Below we summarize by topic some of our concerns with the Wonder Inn Hotel/Resort Project.
The topics listed are generally (not all) consistent with the CEQA elements and correspond to our Stop Wonder Inn Response Comments to the Initial Study. You may find more detail in the Response Comments.
Community Setting
The Wonder Inn Project would be built in a unique rustic desert community of over a thousand people. At no time does the existence of this community or its residents appear in the Initial Study/Mitigated Negative Declaration, which instead repeatedly describes the setting as simply “undeveloped”.
Wonder Valley is not “undeveloped” but rather is developed in an idiosyncratic manner consistent with its historical origins in the Small Tract Act of 1938. Residences are on mostly 5-acre lots, scattered irregularly and sparsely across a broad, open desert basin, connected by dirt roads, interspersed with tracts of public lands, and tending to blend into the landscape. But, though almost invisible in this immense natural environment, the residents ARE there, and they add up to a community.
The 1019 residents (2020 Census) of Wonder Valley are spread across 147 square miles. Residents are diverse but mostly older (average age 59.3) and poorer, with a median income of $16,379 per the Desert Sun (2018). Wonder Valley is considered a Disadvantaged Unincorporated Community by LAFCO.
Why do people live here? Per the Wonder Valley Community Action Guide, part of the 2020 San Bernardino Countywide Plan, “As a community, Wonder Valley values:
- Rural Atmosphere. The large lots and space between properties give residents room to breathe. Wide open spaces allow residents to appreciate and maintain the solitary, laid-back lifestyle of this area.
- Natural Desert Beauty. Residents value the beautiful sunrises and sunsets, the dark and starry night skies and the desert views and wildlife.
- Community Spirit. Wonder Valley is a tight-knit community whose residents value self-reliance and neighborly support. The people have a respect for nature, freedom, privacy, and each other. Here, residents work together but also enjoy their independence and being left alone in solitude.”
Finally, “As a community, Wonder Valley aspires to maintain the Rural Atmosphere: Wonder Valley provides residents with a rural lifestyle on large lots with dark night skies.”
And they make sacrifices to live here. The community has challenges, including a harsh environment, isolation, and especially lack of public services. A current challenge the community is facing, due mostly to larger social and economic trends, is the accelerating growth of short-term rentals, which, on the one hand, bring money and opportunity into the community, but, on the other hand, can put pressure on housing stock, already stressed public services, and the cost of living, and can introduce other disruptions and nuisances.
The San Bernardino Countywide Plan Land Use Element Policy LU-4.5 requires that new development “be consistent with and reinforce the physical and historical character and identity of our unincorporated communities, as described…in the values section of the Community Action Guides” and that the community’s Aspirations statement be considered. However, the Initial Study does not discuss compliance or conflict with Policy LU-4.5 or even mention the existence of the Wonder Valley Community Action Guide.
The lack of description or even acknowledgement of the specifics and peculiarities of the setting – the baseline physical conditions – render much of the evaluation in the Initial Study inadequate and its determinations unreliable. Essentially, the Wonder Inn Project would create a shiny Castle on the Hill, dense, vertical, and dominant above a broad, flat, wild desert basin scattered with the small, dusty cottages of a disregarded community that is invisible in the Initial Study. The potential impacts on the community health and resources must be fully evaluated, and therefore a complete, certified EIR is essential.
PIECEMEALING
After the release of the Initial Study/Mitigated Negative Declaration, it was discovered that the Wonder Inn developers were publicly advertising the sale of 24 “luxury villa homes” which would be built on the remaining 113.4 acres they own adjacent to the Wonder Inn. Specifically, on the Modly.com website was found the following: “On the 160 acre site, we will be constructing 24 private villa homes, each sitting on a private 5-acre site. Each contemporary home will consist of 4 bedrooms and 3 bathrooms with all the amenities you’d expect including a swimming pool, hot tub, outdoor showers, fire pits, solar panels and an electric car charger. Homeowners can occupy the homes year-round or they can opt-in to have the hotel manage the homes for guests to rent them out at $1000 Average Daily Rate. This is a fantastic opportunity to own a second home which pays for itself. Residents can move into their Wonder Valley Villas by Q4, 2024. Lot prices will be starting at approximately $150,000.”
Wonder Inn developer Mr. Landver is on record in the press confirming the intention to place 2,000-square-foot villas on 5-acre lots. In February of 2023, Land Use Services denied having any knowledge of this plan.
The nondisclosure of this plan in the Initial Study qualifies as “piecemealing,” a practice prohibited by the California Environmental Quality Act (CEQA). As per the Association of Environmental Professionals, “Piecemealing or segmenting means dividing a project into two or more pieces and evaluating each piece in a separate environmental document, rather than evaluating the whole of the project in one environmental document. This is explicitly forbidden by CEQA, because dividing a project into a number of pieces would allow a Lead Agency to minimize the apparent environmental impacts of a project by evaluating individual pieces separately, each of which may have a less than-significant impact on the environment, but which together may result in a significant impact. Segmenting a project may also hinder developing comprehensive mitigation strategies.”
Clearly, in light of this undisclosed “second phase” of the Project a reconsideration of all potential impacts of the Project must be undertaken in the form of a complete Environmental Impact Report.
ENVIRONMENTAL JUSTICE
The California Environmental Quality Act (CEQA) requires Environmental Justice be included in the CEQA studies. Yet there is no mention of environmental justice or the Wonder Valley community, or any description whatsoever of the community, in the Initial Study/Mitigated Negative Declaration.
Environmental Justice is defined in government code as “the fair treatment of people of all races, cultures, and incomes with respect to the development, adoption, implementation, and enforcement of environmental laws, regulations, and policies.” “Fairness” means that “the benefits of a healthy environment should be available to everyone, and the burdens of pollution should not be focused on sensitive populations or on communities that already are experiencing its adverse effects.”
Wonder Valley is a low-income community. Residents are diverse but mostly older (average age 59.3) and poorer, with a median income of $16,379 per the Desert Sun (2018). Wonder Valley is considered a Disadvantaged Unincorporated Community by LAFCO. Many residents live here because it is affordable, or because they have health issues that the desert air helps to alleviate. Such residents must be considered in addressing environmental justice.
This project would have significant impacts upon our rural and underserved community. At minimum, the character of our community would be significantly impacted and devalued by the addition of this large, luxury hotel and event space that would be serving an economic demographic quite different from most of the residents. Our quality of life would be dramatically changed. And, at worst, our safety would be at risk, and lives and property may be lost due to the increasing demand upon Public Services in this already underserved community.
A complete Environmental Impact Report is required that would include the study of the environmental justice impacts of the Wonder Inn Project.
AESTHETICS
The landscape of an area defines its cultural, natural, and historic heritage. Scenic routes, special landscape features and vistas of all kinds contribute to a community’s character and aesthetic quality. They can also provide tourism-related economic opportunities for our local owned small businesses. Poorly planned development, such as the Wonder Inn Development, will impact and undermine these resources.
Consequently, growth-related problems can have negative effects on communities by threatening their scenic areas and setting a precedent. Preserving the integrity of scenic vistas requires consideration of both the area being viewed (the vista) and the point(s) from which it is seen (the viewing area). This development will alter and degrade the integrity of the scenic vista that is Wonder Valley.
Based on their own description of the project, with numerous tall structures, the stacked hotel rooms, the amount of site acreage used, the proposed Wonder Inn would have an adverse effect on the scenic vista of Wonder Valley and would NOT “blend into the surrounding area similar to the scattered large-lot residences.”
This large occupancy Hotel/Resort would not only change and degrade the existing visual character of the specific site, but also significantly change and degrade the existing and visual character of the surrounding areas and beyond, as this development would be seen for miles, including from vantage points in Joshua Tree National Park.
County Development Code Section 82.19.040 requires development be evaluated with consideration of areas with unique views of the County’s desert areas or any other aesthetic natural land formations. One of the attractions of Wonder Valley is its wide-open spaces, scenic views of mountains all around, expansive desert landscape and natural land formations. The proposed development would only detract from the open space. Also required by County Code to be considered is an area at least 200 feet to either side of Amboy Road, which is a County designated Scenic Route. In view of these factors, a special viewshed analysis must be performed, which was not included in the Initial Study.
And finally, per the same Development Code, “Structure placement and style shall be compatible with and shall not detract from the visual setting or obstruct significant views.” However, with numerous structures over 20 feet high and up to 35 feet high, including a water tank, geodesic domes, parking light poles, event center, statues, hotel rooms and more, all spread upon 25 acres, this proposed project would detract from the visual setting and obstruct significant views.
“Dark and starry night skies“ are one of the premier values specifically listed by residents in the Wonder Valley Community Action Guide. The Countywide Plan acknowledges the importance of dark skies to desert residents in Land Use Policy 4.7, which states: “We minimize light pollution and glare to preserve views of the night sky, particularly in the Mountain and Desert regions where dark skies are fundamentally connected to community identities and local economies.” If the Wonder Inn gets built it will cause a significant new source of substantial artificial light, skyglow or glare and would negatively affect and have an impact on the day and nighttime views in Wonder Valley and would also impact the well-being of the people who live and visit Wonder Valley. Wonder Valley is part of the “Dark Skies Trail” that includes the East Mojave Preserve and National Trails Monument, and dark skies are central to its identity and its economy. The Wonder Inn Project is not compatible with dark and starry night skies, and it will undermine the community that depends upon this asset.
AIR QUALITY
As it stands now the Mojave Desert Air Quality District is not in compliance with Federal EPA or State Standards. The Wonder Inn Project will increase air pollution in the area, especially PM 2.5 particles which enter the sinuses, lungs and blood stream of residents causing dementia, heart and lung disease and hypertension. PM 10 particulate pollution will also increase. Particulate matter will be increased by more traffic disturbing the desert crust. Of the 175 miles of roads in Wonder Valley 129 miles are dirt; guests at the proposed project will be driving around on these roads “exploring”, and even off-road vehicles are being offered to their guests by the Project in their promotions. So far unassessed is potential PCB contamination in the soil at the Project site which could be exposed and windblown during construction. It is difficult to have accurate readings of air pollution in Wonder Valley as the closest air monitoring facility, which is set up on concrete, is quite distant in Victorville, and is located to the east while the prevailing winds in Wonder Valley are from the west.
BIOLOGICAL RESOURCES
The threatened desert tortoise is present in the area, and contrary to the Initial Study the Project is within a California Department of Fish and Wildlife Terrestrial Significant Habitat with Connectivity Rank of 3. Whether the tortoise is present on the Project site itself remains unknown as there are serious issues with conflicting studies and inconsistent data attached to the Wonder Inn Proposal. These issues must be resolved and potential impacts to the endangered tortoise fully understood before this project is approved.
CULTURAL RESOURCES
Wonder Valley and the commercial building on the Project site (the “Pink Building”) are both of historical significance and must be evaluated for eligibility for the California Register of Historical Resources. The Wonder Valley homestead community with its still numerous “jackrabbit cabins” persists as a uniquely intact legacy of the Small Tract Act of 1938 and warrants evaluation as a historical district. As regards the Pink Building, it was built in 1962 as the headquarters of the Desert Electric Cooperative, locally owned and operated as a uniquely desert expression of the Rural Electrification Administration and a small-tract homestead community. It also warrants preservation as a historical building because of its origins and because its exterior is largely unchanged. The Initial Study failed to properly research the history of the building and therefore its recommendation that the building is not eligible as a historical resource is erroneous and must be rejected. A thorough Environmental Impact Report must be prepared to understand potential impacts upon the significance of these historical resources.
ENERGY
The electrical grid in Wonder Valley continues to have problems with shut-downs and power outages. The proposed Wonder Inn does not include solar power and would put a significant added strain on the already strained power grid in Wonder Valley. This issue was specifically not addressed in the Initial Study.
GEOLOGY AND SOILS
The type of septic system needed by the Wonder Inn would be governed by the EPA’s large-capacity septic systems (LCSSs) regulations, but no details relating to the size and environmental impact of a large commercial septic system was included in any of the Wonder Inn reports. Further, the developers have not demonstrated that the Project has soils capable of adequately supporting a Large Capacity Septic System and leach field, as no percolation test was included in the Initial Study. In fact, the only percolation test on file with County Environmental Health Services (EHS) is a rejected test. The Conditional Use Permit (CUP) application process requires inclusion of an EHS-approved percolation report in their application submittals if they need to build a new septic system, and without an approved percolation report the Wonder Inn CUP application should not have been even processed and should be withdrawn until completed.
An Environmental Impact Report (EIR) is needed to assess the impact of the clearing of 24 plus acres of the native creosote-galleta and other desert plants on soil erosion. Wonder Valley is located within a Sand Transport Path (STP), a geologic feature that is a wind-driven sand deposit over 140 miles long and is stabilized by the creosote plant. Once the plants are removed the soil is rapidly eroded and becomes fugitive dust. This soil erosion will result in an increase in dust storms already experienced in this area and will have a negative effect on residents and visitors to this area.
The Initial Study does not mention that the Project site is located less than 2 miles west of 2 active faults, the East Valley Mountain Fault and West Valley Mountain Fault. An EIR is needed to study:
- The safety of guests at the Wonder Inn and the impact of the increased population on emergency services during a potential string seismic ground shaking event which is an environmental justice concern.
- If the construction of the Wonder Inn project will result in the disturbance of any trace faults that extend from the East and West Valley Faults.
- To determine whether the current proposed building methods for the Wonder Inn take into consideration additional reinforcements that may be required to safely accommodate guests during a seismic event.
GREENHOUSE GASES
There isno indication in the Initial Study that the Project would use solar power. In one of the world’s sunniest places, that seems unreasonable.
Additionally, the Project estimates that it will only require a staff of 20. This number is not realistic for a 106-room hotel with restaurant and full-service spa that is promoted as a 5-star facility. According to www.hotelmanagement.net, a 100-room hotel supports 66 jobs at the hotel itself.
In addition to the 106 hotel guest rooms, the Wonder Inn hotel complex also advertises a 24-hour restaurant, a full-service spa and conference rooms year round. The Wonder Inn has also advertised that it would manage 24 future luxury villas located on the additional 113 adjacent acres owned by the Wonder Inn developers. It is highly unlikely that the Wonder Inn and its future planned developments would be able to maintain an appropriate level of service with a staff of less than 25 employees total over 3 shifts. It appears that this staffing number was presented to gain approval for a TNC water system, but in reality, is significantly under the staffing requirements of a hotel advertising the following offerings.
Local hotels and restaurants find hiring staff is currently more difficult than ever before due to the shortage of housing and new economic challenges.
The question is, where would all the new staff come from, and where would they live? Inexpensive housing, once abundant in Wonder Valley, has dried up as local homes are bought by new residents and investors, and renters already face diminishing options. It is unlikely that staff for the Project could be pulled from current available population, and therefore the Project would either force an increase in local population with new-housing impacts or require substantial commuting, resulting in an increase in greenhouse gases.
An Environmental Impact Report must be prepared to include realistic estimates on staffing and to fully evaluate impacts of the Wonder Inn Project on greenhouse gases.
HAZARDS AND HAZARDOUS MATERIALS
The presence of hazardous materials on the Project site is a real concern. There is a strong possibility the soil could be contaminated with PCBs (polychlorinated biphenyls) as the property was used as headquarters for an electrical cooperative in the 1960s. There is also a history of processing of gold ore on site, raising the concern of cyanide and mercury on the property. Finally, the presence of asbestos must be suspected in a building constructed in 1962. At a minimum, assessment for PCBs, mining wastes, and asbestos needs to be performed and a plan for remediation documented in a full Environmental Impact Report
HYDROLOGY
The County requires new development be connected to potable water. As the residents of Wonder Valley understand, the groundwater in Wonder Valley is not potable based on high levels of dissolved solids and naturally occurring contaminants. It was for this reason the County shut down our fire station and our Community Center’s kitchen. The Project plans to use the groundwater and treat it only cosmetically and not for potability.
The source of the water would be the Dale Basin Aquifer via a TNC or “transient non-community well,” defined as a public water system that does not regularly serve at least 25 of the same persons over six months of the year. The Project proposes to get away with relying on a TNC by insisting it will have no more than 20 employees, a number not realistic for a 106-room hotel with restaurant and full-service spa that is promoted as a 5-star facility.
Finally, there is currently insufficient study of the Dale Basin Aquifer and how the Project would impact the water table and the wells of nearby residents. According to California’s Groundwater Bulletin 118, total Groundwater Storage Capacity for the Dale Valley Aquifer was estimated at 2,000,000 acre feet (in 1975) and 3,500,000 acre foot (in 1979). The actual Groundwater in Storage was Unknown at that time. In the 48 years since that study was done, the population of Wonder Valley has increased dramatically, with more wells being added to draw upon the aquifer. In addition, no studies have been done to evaluate the aquifer and water levels following uses such as the jojoba farming and the numerous illegal large-scale marijuana grows (now shut down), nor the severe drought that has impacted California in recent years.
LAND USE AND PLANNING
The proposed Wonder Inn Initial Study/Mitigated Negative Declaration has failed to adequately evaluate the proposed project’s use of land in accordance with the Principles and requirements of the San Bernardino Countywide Plan, the Wonder Valley Community Action Guide and the California Environmental Quality Act (CEQA), and therefore SHOULD NOT be approved for construction by the Planning Commission.
The Countywide Policy Plan Land Use Element states as Principle: “New development should be focused in areas where there is potable water, wastewater treatment, roadways, and public services.” Wonder Valley, in its entirety, has no potable water, no septic systems, no wastewater treatment, mostly dirt and insufficient roadways, and grossly inadequate public services.
The County Plan further states in LU-4.5: “We require that new development be consistent with and reinforce the physical and historical character and identity of our unincorporated communities, as described in Table LU‐3 and in the values section of Community Action Guides. In addition, we consider the aspirations section of Community Action Guides in our review of new development.”
The proposed project ignores these guidelines and requirements entirely, including the Wonder Valley Community Action Guide, as the project would only degrade the rural atmosphere and the natural desert beauty, diminish the starry night skies and desert views, and take away much of the respect for solitude, privacy and community values. The Wonder Inn is not a small business that would serve the local community and is not compatible with our natural environment. The proposed Wonder Inn DOES NOT meet the requirements of Policy LU-4.5, the referenced Table LU-3 and the Wonder Valley Community Action Guide.
County Plan Policy LU-2.3 requires that “new development is located, scaled, buffered, and designed for compatibility with the surrounding natural environment and biodiversity.” This requirement was ignored in the Initial Study. The proposed Project is HUGE in comparison with the surroundings, with sheer number and size of proposed additional structures NOT fitting with the surroundings, and it definitely is NOT “located, scaled, buffered, and designed for compatibility with the surrounding natural environment and biodiversity” as required.
NOISE
“Quiet” was the word used most often by residents when discussing community strengths and opportunities in the process of developing the Wonder Valley Community Action Guide 2020. This fact was ignored in the Wonder Inn Initial Study, which failed to do an adequate noise study or to fully evaluate noise impacts from increased traffic, including off-road vehicles, and from special events. Note that the developers have advertised “Unique Adventures Tours” involving ATVs, all-terrain vehicles. On- and off-road traffic must be expected to increase throughout Wonder Valley with tourists “exploring;” this has not been evaluated. Special events are also part of the proposal but are not described or analyzed as sources of noise. Further, the Initial Study does not assess how urban and rural noise travels very differently where there are open spaces, or that the location of the Project is elevated in comparison with a large part of Wonder Valley.
POPULATION AND HOUSING
: The daily operations of the Wonder Inn would increase the population of Wonder Valley by approximately 220 people, including guests, visitors, and staff. This amounts to a 21.5% increase in the population relative to the Wonder Valley census data of 2020 showing 1,019 residents. As well, the Initial Study states “the project does not involve construction of new homes so it would not induce unplanned population growth”. But the Wonder Inn developers did not disclose their intention to build 24 luxury “villas” on the 113.4 acres adjacent to the planned Wonder Inn. They have advertised the as-yet unpermitted homes and offered purchasers of 5-acre lots the possibility of a $1,000/day rate for their villa once it is listed as a Short Term Rental and managed by the Hotel/ Inn. This proposal exploits a known loophole in the San Bernardino County’s Short Term Rental ordinance that allows single-family homes to be built as hotels in residentially zoned areas.
As well, per the California Environmental Quality Act (CEQA) the addition of the undisclosed housing development would be considered project piecemealing, which is prohibited.
Finally, the Project estimates that it will only require a staff of 20. This number is not realistic for a 106-room hotel with restaurant and full-service spa that is promoted as a 5-star facility. According to www.hotelmanagement.net, a 100-room hotel supports 66 jobs at the hotel itself.
In addition to the 106 hotel guest rooms, the Wonder Inn hotel complex also advertises a 24-hour restaurant, a full-service spa and conference rooms year round. The Wonder Inn has also advertised that it would manage 24 future luxury villas located on the additional 113 adjacent acres owned by the Wonder Inn developers. It is highly unlikely that the Wonder Inn and its future planned developments would be able to maintain an appropriate level of service with a staff of less than 25 employees total over 3 shifts. It appears that this staffing number was presented to gain approval for a TNC water system but in reality, is significantly under the staffing requirements of a hotel advertising the following offerings.
Local hotels and restaurants find hiring staff is currently more difficult than ever before due to the shortage of housing and new economic challenges.
The question is, where would all the new staff come from, and where would they live? Inexpensive housing, once abundant in Wonder Valley, has dried up as local homes are bought by new residents and investors, and renters already face diminishing options. It is unlikely that staff for the Project could be pulled from current available population, and therefore the Project would either force an increase in local population with new-housing impacts or require substantial commuting, resulting in an increase in greenhouse gases.
An Environmental Impact Report must be prepared to include realistic estimates on staffing and to fully evaluate impacts of the Wonder Inn Project on population and housing.
PUBLIC SERVICES
We currently do not have adequate Fire / Emergency Medical Services for our community. The addition of the proposed Wonder Inn would further increase the burden upon Wonder Valley’s Public Services. This Proposal estimates 160 daily guests, 40 visitors and 20 staff. That’s an additional 220 people added to our existing population of 1019, increasing demand for already stressed public services in our area by roughly 21%.
The closing of our fire station in 2017 increased our emergency response times to dangerous lengths. The distances in our 147-square-mile community were already a challenge. With the closing of Station 45 emergency response services now come all the way from Twentynine Palms, increasing response times by an average of an additional 10 minutes. This is not sufficient for saving lives or homes. To illustrate this point:
- A home fire doubles in size every minute. A cooking fire can completely engulf a home in 5 minutes. Wonder Valley has inadequate fire response times, which means in the event of a home fire in Wonder Valley, total loss of the home is highly likely.
- In the past 5 years – between January 2017 and January 2023, there have been over 33 structure fires in Wonder Valley that resulted in the total loss of property, with some families being left homeless. Sadly, some residents of Wonder Valley refer to the fire department as the “Slab Savers.”
- In the event of choking, drowning, or a heart attack, permanent brain damage begins after 4-5 minutes without oxygen. The current Emergency Medical Response times for Wonder Valley residents are already inadequate to save lives in the event of a life-threatening medical emergency.
And, the Wonder Inn Project would offer no real benefits to Wonder Valley residents. The fire department receives only 2.5% of the property taxes collected from the 4,634 property owners of Wonder Valley. So, the increase in tax revenue generated by this hotel would not be sufficient to cover the additional services needed to cover the extra burden they will create. Instead, in an underserved rural community, this proposed luxury resort – which would be the largest hotel in the Morongo Basin, would draw upon the already insufficient Public Services responsible for covering our vast undeveloped CSA70-M service area.
TRANSPORTATION
Initial Study estimates an additional 604/day vehicle trips to the Wonder Inn site; however, potential impacts of on-site events with non-registered guests are not addressed. Issues of potential traffic congestion in and out of the property at the intersection of Gammel and Amboy are not addressed. Exiting hazards on Amboy, especially from a rise in the road that interferes with line of sight, are not addressed; fatal accidents have occurred on this dangerous stretch in the past. No assessment has been done of impacts to unpaved Gammel Road, which borders the Project site and because of its location is likely to become a major route for guests heading to Joshua Tree National Park. The Initial Study does not address impacts from increased traffic throughout Wonder Valley from guest “exploration.” Importantly, of the 175 miles of road in Wonder Valley, 129 are dirt and are maintained by an annual assessment on residents. Road damage and impact on Wonder Valley road-grading priorities are issues of concern, as is air quality degradation from increased dust. Finally, study documents submitted regarding road modifications are not sufficient to assess impact and are inconsistent in stated mitigation reasons.
UTILITIES
We are concerned about the environmental impact of the construction of new wastewater systems and the expansion of the on-site utilities to accommodate a project the size of the Wonder Inn. At a minimum, an Environmental Impact Report (EIR) is needed to determine impacts on the community health and resources. We are concerned about the impact of the additional load on the local power grid, which is not sufficiently examined in the Initial Study. Also, is there enough available groundwater to serve this project and any future phased construction over drought conditions and multiple dry years? There is no proof that the Wonder Inn’s use of the Dale Basin Aquifer will be sufficient to serve the project and not impact the surrounding residential wells, as no recent studies have been completed to assess the health and availability of groundwater in the area. The developer’s studies make comparisons of the proposed resort to long-ago use of the property for a jojoba farm. This is irrelevant, as are the questionable methods used to compare them. The population of Wonder Valley has grown along with the increase in short-term rentals, it has been many years since the jojoba farm was active, and we currently are in a severe drought. The appropriateness of using a transient non-community water system (TNC) well, limited to a capacity of no more than 25 people, is also questionable based on the realistic staffing levels of a 106-room 5-star hotel. Finally, the Wonder Inn CUP should be withdrawn until a septic/ wastewater system or percolation test has been reviewed and approved by County Environmental Health Services, and an EIR will be needed to assess that the proposed future septic system will have an adequate capacity to serve the Wonder Inn.
WILDFIRE
Wonder Valley has numerous high wind events per year, that can have sustained winds of 25-35 mph and wind gusts of up to 60 mph. Winds like these usually come from the west, blowing towards the east – towards Wonder Valley from the more densely populated areas in the Morongo Basin. In addition, there are fire hazard zones to the west of Wonder Valley, as close as Yucca Valley. Wonder Valley is bordered by mountains on the north and south, creating a channel for high winds. As has been evident in the past several years of California’s devastating wildfires, high winds will move a wildfire very quickly.
There are only 2 paved east-west roads through Wonder Valley: Hwy 62 and Amboy. Both of these roads are little rural 2 lane roads. In the event that a wildfire moved through this area – especially the fast-moving wildfires that are fanned by the high winds that frequent our valley, these are the only roads that Wonder Valley residents would be able to evacuate through to the east to escape a fire. There are over 1,000 residents in Wonder Valley, plus 60 Short Term Rentals with guests. This luxury hotel will add about 220 people per their estimates, increasing population by roughly 20%. Is *one* 2 lane road enough to evacuate 1200+ people if a wildfire came from the west, moving east? Would emergency vehicles be able to get through? Our roads have soft, sandy shoulders, prohibiting passing around any other vehicles.