listed by the California Fish and Game Commission in June. The county suggests that as Joshua trees and other desert plants will be avoided or relocated, there’s no significant impact. Joshua trees generally die after relocation, as do mature mesquites. Relocating a creosote ring might work technically but destroys the prehistoric value of the plant.
- the contention on page 14 that there will be no impact to forestland because the trees will be moved elsewhere is pretty laughable
There are potential creosote clonal rings in excess of 4,000 years old on the site. Yucca clonal rings of similar age may exist. A 2006 study by leading tortoise experts found seven adult desert tortoises on the developable section of the property. The proponents’ recent study finding no tortoises is methodologically suspect.
- The Initial study claims “There are no desert tortoise occurrences documented on site or directly adjacent to it…Desert Tortoise are therefore currently absent from the Project Site” Neighbors of the site have evidence to the contrary. Worth mentioning in as many comments as possible. WE HAVE THOSE PICTURES.
- Study claims “LeConte’s thrasher was neither observed nor detected on-site during the avian auditory and visual survey. Therefore, LeConte’s thrasher is currently absent from the project site.” However, community scientists have documented multiple observations of LeConte’s thrasher within a mile of the site in the last three years. Though they’re not strong fliers, they do so on occasion, and it’s hard to imagine a local population not taking advantage of a square mile of habitat.
- Study also doesn’t offer any details about the survey: how long was it? How many observers? What time of year? What were conditions?
- Other wildlife species using the site include burrowing owls, coyotes, migratory bird species, badger, desert kit fox, Gambel’s quail, and Bendire’s thrasher.

VISUAL IMPACT
- visual impact on scenic vistas
- If something is up to code and compliant with zoning ordinances it does NOT mean there’s no significant visual impact

LIGHT POLLUTION
- the report’s specifications on night lighting is half assed/not specific enough
- Dark skies: The county says that new light pollution and glare from the glamping site will not constitute a significant impact because the project will abide by the recently revised light trespass ordinance in San Bernardino County. As one of the authors of that ordinance (which I intend to point out in NPCA’s comments) this is hogwash. The point of the light trespass ordinance was to establish basic minimum standards to prevent glare and light trespass, leading not only to darker skies but also increased public safety. While the ordinance *will* reduce the impact of existing lighting as it is phased in, it does *not* mean new construction in a formerly dark area will not introduce a new source of light where none existed before. Again, simple compliance with the law is NOT equivalent to no impact.
- Also, 12 feet in height for pole lighting does not guarantee compliance with the light trespass ordinance. The light sources will still be visible from neighboring properties, and (dangerously) from the highway.

AIR QUALITY
- Air quality impacts from visitor traffic are based in the initial study on an assumption of 20 vehicles per hour for a total of 200 vehicle trips. However, this assumes not only that visitors will arrive at times staggered throughout the day, rather than within a few hours on a Friday night (and similarly leaving on Sunday morning) but also that once arrived, visitors will not make multiple trips to Joshua Tree NP, to Pioneertown, to Coachella or even a few hundred yards up the road to La Copine. Given that the proponents expect a maximum visitorship of 300 and as many as 50 seasonal employees arriving at the site each day, 200 vehicles may be a conservative estimate.
- There is a number missing from the narrative on page 19 in the Air Quality section, in which the first paragraph ends “However, the distance to the proposed campground improvements are approximately (insert number) feet.” This could be used to bolster the point that this document was prepared hurriedly and with no real attention to detail.
- The Helipad is mentioned in the beginning of the document (page 2)  as taking up 7,854 square feet, but emissions from helicopters are not mentioned in the air quality section.
- Dust from construction, with wind, would be hazardous to the surrounding human community and wildlife

TRAFFIC SAFETY
- Route 247 is a dangerous high-speed highway. Adding a destination which hundreds of vehicles will be entering and exiting on a particularly hazardous stretch of the road is a bad idea. First responder response times can be lengthy. Safety would require adding an additional lane and even a vehicle-controlled stoplight. A traffic study is warranted.
- The Initial Study estimates the project would generate 16 morning peak hour trips and 20 evening peak hour trips. Justification for this assumption, which appears elsewhere in the study, is scant. Moreover, no discussion of seasonal and weekly patterns in additional traffic is included. This lack of information suggests that a traffic study is needed, but the study proposes exempting the developer from a Traffic Impact Study that would help answer exactly these questions.
- A similar point could be made regarding the exemption from a Vehicle Miles Traveled assessment as described on page 64, given that that exemption is based on the assumption that fewer than 110 average daily trips will be generated as a result of the project.
- The importance of this cannot be overemphasized. Additional traffic on a high-speed two lane cannot be treated with this level of disregard.
- In the last five years there have been more than a dozen accidents in the stretch of highway between  Aberdeen and Reche that were serious enough to have had first responder involvement. Adding more than 100 cars exiting and entering the highway here during busy hours will prove dangerous, especially given drivers who pick up speed once they emerge from Pipes Canyon south of the project. A thorough traffic study, dedicated turn lanes, and perhaps a stop light should be considered if the project goes forward. The likelihood of extra costs to the county for first responders should be assessed.
- I demand you do a traffic report.

NO AMENITIES OPEN TO THE PUBLIC
- According to the Notice of Availability sent out to neighbors, Glamping “destination resort” with support facilities, none of which are to be open to the public, including restaurants/bar, reception area/store, trails and paths, recreation buildings, and helipad on a 25-acre portion of a 640-acre parcel
- The county should confirm in writing that the owner will not be allowed to develop the music festival venue with helipad described in the project documents, or the bar and restaurant also described. We appreciate the verbal assurances from contract staff, but that change needs to be made formal and permanent.
- How does this project positively impact our community at all?
- Community members were given assurances that the music festival venue, helipad, restaurant and bar would be excluded from the project plan. Only the amphitheater has been dropped. The helipad is mentioned only once, in a description of the square footage of the physical plant. Similarly with the bar and restaurant, which would at the very least generate food waste  that offers a potential subsidy to raven and other animals that may affect populations of sensitive species such as the desert tortoise.

FIRE SAFETY
- inadequate analysis of fire safety in the report
- Winds get up to 20mph and upwards of 100mph in this proposed area
- Pipes Canyon is a natural break in the mountains through which high winds from the west are often funneled. Placing a campsite for hundreds of people at the mouth of Pipes Canyon means that any campfires lit during high wind events could easily spread eastward, threatening habitat and people’s homes. High winds also imply that trash discarded by careless campers will be distributed throughout the Landers area, an unsightly inconvenience to residents and a threat to local wildlife.
- Concentrating campfires in this area upwind of most of the Morongo Basin also means a new source of particulate matter pollution, a serious concern in the Basin during both winter months and the peak of fire season.
- The emissions of particulate matter and other pollutants from fire pits should be discussed in more detail; rather than simply assigning those emissions to a total category claimed to be at 0.0 tons per year of emissions.
- Back of the envelope calculations: fireplaces and wood stoves emit as much as 50 grams of particulate matter 2.5 microns or smaller (PM25) per hour. The four firepits on site will almost certainly emit more than that because of larger fires and less efficient burning, but even taking 50 grams PM25 per hour each as an assumption, and assuming an average of four hours of fires each day, that’s 292 kilograms of PM25emitted each year, a.k.a. .29 tons per year.
- Wood smoke can also include benzene, benzo(a)pyrene and dibenz(a,h)anthracene, carbon monoxide, formaldehyde, organic gases (including aldehyde gases and other respiratory irritants), nitrogen oxides, polycyclic aromatic hydrocarbons (PAHs), and dioxin. All of these are toxic. We deserve more than a dismissal of any need for analysis of their possible impact on downwinders.
- Odor: initial study claims that the nearest  “sensitive receptors” (a.k.a. potentially affected residents) are 800 feet away from the site, that odors from campfire smoke will not be significant. This is worth challenging as subject to personal sensitivities. Smoke every weekend from four bonfires might affect quality of life on a consistent basis even several miles downwind.

NOISE LEVELS
- Noise: no discussion of noise levels after 10 pm is included in the initial study. Unless the operators intend to enact and enforce a 10 pm curfew policy, this should be discussed in an environmental assessment. Noise from traffic on Old Woman Springs road would be appreciably lower during night-time “party” hours than the 50.6dBA cited during daytime hours.
-The Helipad is nowhere discussed in the noise section.

WATER
- Proponents’ plans suggest that wastewater will be directed to a leach field on the property, north of the resort. A stormwater retention basin will be sited immediately east of the sewage disposal leach field. What volume of wastewater is projected to be disposed of via this leach field (considering perhaps 200-300 guests in a typical weekend in season)? Are hydrology studies available that ensure this large addition of wastewater won’t infiltrate into neighbors’ wells (there are at least 61 domestic wells within a few miles downstream) or the aquifer serving Bighorn Desert View Water Agency? Would stormwater capture from the project’s hardened surfaces accentuate this percolation of sewage?
- Water use: the Initial study says that the project would consume 18,150 gallons of potable  water per day, a bit more than 20 acre-feet per year. The study compares this to an estimate of 14,568 gallons per day were the site to be developed to its maximal footprint for residential use at 82 units. The failure of attempts to develop residences on the land due to seismic hazards is not mentioned, nor is the fact that not developing the land instead of developing the resort would consume zero gallons per day. 

SEISMIC ACTIVITY
- A housing project on this site was denied permit due to a nearby earthquake fault. Though Flamingo 640 would be a much smaller development than that previous proposal, the plan still incorporates structures (camping “lofts,” as well as other guest amenities) that could pose a hazard during a quake, and which may disqualify the project from obtaining a Conditional Use Permit.

MORE TALKING POINTS
- Would the proposed project be accessible for those with physical limitations? How would the proposed project utilize local labor and contractors to support the local community? How would the campground keep their guests from trespassing on adjacent properties?
- The Morongo Basin needs additional camping capacity.  However, preference should be given to sites that are closer to the park, are preferably on land that is previously degraded, and which are more readily accessible by highways capable of bearing the increased traffic. Additionally, we favor development of campgrounds that are economically accessible to more potential visitors, so that families with less disposable income have a way to visit the high desert.

CLOSING POINTS
- Flamingo 640 it would convert valuable conservation land surrounded by low-density rural zoning into a traffic-choked playground for the more-affluent.
- I hope to see these comments addressed and again, will not be satisfied until a thorough and unbiased Environmental Impact report is conducted. 
- As a Rural Living community, we do not need a private "resort" experience or "hotel" in a rural zoned area that would do nothing to our community except add danger on the roads, add unnecessary hazard in an area already distinguished as a threat from wildfires, knowingly disrupt and destroy the natural environment, pollute the area with noise and light and change the character of our community irreparably. If one of the listed "objectives" for this development is to relieve camping congestion in the National park, then a safe and small public campsite and trails would do much less damage, not a private resort experience out of the price range of the residents who live here, or campers who would otherwise camp in the national park.

THANK YOU FOR TAKING THE TIME TO SUBMIT YOUR COMMENTS, EVERYONE.