Dear Community,
The window to send in your comments to Contract Planner Jim Morrissey again this project closes tomorrow, 4/21 at 4:30 PM. Please submit your comments now. We need to overwhelm their inboxes with what we stand for - environmental and community integrity. Below I include another sample letter you can use to frame your own.
Send To:
email: jim.morrissey@lus.sbcounty.gov
Subject: Project # PROJ-2020-00191, Assessor Parcel Number (APN) 0629-181-01
Dear Jim Morrissey,
I hope you are taking the time to read through all the emails you are receiving about this project. As an adjacent property owner to the site, I am incredibly disheartened to find that this project is moving forward without a proper and diligent Environmental Impact Report. After reading through the Draft study, I was shocked by the outright 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. I have also attached pictures and coordinates of Desert Tortoises I have seen in the area along with a petition I started last year with nearly 4,000 signatures on it.
ENVIRONMENTAL HAZARD
Firstly, this project should be abandoned, but if you must continue this process, we DEMAND a full Environmental Impact Report (EIR). This project is an environmental hazard. Mojave Desert Land Trust and the Center for Biological Diversity have both deemed this area in question a wildlife corridor. 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 such as bighorn sheep, bobcats, and mountain lions from migrating through Pipes Canyon if those species are wary of any contact with humans.
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. The contention on page 14 that there will be no impact to forestland because the trees will be moved elsewhere is pretty laughable.
Joshua trees generally die after relocation, as do mature mesquites. Relocating a creosote ring destroys the prehistoric value of the plant. 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 near the site have evidence to the contrary.
The 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. This information should be provided in a full Environmental Impact Report.
The study also doesn’t offer any details about the survey: how long was it? How many observers? What time of year? What were the conditions?
Other wildlife species using the site include burrowing owls, coyotes, black-tailed jackrabbits, migratory bird species, badger, bobcats, desert kit fox, Gambel’s quail, and Bendire’s thrasher.
VISUAL IMPACT
The proposed project would have a severe visual impact on scenic vistas. I am an adjacent property owner to the glamping project proposal and bought property in Yucca Valley a few years ago as to avoid the gross overbuilding I encountered in San Francisco and Brooklyn during my times living there in the last ten years. The high desert is special and this project would strip it of its many peaceful and visual wonders. Please keep in mind that just because something is up to code and compliant with zoning ordinances it does NOT mean there’s no significant visual impact.
LIGHT POLLUTION
The proposed project would cause terrible light pollution. The report’s specifications on night lighting is not specific enough and my neighbors and I do not want this to effect our dark night 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. 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 (primarily of tourists who are not used to driving on the 247) will be entering and exiting on a particularly hazardous stretch of the road is a bad idea. For all the trips listed in my previous section on Air Quality (JTNP, Pioneertown, etc.) there would be more traffic coming into these places too that also have roads with traffic incidents (e.g. Pipes Canyon Road). 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.
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. We demand you do a traffic report.
The importance of this cannot be overemphasized. Additional traffic on a high-speed two lane cannot be treated with this level of disregard.
NO AMENITIES OPEN TO THE PUBLIC
This site is being proposed without any concern or care for its surrounding community. 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.
Furthermore, 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.
How does this project positively impact our community at all? There is obviously no consideration for the neighbors.
FIRE SAFETY
There is inadequate analysis of fire safety in the report. Winds get up to 20mph and upwards of 80mph 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.
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.
Also, the 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
There is no discussion of noise levels after 10 pm 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.
OTHER 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.
To close, Flamingo 640 meets none of these criteria. Instead, it would convert valuable conservation land surrounded by low-density rural zoning into a traffic-choked playground for the more-affluent. If you plan to build this site, build it somewhere else - closer to the 62 or the park if your concern is to house tourists coming from out of town.
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.
Jim, I hope you read this with thought and concern, and do not leave those in your fellow SB community feeling dismissed.
With disappointment,